DG ECHO is committed to maintain a large and varied partnership based on the assessment of the different capabilities, of the comparative advantages in responding to certain situations or circumstances, as well as on the recognition of the specific and diverse mandates given by the international community to some of its partners. DG ECHO recognises the vital role and added value of non-governmental organisations in providing humanitarian assistance, for their field presence, flexibility, specialisation, and for being a direct expression of active citizenship at the service of the humanitarian cause.
In order to better take account of the diversity of DG ECHO's partners and to establish a more effective control environment as imposed by the Financial Regulation, the FPA 2008 established differentiated control mechanisms of the humanitarian actions. The applicable control mechanisms are based on DG ECHO's ex ante assessment of the humanitarian organisation's internal control mechanisms and risk management, financial strength and procurement rules.
The expression control mechanism refers to the supervisory and monitoring procedure applied to each individual Agreement for identifying, assessing, and managing risks, carried out by the European Commission to provide reasonable assurance as regards the achievement of the objectives. The Special Conditions of the individual Agreements signed with the Contracting Authority expressly identify the control mechanism to be applied.
The applicable control mechanism will be established by DG ECHO based on the following three domains:
Upon signature of the Framework Partnership Agreement, the Commission shall inform the Humanitarian Organisation by registered letter of the control mechanism and related funding threshold applicable to the Actions. The Commission will revise this mechanism and threshold in the context of the annual assessment.
In accordance with Article 28a of the Financial Regulation, and in order to ensure a proportional approach of control and risk management, the Commission shall submit the Actions of the Humanitarian Organisation to an appropriate control mechanism which shall take one of the following two forms.
A – control mechanism (A standing for Action related monitoring) focuses on the monitoring of the Action's implementation through more extensive controls related to the final report and supported by ex post audits of the Actions and the compliance with the FPA conditions.
This mechanism does not require the same level of ex ante assurance with respect to the compliance of the procedures of the partner.
For grant agreements under A-control mechanisms, the partner must comply with stricter procurement rules, applicable for the award of contracts exceeding EUR 60.000, as defined in the Single Form (Annex I) and the “General Rules and Procurement Procedures” in Annex IV. The actions are subject to a maximum funding threshold per action. Above this threshold, additional controls will have to be implemented.
P – control mechanism (P standing for Prior assessment and own Procedures) based upon an ex ante assessment of the Humanitarian Organisation's own internal control, risk management and procurement procedures, supported by appropriate monitoring, some controls related to the final report and ex post audits of the implementation of the Humanitarian Organisation's own rules and procedures. This mechanism is applicable to those humanitarian actions where the partner's internal procedures are recognised as equivalent to those established in the FPA. In practical terms, this recognition is translated into greater flexibility in managing the humanitarian action. For instance, for grant agreements under P-control mechanisms, the partner applies its own procurement procedures. The humanitarian actions are not subject to contractual limits on funding.
In any case, the Humanitarian Organisation shall ensure:
If, with regard to the requirements established above, the Commission considers that the internal control and risk management procedures of the Humanitarian Organisation comply with the standards and best practices in the sector, that the procurement procedures comply with the Mandatory Principles and Special Rules defined in Annex IV and that the financial capacity of the Humanitarian Organisation is adequate, the Actions shall be submitted to the P-control mechanism.
The assessment of signatory Humanitarian Organisations will be regularly carried out by the Commission. As a result of the annual assessment, the Commission may confirm, suspend or terminate the FPA, and confirm or modify the control mechanism and the related funded threshold applicable to the organisation.
The assessment consists in a two-phase procedure. The first phase is carried out annually and is compulsory for all Humanitarian Organisations. It consists in an update of the information concerning the partners. An in-depth assessment takes place at least once every three years in a second phase. In this second phase DG ECHO updates the appraisal of the control mechanism to be applied to FPA-agreements by reassessing three main domains, being the financial strength of the organisation, the internal control and risk management procedures and the procurement rules. For the latter, DG ECHO Annex IV of the 2008 FPA is used as a benchmark, in accordance with article 2.4 of this Annex. For better transparency and in a spirit of good partnership, operational comments may be included, if relevant, in the conclusions of the partner assessment sent to partners. However, the result of the assessment, and particularly the modification in control mechanisms, does not express an opinion on the quality of the humanitarian aid activities undertaken by the organisation under review.
If the Humanitarian Organisation whose Actions are subject to the A-control mechanism, wishes the application of the P-control mechanism (see section on Take diversity into account), it may request a second phase assessment.
The Commission may at any time request the submission by the Humanitarian Organisation of any documents or information the Commission considers important for the assessment.
References and useful links