EN    EN 
 
 
 EUROPEAN  
COMMISSION   
Brussels, 7.5.2015  
SWD(2015) 105 final  
  
COMMISSION STAFF WORKING DOCUMENT  
Relevant underlying factual information concerning the misrepresentation of data in the 
Autonomous Community of Valencia  
Accompanying the document  
Report from the Commission  
on the investigation related to the manipulation of statistics in Spain as referred to in 
Regulation (EU) 1173/2011 of the European Parliament and of the Council on the 
effctive enforcement of budgetary surveillance in the euro area (Commission Decision of  
11 July 2014)  
{COM(2015) 211 final}   
 
2 
 Table of Contents  
 
1. Institutional responsibilities in the framework of the EDP data reporting in Spain  ...........  4 
2. Overview of creditor accounts in the Spanish General Public Accounting Plan  ...............  8 
3. The compilation, recording and reporting of expenditures in the  AC of Valencia  .........  10 
3.1. Legal framework in the AC of Valencia  ................................ ................................ .... 10 
3.2. Units involved in the compilation, recording, reporting and control of EDP data in 
the AC of Valencia  ................................ ................................ ................................ ..... 11 
3.3. The workflow for public accounts and EDP data in the AC of Valencia  ..................  12 
3.3.1.  Compilation of Public Accounts: IGGV  ................................ ............................  12 
3.3.2.  Control of Public Accounts: the  Regional Court of Auditors  ...........................  13 
3.3.3.  The translation of public accounts into national accounts: IGAE  ......................  13 
3.4. The recording and reporting of data in extra -budgetary accounts (409, 411) and their 
impact on deficit (B.9)according to legal provisions  ................................ .................  17 
 
  
 
3 
 List of acronyms used  
 
AC - Autonomous Community ( Comunidad Autónoma ) 
B.9 - Government deficit/surplus  
CPFF - Fiscal and Financial Policy Council ( Consejo de Política Fiscal y Financiera ) 
EDP - Excessive Deficit Procedure  
ESA – European System of Accounts  
IGAE - National Audit Office ( Intervención General de la Administración del Estado ) 
IGGV - Regional Audit Office of Valencia ( Intervención General de la Generalitat 
Valenciana ) 
INE - National Statistical Institute ( Instituto Nacional de Estadística ) 
MoF - Ministry of Finance ( Consejería de Hacienda y Admistración Pública)  
PGCP - General Public Accounting Plan ( Plan General de Contabilidad Pública ) 
PGCPGV - General Public Accounting Plan of the AC of Valencia ( Plan General de 
Contabilidad Pública de la Generalitat Valenciana ) 
SQ - Standardised Questionnaire  
  
 
4 
 List of tables  
 
Table 1: Responsibilities in the framework of EDP reporting in Spain as regards Autonomous 
Communities  
Table 2: Work and data flow between the different units involved in the EDP data 
compilation in the AC of Valencia  
 
5 
 1. Institutional responsibilities in the framework of the EDP data 
reporting in Spain  
 
In Spain, the Technical Committee of National Accounts (formerly called National Accounts 
Working Group) is composed of the following three participati ng institutions:  
- National Statistics Institute ( Instituto Nacional de Estadística  - INE);  
- National Audit Office  (Intervención General de la Administración del Estado  - IGAE);  
- Bank of Spain  (Banco de España) . 
This Committee is led by INE and its role is limited to the classification of units, decisions on 
the treatment of special transactions and discussion of other horizontal issues. This 
Committee discusses only methodological issues. Issues related to qualit y of data are not 
discussed in this forum. The three institutions meet on a regular basis.  
The responsibilities of each of the participating institutions are laid down in the National 
Statistical Plan. As regards EDP compilation, the responsibilities are divided as follows:  
 INE is an autonomous body attached to the Ministry of Economy and Competitiveness. 
INE is the supreme statistical authority in Spain. The role of INE in EDP issues is limited. 
Its main responsibility relates to the participation in (and  chairing of) the Technical 
Committee of National Accounts to discuss methodological issues, with IGAE and the 
Bank of Spain. INE is also the co -ordinator of the EDP reporting of Spain to Eurostat. 
INE does not elaborate by itself the non -financial governm ent accounts, which are the 
responsibility of IGAE.  
 IGAE is part of the national Ministry of Finance. It is the internal control unit of the 
economic and financial management of the public sector at central government level. 
IGAE is responsible for the co llection of data on non -financial government accounts for 
the whole government sector. Moreover IGAE is responsible for the translation of the 
public accounts of the Autonomous Communities into national accounts.  
 Bank of Spain is responsible for compiling  both financial accounts and Maastricht debt of 
general government and is not involved in the compilation of non -financial accounts  
According to the Ministerial Order ORDEN HAC/2283/20031, the Regional Audit Office 
(Intervención General Regional)  of each Autonomous Community (hereinafter referred to as 
AC) is obliged to send data to IGAE.  
                                                            
1Ministerial Order HAC/228/2003 is available at the following link:  
https://www.boe.es/diario_boe/txt.php?id=BOE -A-2003 -16001  
From 2012 onwards: Ministerial Order HAP/2105/2012: https://www.boe.es/diario_boe/txt.php?id=BOE -A-
2012 -12423  
 
6 
 Every AC is responsible for sending correct data to IGAE in the context of EDP reporting.  
The accrual principle has to be respected.  
IGAE organises meetings on an ad -hoc basis, with the main aim to inform the Autonomous 
Communities about all methodological rules to be followed and about changes in national 
accounts (ESA 95)2. In addition, supplementary information (a Manual on the calculation of 
deficit in Nation al Accounts3) has been available on the website of IGAE from 2006 
onwards. Methodological notes stressing the importance of the accrual principle are also 
published on the website of IGAE.  
IGAE`s responsibilities are defined by law. IGAE does not have the same competences over 
Autonomous Communities in the same way in which they do for the other three government 
sub-sectors (central government, social security funds and local government), to adapt the 
norms of the General Public Accounting Plan (PGCP) to ea ch of them. In Autonomous 
Communities this responsibility is under the Intervenciones Generales Regionales ( Regional 
Audit Offices ). Moreover, Autonomous Communities can adapt to their own needs the 
general accounting plan of government.   
The Bank of Spai n is the National Central Bank and the supervisor of the Spanish banking 
system. As regards EDP statistics, the Bank of Spain is responsible for compiling both 
financial accounts and Maastricht debt of general government and is not involved in the 
compilat ion of non -financial accounts.  
The National Court of Auditors ( Tribunal de Cuentas)  is the external control unit of the 
economic and financial management of the public sector at central government level. It is not 
directly involved in EDP.  
Each AC is resp onsible for its General Budget and for compiling a set of public accounts 
(general account, integrated by the balance sheet, profit and loss account and a detailed 
report) on a yearly basis. The compilation of the accounts is the responsibility of the Regi onal 
Ministry of Finance ( Consejería de Hacienda y Admistración Pública ). A specific unit, the 
Regional Audit Office ( Intervención General Regional ), exists for this purpose within each 
Regional Ministry of Finance.  
The external control of public accounts  in the regions is carried out by the Regional Court of 
Auditors (in some Autonomous Communities by the National Court of Auditors).  
                                                            
2 The relevant reporting described in the current case was made under Co uncil Regulation (EC) No 2223/96 of 
25 June 1996 on the European system of national and regional accounts in the Community, OJ L 310, 
30.11.1996, p. 1, (ESA 95). Regulation (EU) No 549/2013 of the European Parliament and of the Council of 21 
May 2013 on th e European system of national and regional accounts in the European Union, OJ L 174, 
26.6.2013, p. 1, (ESA 2010) is applicable from 1 September 2014.  
3A Manual on the calculation of deficit in National Accounts in available on the following link: 
http://www.igae.pap.minhap.gob.es/sitios/igae/es 
ES/ContabilidadNacional/InformacionGeneral/Documents/Manual_AATT/ManualCCAA1Edicion2006b.pdf  
 
7 
 The coordination between the national Ministry of Finance (MoF) and the regional MoF in 
the Autonomous Communities is implemented in the framework of the Fiscal and Financial 
Policy Council (CPFF), which meets regularly.  
Public accounts in the Autonomous Communities are compiled by each Regional Ministry of 
Finance (Regional Audit Office when existing, if not, directly by the Regional Ministry of 
Finance).  Regional Audit Offices (or Regional ministries of Finance) transmit public 
accounts of the Autonomou s Communities to IGAE via the Standardised Questionnaire (SQ), 
agreed in the context of the CPFF. IGAE makes the conversion from the public accounts of 
the regions into national accounts and calculates the deficit figure in national accounts terms 
(ESA 95)  at both the regional and the national level.  
Table 1 shows the specific responsibilities of the different institutions involved in the 
framework of EDP work as regards Autonomous Communities and the relation between 
them.  
 
8 
 Table 1: Responsibilities in the framework of EDP data reporting in Spain as regards Autonomous Communities
 
Source dataCompiles public accounts;
Transmits them to IGAE; 
Framework of the CPFFTranslates
public 
accounts
into 
national
accounts
ESA 95Compilation
of EDP dataData
transmitted
by INE
Units
in the regional
government1
Regional
Audit
Office
(Regional MoF)2
IGAE3 National 
Accounts 
Working 
Group 
INE
IGAE
Bank of Spain4
Eurostat
5
Regional
Court of Auditors
External control of public accounts
at regional level
 
9 
 2. Overview of creditor accounts in the Spanish General Public 
Accounting Plan  
 
Expenditures incurred but not yet paid, which are the focus of this report, can be classified in 
the following three groups, and ranked according to the potential risk they may represent for 
a correct recording in public and national accou nts: 
1. Expenditures not yet paid, but imputed in the budget : expenditures registered in the 
budget are automatically recorded in public accounts and thus reflected in national 
accounts.  They are recorded in budgetary accounts.  
2. Expenditures not yet paid, not  imputed in the budget, but recorded in extra -budgetary 
accounts . They will be reflected in the national accounts when making the transition from 
public accounts. They are recorded in extra -budgetary accounts.  
3. Expenditures not yet paid, not imputed in the  budget and not recorded in extra -budgetary 
accounts , which means that these expenditures are not recorded in any standard public 
account, thus excluded from any reporting in national accounts4.  
The General Public Accounting Plan (PGCP) is the compulsory framework for public sector 
accounts at central government level. In the exercise of its competences, each AC is entitled 
to approve its own Public Accounting Plan in order to adapt it to the specific needs of the 
region, as long as it observes the princip les and general rules contained in the PGCP, which is 
the master framework for all Public Administrations. Thus, the public accounting plans at the 
level of AC can differ slightly among them, although they must all be in line with the PGCP, 
designed as gen eral framework for central government, and cannot be in contradiction with 
the PGCP. The accrual principle is a universal principle in the Spanish PGCP. The current 
version of the PGCP dates back to 20105.  
According to the Spanish accounting rules, the ex penditures must be imputed to the budget in 
the year in which they are incurred. This imputation must be preceded by a formal act of 
recognition of the obligation. If both the timing of the expenditure and the moment of 
recognition of the obligation fall i n the same year, a recording is made in the budgetary 
accounts.  
The creditor budgetary accounts are used to include expenditures already imputed in the 
annual budget but which have not yet been paid. As these expenditures have already been 
registered in th e budget, they are immediately reflected in the public accounts (although not 
                                                            
4 This type of expenditure should not exist. In practice, it reached considerable amounts exclusively in the AC of 
Valencia, as will be described later in this report.  
5 The current version of the PGCP can be found at the following link: 
http://www.boe.es/boe/dias/2010/04/28/pdfs/BOE -A-2010 -6710.pdf  
 
 
10 
 paid) and thus translated into national accounts, so that, as far as national accounts rules are 
concerned, the correct recording is assured.  
However, a period of time can occasi onally  elapse between the moment of the expenditure 
and the recognition of the obligation, causing a delay in the recording/allocation of the 
expenditure, and allowing a temporary entry in extra -budgetary creditor accounts.  
Creditor extra -budgetary accoun ts are designed for expenditures (with or without obligation 
to pay) already incurred but not yet paid, which have not been imputed in the annual budget.  
The amounts in extra -budgetary accounts must:  
1. As regards public accounts: be incorporated into the bu dget of the following year(s).  
2. As regards national accounts: be accounted for as expenditure in the deficit of the current 
year (year in which the expenditure incurred) in order to respect the accrual principle. 
This happens automatically if the expenditu res are correctly accounted for in the extra -
budgetary accounts, as these accounts are part of the SQ and are automatically recorded 
in the correct year in national accounts (ESA 95).  
 
For a better understanding of the report it is important to provide a d escription of the two 
extra -budgetary accounts that had a major role in the deficit revision in May 2012. These 
accounts are account 4096 and account 4117 and they play a crucial role in translating public 
accounts into national accounts.   
In the implemen tation of the accrual principle, both accounts are used to register expenditure 
made which neither have been paid nor included in the budget at the end of the year. The 
difference between them is that account 409 registers expenditures made and matured whi ch 
were not imputed, as some administrative procedure requisite was still pending, whereas 
account 411 registers expenditures made but not matured (i.e. expenditures that have taken 
place in the economic sense, but they have not matured yet and therefore t hey have not 
generated obligations in a budgetary sense).  
Account 409 consists of expenditure, not imputed in the budget of year T, for which 
the obligation to pay has been recognised (invoice received) and must be imputed to the 
budget of year T+1. Such expenditure impacts the EDP deficit (B.9) of year T.  
Account 411 consists of expenditure, not imputed in the budget of year T, for which the 
obligation to pay has not been created, as the expenditure is not matured (the official invoice 
was not yet receive d), and which must be imputed to the budget of year T+1 once the invoice 
has been received, after the due date, and the obligation to pay is recognised. Such 
expenditure impact the EDP deficit (B.9) of year T.  
                                                            
6 Account 409 became account 413 in the new PGCP of 2010, but this did not change substance of the account. 
The reference used in the report is to account 409.  
7 Account 411 is in fact relevant just in the case of the AC of Valencia as it was extensively used only in this 
AC. 
 
11 
 3. The compilation, recording and reporting of ex penditures in the 
AC of Valencia  
 
3.1. Legal framework in the AC of Valencia  
As for the rest of Autonomous Communities, the AC of Valencia has its specific legal 
framework in addition to the common framework applicable to all ACs. The regional laws in 
the AC of Valencia, which are relevant in the context of the present report, are the following:  
 Public Finance Act  (Ley de Hacienda Pública de la Generalitat Valenciana)  
This Law specifies the budget system and the economic, financial, and accounting framework 
and sets the basis for the control of public accounts in the region. It dates back to 19918.  
This Law has been updated several times. By Law 12/2004 of 27 December, new Article 
59bis, in addition to Article 59, was adopted. Article 59bis set the framework  for the non -
recognition of payment obligations under certain circumstances. Later, by Law 10/2006 of 26 
December, two new sections (2.d and 3) were added to Article 59bis. These new sections 2.d 
and 3 enabled the adoption of specific measures for budget a llocation to future years in case 
of insufficient budgetary provision to meet past and present payment obligations9. By Law 
10/2012 of 21 December 2012, sections 2.d and 3 were revised again and the adoption of 
specific measures for budget allocation to future years, in case of insufficient budgetary 
provision to meet past and present payment obligations was deleted.  
 General Public Accounting Plan for the AC of Valencia ( Plan General de 
Contabilidad Pública de la Generalitat Valenciana) -  PGCPGV  
- It sets  the framework for public accounts in this region. It should be in line with the 
PGCP set for central government units. It was approved in 200110. 
 Accounting Instruction for the AC of Valencia (Instrucción de Contabilidad para la 
Generalitat Valenciana)11  
                                                            
8 The Public Finance Act of the Generalitat Valenciana  is available at the following link: 
http://noticias.juridicas.com/base_datos/CCAA/va -dleg260691.html  
9Under Section 3 of Article 59bis, it is stated that ” However, when in the current year there is an absence of 
adequate and sufficient budgetary credit to meet the current obligations and in addition, the use of the 
possibility provided in Article 32 of this Act is not considered as appropriate, it will be necessary to submit in 
advance to the Consell (the Regional Government) the documentation, jointly with a favourable opinion from 
the Regional MoF so that, if need be, the Consell would adopt a program of budget allocation to future years. ” 
This Article allowed the inclusion in the Budget of the health expenditures  which were previously never 
included in account 409, which shows that IGGV was indeed aware of the existence of health expenditures 
undertaken, not paid and not included in the budget, and that according to IGGV the account 411 was not 
suitable and could not be used (as it should have been and as it was used in the other ACs) to record these 
expenditures.  
10 The General Public Accounting Plan for the Generalitat Valenciana  is available at the following link: 
http://www.docv.gva.es/index.php?id=26&L=1&sig=3185/2001  
11The Accounting Instruction for the Generalitat Valenciana  is available at the following link:  
http://www.docv.gva.es/portal/ficha_disposicion_pc.jsp?sig=5627/2002&L=1  
 
12 
 - It was approved in 2002 and it establishes the accounting framework needed after the 
adoption in 2001 of the PGCPGV.  
Rule 5 of the Accounting Instruction of the AC of Valencia deserves special attention, as it 
explicitly establishes account 409 for the reco rding of expenditure incurred, not yet paid and 
not imputed to the budget of the current year.  
 Specific Agreements of government in 2007 – 2010  (Acuerdos del Consell ) 
The Government of the AC of Valencia signed different agreements between 2007 and 2010.  
The debt recognised through these agreements has been recorded in the account 411, 
impacting the accounts of the year when the agreement was signed instead of the years in 
which the expenditures took place (thus violating the accrual principle in national accounts). 
The agreements foresaw a payment scheme, to be implemented through a number of future 
years, via the imputation of a constant amount every year.  
There is a double effect of such agreements in the account 411 and, thus, on government 
accounts. On  the one hand, the new debt recognised after each agreement impacts 
government deficit. On the other hand, the regular payments foreseen each year impact the 
flow of payments in public accounts.  
As a consequence of these agreements, around 2 billion euro o f expenditures related to 
health, incurred in past years and never recorded before in the accounts, were recognised, 
impacting the accounts of the region from 2007 onwards12. 
3.2. Units involved in the compilation, recording, reporting and control of EDP data in  
the AC of Valencia   
The units dealing with the compilation, recording, reporting and control of EDP data in the 
AC of Valencia are the following:  
 The Regional Ministry of Finance  (Consejería de Hacienda y Admistración Pública , 
hereinafter referred to as t he “Regional MoF”), which is part of the Government of the 
Generalitat Valenciana .  
 The Regional Audit Office ( Intervención General de la Generalitat Valenciana  - IGGV, 
which is a specific unit inside the Regional MoF responsible for the compilation, inter nal 
control and reporting of the public accounts of the region. The responsibility of the IGGV 
is established in the Public Finance Law ( Ley de Hacienda Pública de la Generalitat 
Valenciana) . IGGV forms part of the Regional MoF, but it is functionally inde pendent in 
relation to the control and the accounting of expenditure.  
 The Regional Ministry of Health  (Consejeria de Sanidad, hereinafter referred to as the 
“Regional MoH” and other public units, providing source data to IGGV.  
                                                                                                                                                                                         
 
12 As they had been incurred in past years, they should have been recorded as expenditure in the year in which they were 
incurred.  
 
13 
 - The Regional Court of Auditors  (Sindicatura de Cuentas de la Comunidad Valenciana, 
hereinafter referred to as the “Regional Court of Auditors”) which is part of the 
Government of the Generalitat Valenciana although is functionally independent. It is in 
charge of the external control of the public accounts compiled by IGGV. The Regional 
Court of Auditors does not assess the respect of national accounts principles as the 
national accounts principles are not applied at the level of Autonomous Communities but 
at the level of the n ational statistical authorities.  
3.3. The workflow for public accounts and EDP data in the AC of Valencia  
The workflow for the compilation of EDP data in the AC of Valencia is the following:  
3.3.1.  Compilation of Public Accounts: IGGV  
As stated in the Public Finance Law ( Ley de Hacienda Pública de la Generalitat 
Valenciana) , the compilation of public accounts is carried out by the IGGV, which is part of 
the Regional MoF. IGGV also complies with the function of internal auditor of the AC of 
Valencia.  
The IGGV compiles the General Account of the Generalitat Valenciana  in terms of public 
accounting, following the PGCPGV and the Accounting Instructions ( Instrucción de 
Contabilidad) .  
In Spain, every region is responsible for sending correct data to IGAE in the context of t he 
EDP reporting.  The accrual principle has to be respected. The responsibility for doing so in 
the AC of Valencia belongs to IGGV. IGGV transmits data to IGAE, via the SQ, four times 
per year13. 
IGGV has to collect the information from all the units in Re gional Government (public 
hospitals, units involved in health care, universities, etc.) before transmitting the S Q to 
IGAE. The deadline for regional units to report data of year T -1 to the IGGV is mid -January 
of year T. Subsequently, the S Q is provided by IGGV to IGAE by the end of January of year 
T, including for the first time data of year T -1 and is the basis used for the April EDP 
Notification of year T.  
Ideally, all information concerning extra -budgetary accounts would be correctly and 
completely re corded in the SQ in January, allowing for a real reflection of the economic 
activity, the respect of the accrual principle in the translation of public accounts to national 
accounts and the correct calculation of deficit (B.9) in the April EDP Notification  of year T.  
IGGV was constantly informed about the methodology used for the reporting of EDP, via 
different means:  
- firstly, by the Ministerial Order of 2003 (Orden HAC/2283/2003) ; 
                                                            
13 From 2013 onwards, Autonomous Communitie s transmit data to IGAE, via SQ, on a monthly basis.  
 
14 
 - secondly, every year in a form of a letter by IGAE to all regions, reminding them about 
the importance of EDP reporting;  
- thirdly, the Article 69 of the Public Finance Act ( Ley de Hacienda Publica de Valencia)  
sets the obligation for IGGV to centralise all necessary data and send them to IGAE, both 
for national purposes an d for EDP reporting.  
Article 69 of the Public Finance Act establishes,  that the General Comptroller of IGGV is 
responsible, amongst other, for:  
(a)  preparing the General Account of the Generalitat Valenciana ; 
(b)  preparing and reviewing, with appropriat e observations, the accounts to be submitted to 
the Regional and National Court of Auditors;  
(c)  requesting the presentation of the accounts, statements and other documents subject to 
critical examination;  
(e)  preparing the public sector accounts of the Generalitat Valenciana  in a manner consistent 
with the national accounting system followed by the State;  
(h)  standardising accounting information in terms of the European accounting system.  
The General Account is composed of the following elements: balanc e sheet, profit and loss 
account, budget implementation and a detailed report.  
Before the end of June of year T, the General Account of year T -1 is sent to the Regional 
Court of Auditors for external control.  
The General Account of the Generalitat Valenciana  is published every year in the website of 
the IGGV.  
3.3.2.  Control of Public Accounts: the  Regional Court of Auditors  
While the internal control of public accounts is carried out by the IGGV, the external control 
is undertaken by the Regional Court of  Auditors, which analyses the General Account of the 
region and prepares a report on the fulfilment of public accounting principles. The Regional 
Court of Auditors receives the General Account of year T -1 from the IGGV at the latest by 
June of year T and t he deadline for publishing its report is December of year T.  
3.3.3.  The translation of public accounts into national accounts: IGAE  
Being responsible for the compilation of general government accounts in terms of ESA95, 
IGAE is in charge of translating the public  accounts of the AC of Valencia (as well as of the 
other regions) into national accounts. This is achieved by way of the SQ that IGGV sends to 
IGAE on a quarterly basis14, which contains all the information related to the public accounts 
of the region.  
                                                            
14 On a monthly basis from 2013 onwards.  
 
15 
 The main source of estimated and preliminary data is the SQ while final data (available in the 
October notifications for data of year T -2) are based on the General Account of Autonomous 
Communities.  
Autonomous Communities transmit data to IGAE via the SQ  by: 
 31 January (used for the April EDP  notifications);  
 30 April (used for the October EDP notification);  
 31 July (used for the October EDP notification, if updates are made);  
 31 October.  
According to the Ministerial Order HAC/2283/2003, the Intervencion Gener al of each region 
is obliged since the year 2003, to send data to IGAE. In line with this Order, meetings 
between IGAE and the regional Audit Offices ( Intervenciones Generales) of each region are 
also organised.  
Whenever additional clarifications about dat a are needed, or there are doubts about the 
quality of data provided by the Autonomous Communities, IGAE contacts directly the AC 
concerned. These contacts are made almost exclusively by phone. In some cases, after 
discussing data quality issues with IGAE,  the Autonomous Communities correct the data 
accordingly and re -send them by the SQ to IGAE. In other cases, IGAE receives additional 
qualitative information which explains / confirm the data sent earlier or at the same time by 
the Autonomous Communities.  
IGAE is not allowed to correct unilaterally the data sent by ACs or to make estimations, as 
the data sent by regions are considered as official. IGAE would be entitled to make 
estimations only if the ACs would not send the data, although this has never hap pened 
(moreover, Autonomous Communities have, from 2003 onwards, a legal obligation to send 
data).  
A Manual on the calculation of deficit in National Accounts ( Manual de cálculo del déficit en 
contabilidad nacional adaptado a las Comunidades Autónomas)  adapted to Autonomous 
Communities  is published on the website of IGAE and provides further guidelines for the 
Autonomous Communities on how to report data to IGAE in the context of EDP reporting. 
Methodological notes stressing the importance of the accrual p rinciple are also published on 
the website of IGAE.  
In addition, IGAE organises regular meetings with the Autonomous Communities, informing 
them about any methodological changes which would affect EDP data.  
 
16 
 Autonomous Communities are fully informed about t he importance of data sent to IGAE for 
the EDP purposes.  IGAE sends a letter to all Autonomous Communities several times per 
year15, explaining the importance of the data sent via the SQ for the EDP purposes.   
With the information provided in the SQ, IGAE calculates the deficit (B.9) and the other 
national accounts data for the AC of Valencia (and all other Autonomous Communities) to be 
transmitted to Eurostat in the EDP Notifications.  
IGAE sends regularly to all Autonomous Communities the preliminary Natio nal accounts 
figures (including the EDP deficit), containing all the adjustments made to public accounts 
data. At this stage, the ACs still have the possibility to revise data, if necessary. For this 
purpose, an annual meeting is held with the Autonomous C ommunities every year in July. 
Usually, the General Comptrollers of the regional Audit offices ( Intervenciones Generales ) 
participate to these meetings, either alone or accompanied by other officials.  
IGAE is not supervised by any other unit in the process  of translation of regional public 
accounts data to national accounts data to be used in the EDP context.  
Table 2 provides an overview of the workflow between the different units involved in the 
EDP data compilation in the AC of Valencia .  
                                                            
15 Every time before data on deficit is published.  
 
17 
 Table 2:  Work and data flow between the different units involved in the EDP data compilation in the AC of Valencia  
 
 

 
18 
 3.4. The recording and repor ting of data in extra -budgetary accounts (409, 411) and 
their impact on deficit (B.9)according to legal provisions  
All expenditures incurred in one particular year, no matter whether paid or not, must be 
reflected in the accounts, with a corresponding impa ct on deficit (B.9).  
Expenditures not paid but already imputed to the budget, are automatically reflected in the 
accounts. Expenditures not paid and not yet imputed to the budget must be recorded in extra -
budgetary accounts, as by doing so they will be ta ken into account in the national accounts of 
the current year with the corresponding impact on deficit.  
Therefore, all expenditures must be reflected either in the budgetary or in the extra -budgetary 
accounts and under no circumstance may any expenditure not be recorded.  
Most Spanish regions register some amounts, mainly related to health expenditure, in ac count 
409. These amounts have increased considerably during recent years due to the economic 
downturn, which has implied cuts in regional budgets and a sudden decrease in the revenue of 
regional governments. Almost all the regions seem to have used extra -budgetary accounts to 
record health expenditures not paid and not imputed to the budget, in order for this 
expenditure to be recorded (albeit, sometimes with a delay of one year for some small 
amounts16).  
The Rule 5 of the Accounting Instructions for the AC  of Valencia  explicitly mentions account 
409 for the recording of expenditure incurred, not yet paid and not imputed to the budget of 
the current year. It states the following:  
“Any recognition of the obligation implies the corresponding payment proposal, meaning by 
this the request by the competent authority which has recognised the existence of an 
obligation so that, in accordance with current regulation, the Ordenador General de pagos  
(the person responsible for executing the payments) proceeds to execut e the payment order. 
Once the recognition of the obligation is agreed, the managing service shall issue compliance 
document which, together with the documents to be used as justification of the operation, will 
be sent to the Regional Audit Office (IGGV).  
When for some justified reasons , the recognition of payment obligations for goods and 
services actually received in that year has not been made in the current period, the units 
managing expenditures will take the appropriate measures to transmit to the Reg ional Audit 
Office the necessary documents to record such obligations as imputed to the budget of the 
following year.  
Taking as a reference the date in which the expenditure was incurred, which should be 
specified in the accounting document, an amount conc erning pending operations to be 
imputed to the budget will be recorded in the economic and patrimonial accounts of the 
                                                            
16 With the exception of the AC of Valencia where expenditures were recorded sometimes with a delay of many 
years.  
 
19 
 current year, through the account 409, as foreseen in the General Public Accounting Plan of 
the AC of Valencia.  
This account will be bala nced once the transaction is imputed to the budget of the following 
year.”  
Accordingly, the procedure in the region should be the following:  
Expenditure incurred in the year, but not paid and not imputed to the budget of the current 
year, should be reflect ed in account 409 and imputed to the budget of the following year (s). 
This task is the responsibility of the IGGV, which compiles the general account of the region 
every year (public accounting).  
By following the above mentioned recording, all expenditure s would be recorded, either 
directly in the budget or in the extra -budgetary accounts.  
The IGGV should gather all the information concerning public accounts in the AC of 
Valencia and transmit it to IGAE in the SQ, which makes the translation of public acco unts 
into national accounts and calculate the EDP deficit for the region.  
This information will be integrated in the tables for the EDP Notification. Data for year T 
will be released in the April and October EDP Notifications in year T+1.