A traceability and control guide, not a predetermined conclusion.
It organises the alert, Regional Incentives file, ERDF identification, private/RIC funding, asset perimeter, costs and status of each control.
OPEN FILE · ALERT ≠ FRAUD · PLAQUE ≠ COMPLETE AUDIT
SNCA / ERDF: reconstruct what was received, what was checked and what expenditure was funded.
This route separates the anti-fraud channel, operation management, accounting/certification, inspection and control. It does not presume fraud or loss to the Union. It requires a reproducible trail from beneficiary and asset to invoice, payment, employment, certification and any correction or recovery.
SNCA file141-2026-IRR02
Controlled receiptREGAGE26e00069678966
Published subsidy€3,440,914.20
FundERDF identified; detail open
Proof of duplicate funding or loss to the EU budget.
An alert proves communication; a plaque proves public fund identification; an award proves the published act. Material outcome requires the file, expenditure, payment and verification.
THE CASE IN 7 MINUTES
Six layers that must remain separate and connected.
SNCA / Infofraud
What information entered, with which attachments, what checks were performed, what was preserved, what was referred and what status followed.
GC/836/P06
Hotel New Trend, S.L.; published investment €11,469,714; subsidy €3,440,914.20; 60 jobs.
ERDF identified
The permanent plaque identifies ERDF. Operation identifier, programme, rate, certified expenditure, payment and controls remain open.
Fragmented perimeter
The position documented within RICPE on 20 July 2021 distinguished 54 CAM, 190 LPB and 18 third-party units.
Source-and-use
Reconcile RICPE/RIC, subsidy, co-financing, own resources, bank/supplier funding, invoices and payments.
Verification and correction
Checks, audits, issues, certifications, financial corrections, recoveries and closure, if any.
AUDIT TRAIL
From asset to account: no institutional stamp replaces the previous link.
BeneficiaryHNT, group, related parties and capacity.
AssetUnit, right and availability.
WorkPackage, contract and supplier.
Invoice / paymentLine item, bank, date and amount.
EU expenditureEligibility, certification and rate.
ResultAsset, employment, indicator and use.
ControlVerification, audit, correction and recovery.
Dependency question: at each arrow, was the primary source checked or was an assertion inherited from the applicant, another authority or an earlier file?
WHAT CHANGED?
The 2021 fragmentation must be reconciled with the later funded operation.
20 JUL 2021
54 CAM / 190 LPB / 18 third parties; conditional acquisition, unsigned LOI and full DD not started.
WHAT PERIMETER WAS FUNDED?
AFTERWARDS
HNT/MYND, Regional Incentives support and ERDF identified. Each asset, work, cost, invoice, job and income stream should map to the relevant legal perimeter.
Boundary: fragmentation does not automatically invalidate the operation. It requires the file to show what was included, what was excluded and under which title or consent.
NUMBER CONTROL
Multiple sources are neither added nor normalised without reconciliation.
RICPE / prospectus
€1,598,849.78 works + €4,971,863.78 employment = €6,570,713.56.
Separate accounts reconstruction
€6,573,703.10. Difference from prospectus: €2,989.54, awaiting explanation.
GC/836/P06
Published subsidy €3,440,914.20 on €11,469,714 investment and 60 jobs.
No automatic conclusion: the amounts may concern different components, dates or accounting treatment. Proving overlap requires invoice, cost, asset, payment and period comparison; proving no overlap requires the same table.
DECISION TREE
How to move from an alert to a verifiable conclusion.
Is the information concrete?
Fact, file, beneficiary, amount, document, period and potential EU financial interest.
Which body is competent?
SNCA, ERDF management, accounting/certification, Incentives, inspection, IGAE or another.
What was checked?
Primary source, data cross-check, file, visit, invoice, payment or employment.
What outcome followed?
Reasoned closure, request, referral, investigation, correction, recovery or final closure.
MINIMUM PRODUCTION
A file an external auditor can reproduce.
- Complete index of 141-2026-IRR02.
- Infofraud / REG-AGE reconciliation.
- Alert, attachments and intake metadata.
- Classification, competence and referrals.
- Complete GC/836/P06 file.
- Application, memorandum and individual award.
- Property/right map and availability.
- ERDF operation identifier and operation sheet.
- Programme, priority, rate and beneficiary.
- Eligible costs and exclusions.
- Contracts, suppliers, invoices and payments.
- Other-aid and cumulation declarations.
- Consolidated source-and-use.
- Employment, FTE, persons and periods.
- Administrative and on-the-spot checks.
- Statements of expenditure and accounting function.
- Audits, issues and representations.
- Financial corrections and recoveries.
- Current status, closure and reasoning.
- Exculpatory or no-overlap evidence.
OPEN KIMONO · BEST CONTROL AND WARNING
Protecting the Union’s financial interests requires an open trail, not a black box.
Good SNCA / ERDF practice
- The alert is preserved with attachments and real status.
- Competence and referral are documented.
- Operation, beneficiary and expenditure are identified.
- Invoice, payment, certification and indicator are connected.
- Other aid and finance are reconciled.
- Contrary evidence can close or narrow the hypothesis.
- Correction and recovery, where applicable, remain traceable.
The opposite practice
- Channel used as a mailbox without status or custodian.
- Referral treated as investigation or solution.
- ERDF plaque used as substitute for the file.
- Award used as proof of final eligibility.
- Separate instruments used to avoid an invoice table.
- Employment declared without persons, period or FTE.
- Secrecy or silence converted into a merits answer.
Boundary: the comparison does not assert that SNCA, IGAE, DGFE or the regional authority engaged in every negative practice. It defines a public standard the file can meet, correct or fail.
SEPARATE FUNCTIONS
Anti-fraud, management, accounting/certification and control are not synonyms.
SNCA / Infofraud
Channel and anti-fraud function for concrete information on possible irregularities affecting EU funds; receipt is not acceptance.
ERDF management
The official structure assigns selection of operations and systems ensuring compliance of expenditure submitted for co-financing.
Accounting/certification and payments
The function manages statements of expenditure, payment applications, accounts and economic-financial monitoring.
Inspection and Control
Performs checks and proposes corrective measures; it also conducts state inspection/checks for Regional Incentives.
Regional Incentives
Award, conditions, execution, settlement and non-compliance retain their own file and bodies.
Intervención / audit
Public-resource control and applicable audits must remain distinct from anti-fraud intake and management.
Series F/G control: Series F/G · suitability → separates the 2022–2023 administrative authorisation, source-specific amounts and use-of-funds questions without treating them as a fraud finding.
CONNECTED ROUTES
GC/836/P06Award, execution, jobs, payment and compliance.CNMVRICPE governance, information, DD and re-entry.RICPEOrigin, conflict, controls and capital.RIC / taxMaterialisation and compatibility.ReconciliationAsset, invoice, job and euro.Clean roomOne factual base, different competences.AuthorityTitle, vote, access and perimeter.
Public status: the file and receipt establish communication. No investigation, conclusion, correction or recovery is published as fact without a supporting primary record.