2009
THE COMMISSION’S MANAGEMENT
OF NON-STATE ACTORS’  
INVOLVEMENT  IN EC DEVELOPMENT 
COOPERATIONEUROPEAN COURT 
OF AUDITORS
Special Report  No 4
EN
ISSN 1831-0834

THE COMMISSION’S 
MANAGEMENT OF NON-STATE ACTORS’ INVOLVEMENT IN EC DEVELOPMENT COOPERATIONSpecial Report  No 4   2009
EUROPEAN COURT OF AUDITORS(pursuant to Article 248(4), second subparagraph, EC)
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation2
EUROPEAN COURT OF AUDITORS
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LUXEMBOURG
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Fax +352 4398-46430
E-mail: euraud@eca.europa.eu
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Special Report  No 4   2009
More information on the European Union is available on the Internet (http://europa.eu).
Cataloguing data can be found at the end of this publication.Luxembourg: Office for Official Publications of the European Communities, 2009ISBN 978-92-9207-273-5
© European Communities, 2009
Reproduction is authorised provided the source is acknowledged.
Printed in Belgium
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation3
CONTENTS
Paragraph
  LIST OF ABBREVIATIONS
I–VII   EXECUTIVE SUMMARY
1–12   INTRODUCTION
1–4   CONTEXT OF THE AUDIT
5–6   BUDGETARY SIGNIFICANCE
7–9   THE LEGAL FRAMEWORK
10–12   KEY DOCUMENTS
10  THE EUROPEAN CONSENSUS ON DEVELOPMENT11–12  COMMUNICATIONS AND GUIDELINES
13–17   AUDIT SCOPE AND APPROACH
18–83   OBSERVATIONS
18–35   DOES THE COMMISSION ADEQUATELY ENSURE THAT NSAs ARE INVOLVED EFFECTIVELY 
IN THE DEVELOPMENT COOPERATION PROCESS?
20–29  PREPARATION OF COUNTRY STRATEGY PAPERS
30–35  THEMATIC PROGRAMME ON NON-STATE ACTORS AND LOCAL AUTHORITIES IN DEVELOPMENT
36–68   DO THE COMMISSION’S MANAGEMENT SYSTEMS EFFICIENTLY ENSURE THAT ACTIVITIES IMPLEMENTED 
BY NSAs ARE RELEVANT AND LIKELY TO PRODUCE THE INTENDED RESULTS?
37–41   SELECTION PROCEDURES
42–50 CONTROL AND SUPERVISION PROCEDURES
51–62  MONITORING INCLUDING TOOLS AND ASSESSMENTS OF THE EFFECTIVENESS OF NSA ACTIVITIES
63–68  PROSPECTS FOR SUSTAINABILITY
69–83   DOES THE COMMISSION ADEQUATELY ENSURE THE PROVISION OF CAPACITY DEVELOPMENT TO NSAs?
70–74  STRATEGY FOR CAPACITY DEVELOPMENT OF NSAs
75–83  PROGRAMMES ON CAPACITY DEVELOPMENT OF NSAs
84–92   CONCLUSIONS AND RECOMMENDATIONS
 ANNEX I — CONTRACTED AMOUNTS WITH NSAs
 ANNEX II — MAIN PROVISIONS OF THE COTONOU AGREEMENT RELATED TO NSAs
 ANNEX III — LIST OF THE PROGRAMMES, PROJECTS AND LOCAL CALLS FOR PROPOSALS EXAMINED
 ANNEX IV — DEVELOPMENT COOPERATION ACTORS VISITED ON THE SPOT
 REPLY OF THE COMMISSION
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation5
LIST OF ABBREVIATIONS
ACP : African, Caribbean and Pacific (Group of States)
ALA : Asia(n) and Latin America(n)
CONCORD : European NGO Confederation for Relief and Development
CRIS : Common RELEX information system (computer application)
CSO : Civil society organisation
CSP : Country strategy paper
DCI : Development cooperation instrument
EC: European Community
EDF : European Development Funds
EIDHR : European Initiative for Democracy and Human Rights
ENGO : European NGO
ENPI : European neighbourhood and partnership instrument
EU: European Union
EuropeAid : European Commission’s Cooperation Office
Logframe : Logical framework matrix
NGO : Non-governmental organisation
NSA : Non-state actor
PADOR : Potential applicant data online registration (computer application)
RELEX : Directorate-General for External Relations
Southern NSAs : NSAs from the beneficiary countries (the South)
REPLY OF THE 
COMMISSION
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation6
EXECUTIVE SUMMARY
I.
The term ‘non-state actors’ (NSAs), as used 
in this report, covers all aspects of society 
that do not form part of the private sector 
or the state, including non-governmental  
organisations (NGOs)1. The Cotonou Agree-
ment with the ACP group of states, and  EU legislation, provide for such non-state  
actors to play multiple roles in development 
cooperation, notably participating in policy 
dialogue as well as implementing projects. Support for capacity development is envis-aged to help NSAs to fulfil these roles. The 
EU funds directly attributed to NSAs in 2007 were approximately 915 million euro, 10 % of the total aid to developing countries  (general budget and EDF).
II.
The Court’s audit considered the two  
main roles of NSAs and asked whether the  
Commission:
adequately ensures that NSAs are   —
involved effectively in the development 
cooperation process;
has efficient management systems to   —
ensure that activities implemented by  
NSAs are relevant and likely to produce 
the intended results;
adequately ensures the provision of   —
capacity development to NSAs.
1 In the Cotonou Agreement the definition of non-
state actors also includes the private sector. This report, 
however, takes the usage of the Development Cooperation Instrument (DCI — Regulation (EC) No 1905/2006 of the 
European Parliament and of the Council of 18 December 
2006 establishing a financing instrument for development 
cooperation (OJ L 378, 27.12.2006, p. 41)), which excludes 
profit-making bodies. Article 24(2) of the DCI gives a fuller 
list of types of organisation. Although there is evident 
wide agreement on the typical characteristics of NGOs, there is no uniform definition (the United Nations and 
the World Bank both publish working definitions), and 
none was needed in order to carry out this audit since it 
is more useful to apply the broader concept of NSAs in 
development (equivalent to civil society as a whole).
REPLY OF THE 
COMMISSION
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation7
III.
The Court found that, despite the Com-
mission’s attempts to involve NSAs in the  
development cooperation process, this  
involvement has been limited and falls short 
of the sustained and structured dialogue  
envisaged by the EU legislation and the Com-mission’s own guidelines (see  paragraphs 18 
to 35).
IV.
The Commission’s management systems  generally ensure that projects implemented 
by NSAs are relevant and are likely to pro-duce the intended results. But the Call for  proposals procedure does not always assure timely completion of project design, there is 
insufficient guidance for NSAs on the prac-
tical application of the financial rules, and there are inconsistencies in the in ter pret-
ation and application of procedures. There 
is insufficient monitoring, and prospects for 
sustainability are poor partly because of the 
short project duration (see paragraphs 36  
to 68).
V.
Capacity-development programmes are  
developed and form part of a strategy in most 
ACP countries, where, under the  Cotonou  
Agreement, they are implemented in coop-eration with the partner governments. How-
ever there is a significant disparity between 
this approach and that in Asian and Latin  
American beneficiary countries, for which  
strategies have not yet been developed (see 
paragraphs 69 to 74).
VI.
The first round of capacity-development  programmes were found to be highly rele-vant to the needs of NSAs in the beneficiary 
countries. However, they did not reach their full potential mainly because management 
procedures led to delays that worsened the 
prospects for effectiveness and sustainabil-
ity. The programmes are also faced with the inherent contradiction of supporting capac-ity development of the NSAs most in need  
by means of a procedure (Calls for Propos-als) which is designed to select the best-
performing NSAs (see paragraphs 75 to 83).EXECUTIVE 
SUMMARY
VII.
The report’s main recommendations are that 
the Commission should:
strengthen and provide more guidance  —
on its procedures for involving NSAs in 
the development cooperation process;
continue measures already in train   —
to improve the Call for Proposals  
procedure;
enhance the targeting of monitoring and  —
support by Delegations;
ensure sufficient guidance for both Dele- —
gation and NSA staff on performance  indicators;
to improve sustainability, consider   —
using a mix of instruments (and not only 
projects) when working with NSAs;
develop a strategy for capacity devel- —
opment of NSAs in ALA countries and  
reconsider the disparity in approach as between ACP and ALA countries;
examine additional ways of delivering   —
the capacity-development policy aims  
such as use of partnership agreements, multi-donor funding, and cascading  
grants in order to better reach grass-
roots organisations.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation8
INTRODUCTION
CONTEXT OF THE AUDIT
 1.  The EU’s approach to development cooperation, reflecting the evolv-
ing international consensus, has undergone a series of changes over 
the last decade, both at the policy level and as regards funding. EC 
policy now involves, to varying degrees, a range of partners whose 
characteristics and roles have progressively developed. The Commis-
sion works increasingly in partnership with a large range of bodies including, or representing, non-state actors.
 2.  The term ‘non-state actors’ (NSAs) covers all aspects of society that do not 
form part of the private sector or the state. In the field of development 
cooperation, non-state actors include non-governmental organisa-tions (NGOs) and also community-based organisations, farmers’ asso-
ciations, business or professional associations, environmental groups, 
universities, trade unions, chambers of commerce, and foundations 
as well as churches or faith groups. The term non-state actors is often 
used as a synonym of civil society organisations, and it is in that sense 
that it will be used in this report (see also footnote 1 in the Executive 
Summary). In the past, NGOs and in particular European NGOs were the EU’s main NSA partners
2. However, there is now a strong emphasis 
on involving NSAs from the partner or beneficiary countries (often 
called ‘Southern NSAs’).
 3.  NSAs fulfil a variety of functions in the EU development cooperation 
field as a whole, of which the two main roles are:
policy dialogue, encompassing all representational, advocacy and (a) 
watchdog functions vis-à-vis governments and donors;
implementation of development programmes and projects which (b) 
directly provide benefits for the poor.
 4.  The legislation envisages the Commission working with NSAs in three 
main ways: by enhancing their policy dialogue role through involv-
ing them in its development cooperation; by funding development 
programmes and projects implemented by NSAs; and by support-
ing capacity development3, mainly for Southern NSAs, to enable  
them to play both roles. Under the devolution process, Commission 
Delegations now play the leading role in relations with NSAs and  manage about 80 % (by number) of the programmes and projects  concerned.2 One main reason was that 
European NGOs had better 
capacity to deal with the 
Commission requirements than 
NSAs from beneficiary countries, 
which were formerly rather sparse and weak.
3 Capacity development is 
the process by which people 
and organisations create and 
strengthen their ability to perform 
tasks and produce outputs, to define and solve problems, and to 
make informed choices over time.
1 000
800600400200
0
2000 2001 2002 2003 2004 2005 2006 2007
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation9
4 See paragraph 52.
5 Excluding humanitarian and 
emergency aid (see paragraph 17) 
and excluding grants to 
international organisations (which 
may ultimately use NGOs/NSAs 
for implementing actions).
6 Thematic programmes are 
specific subjects or types of 
development activity, which are 
specifically provided for by the legislation and are programmed 
separately from the geographic 
programmes. They include: 
human and social development; 
environment and sustainable 
management of natural resources, 
including energy; non-state actors and local authorities; food security; 
and migration and asylum.
7 Geographic programmes 
encompass the cooperation in development activity with partner 
countries and regions, determined 
on a geographical basis.BUDGETARY SIGNIFICANCE
 5.  It is difficult to trace the financial flow of the EC funds channelled through 
NSAs as the Commission lacks comprehensive data4. Nevertheless,  
development funds directly attributed to NSAs with no intermedi-
ary5 have gradually increased over the last decade, reaching, in 2007, 
approximately 10 % of the combined general budget and European 
Development Fund (EDF) aid to developing countries (see Graph 1  
and Annex I ).
 6.  Traditionally, EC support to NSAs has been mainly provided by the the-
matic budget lines6, and to a lesser extent through the geographic 
budget lines7 and the EDF ( Annex I ). The main funding source has  
been the ‘Co-financing with NGOs’ programme (then restricted to  European NGOs) which, established in 1976 with 2,5 million euro,  rose to about 200 million euro/year in the mid-1990s, representing 23 % of the total funding from the Commission to NSAs in 2007.
EVOLUTION OF PAYMENTS MADE TO NSAs* 
DURING THE PERIOD 2000–07GRAPH 1
* EU spending directly to development NSAs as first recipients of the payment.
Source: Commission Services.Yearin million euro
Total EDF Budget
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation10
THE LEGAL FRAMEWORK
 7.  The Commission has for many years funded European NGOs’ own ini-
tiatives (under co-financing procedures) as well as using NGOs as  
implementers of EU aid. Council Regulation (EC) No 1658/988 set out 
the rules on co-financing operations with European NGOs in fields of 
interest to the developing countries.
 8.  As regards the African, Caribbean and Pacific (ACP) Group of States, the 
Cotonou Agreement, signed in June 2000, introduced a substantial reorientation in the relationship between the EU and NSAs. The ACP countries and the European Community legally committed themselves to involving NSAs in all phases of the cooperation process (formula-tion, implementation, review and evaluation) and to providing funds for strengthening the capacity of NSAs to enable them to play the  new role of partners in development cooperation (see Annex II ).
 9.  For other countries, the Development Cooperation Instrument (DCI)9 and 
the European Neighbourhood and Partnership Instrument (ENPI)10, 
which replaced the existing regulations from January 2007, contain 
specific provisions dealing with the role of NSAs in development. The 
DCI also includes a new thematic programme for non-state actors and 
local authorities in development, of which the main objective is to provide capacity development (replacing the previous ‘Co-financing 
with NGOs’ programme — see paragraph 6).8 OJ L 213, 30.7.1998, p. 1.
9 Regulation (EC) No 1905/2006.
10 Regulation (EC) No 1638/2006 
of the European Parliament and of the Council of 24 October 
2006 laying down general 
provisions establishing a European 
Neighbourhood and Partnership 
Instrument (OJ L 310, 9.11.2006, 
p. 1).
THE ‘EUROPEAN CONSENSUS ON DEVELOPMENT’ — 
PARTICIPATION OF CIVIL SOCIETY
‘Th e EU supports the broad participation of all stakeholders in countries’ development and encourages all parts of society 
to take part. Civil society, including economic and social partners such as trade unions, employers’ organisations and 
the private sector, NGOs and other non-state actors of partner countries in particular play a vital role as promoters of 
democracy, social justice and human rights. Th  e EU will enhance its support for building capacity of non-state actors 
in order to strengthen their voice in the development process and to advance political, social and economic dialogue. Th e important role of European civil society will be recognised as well; to that end, the EU will pay particular attention 
to development education and raising awareness among EU citizens.’BOX 1
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation11
KEY DOCUMENTS
THE EUROPEAN CONSENSUS ON DEVELOPMENT
 10.  In December 2005, with the ‘European Consensus on Development’ the EU 
made a high-level political declaration which recognises and strength-
ens the principle of participation of NSAs in countries’ development, and made a commitment to support developing the capacity of NSAs 
to fill this role
11.
COMMUNICATIONS AND GUIDELINES
 11.  In May 2003, the Council adopted12 a certain range of standards that 
Commission services should meet in order to assure an adequate  
level of NSA consultation and participation:
promotion of NSA involvement in the preparation of the National (a) 
Development Strategy or poverty strategy papers by the national 
authorities;
NSAs should be consulted systematically throughout the  (b) 
 programming process;
all areas of interest should be represented in consultations; (c) 
clear and comprehensive information to be provided to NSAs  (d) 
in good time so as to allow them to prepare their effective  
participation;
capacity development is essential to enable NSAs to play a  (e) 
 constructive role in the development process;
enhanced coordination with Member States and other donors; (f) 
the EC to continue to encourage NSAs to participate in the  (g) 
 implementation of cooperation projects and programmes;
the EC to keep its existing relations with NSAs as implementing (h) 
partners and as implementers of their own initiatives.
 12.  In November 2004 the Commission released guidelines for all Commis-
sion Delegations on NSA involvement in the development process, which complement those already issued for ACP Delegations. These guidelines apply to the 2007–13 Country Strategy Papers.11 As explained in paragraph 2, 
NSAs is used here as synonym 
of civil society.
12 The standards are set out 
in the conclusions of the 
Commission’s Communication 
on the participation of non-state 
actors in EC development policy 
(COM(2002) 598 final).
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation12
AUDIT SCOPE AND APPROACH
 13.  The Court’s audit addressed the Commission’s management of NSAs’ 
involvement in development cooperation, taking into account their 
two main roles, as partners in EC development cooperation and as implementing actors (see paragraph 3). The audit approached this  
through the three following questions:
Does the Commission adequately ensure that NSAs are involved (a) 
effectively in the development cooperation process?
Do the Commission’s management systems efficiently ensure that (b) 
activities implemented by NSAs are relevant and likely to produce the intended results?
Does the Commission adequately ensure the provision of capacity (c) 
development to NSAs?
 14.  The Court took as a starting point the standards and guidelines referred 
to in paragraphs 11 and 12 above. They set out an approved basis for 
the implementation of the EU’s policy to ensure NSA participation  
in EC development cooperation, and therefore serve as overall audit 
criteria for this audit.
 15.  The main audit work carried out to answer these questions was as  
follows:
a review of documentation on EC policy and programming con- (a) 
cerning NSAs, together with reports on implementation (see  
paragraph 24);
on-the-spot missions to Commission Delegations in Bangladesh, (b) 
Ethiopia, Peru and South Africa to examine Commission pro-ced ures and activities including five programmes of capacity-
development support, seven local calls for proposals and 16 indi-
vidual projects (see Annex III );
desk reviews covering two programmes of capacity-development (c) 
support in Mali and Uganda;
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation13
interviews with more than 60 local and international NSAs, with (d) 
central and local authorities in partner countries, technical assist-
ance units and other donors, and with some European NSA plat-forms and networks, to collect information on the level of NSA  
participation in the development cooperation process, and on  
their experience of the Commission’s procedures to support such 
participation (see Annex IV );
benchmarking with the development assistance agencies of the (e) 
Netherlands and Sweden.
  The audit covered consultation with NSAs from the year 2000 onwards 
(date of signature of the Cotonou Agreement), together with a sample of projects and programmes that were in progress in 2007.
 16.  The results of recent Court audits involving observations on NSAs in 
development cooperation13 were also taken into account, as well  
as the recent Commission Internal Audit Service audit on NGOs in  
 EuropeAid and its follow-up. The audit also took into account the  
fact that the Commission is currently carrying out an evaluation of 
EC aid delivery through civil society organisations. According to its terms of reference, the evaluation focuses on NSAs as implementers 
(channels by which EC aid is delivered). The Court’s audit has exam-
ined the broader question of the Commission’s involvement of NSAs 
in all phases of EU development cooperation.
 17.  The audit focused on the NSA roles in development cooperation and 
did not extend to humanitarian or emergency aid, because that is  
a separate field with specific strategy and management systems. It did not include comparison between various channels (private sec-tor, UN, banking systems) in the field of efficiency and effectiveness, nor comparative analysis of the impact of NSA actions in various   intervention sectors.13 The last three annual reports of 
the Court on the implementation 
of the budget (2007: Chapter 8, 
External aid, Development and Enlargement; 2006 and 2005: 
Chapter 8, External actions), and 
on the activities funded by the 
European Development Funds 
(concerning the financial years 2005, 2006 and 2007), and the 
Special Report No 10/2008 — 
EC Development Assistance to 
Health Services in sub-Saharan 
Africa (http://www.eca.europa.eu).
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation14
DOES THE COMMISSION ADEQUATELY ENSURE 
THAT NSAs ARE INVOLVED EFFECTIVELY IN THE DEVELOPMENT COOPERATION PROCESS?
 18.  The systematic involvement of NSAs in development cooperation is widely 
recognised as a means of promoting ownership and participation,  
core principles of EU development policy, and of tapping practical 
local knowledge and experience as an input to programming. This is reflected in policy as stated in the ‘European Consensus on Develop-
ment’ (see Box 1 ).
 19.  In order to assess the adequacy of the Commission’s involvement of 
NSAs, the Court examined two fundamental consultation processes concerning:
the preparation of country strategy papers for ACP, Asian and  (a) 
Latin American countries;
the preparation of the strategy paper for the new thematic  (b) 
 programme for NSAs and local authorities in development.
PREPARATION OF COUNTRY STRATEGY PAPERS
 20.  The Court assessed the existence of a sustained and structured dia-
logue, the completeness of the guidelines for consulting NSAs (para-
graph 12), and the level of compliance with these guidelines and with 
the Commission’s general principles and standards for consultation of interested parties
14:
the existence of clear institutional mechanisms; (a) 
the inclusion of relevant NSAs; (b) 
that the time provided for NSA participation was sufficient; (c) 
the adequacy of the preparatory process; (d) 
whether clear feedback on the results of the dialogue was  (e) 
given;
the existence of sufficient EC resources for an effective  (f) 
dialogue.OBSERVATIONS
14 Communication from the 
Commission: General principles 
and minimum standards for 
consultation of interested parties by the Commission, COM(2002) 
704 final, 11.12.2002.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation15
NSA S’ INVOLVEMENT  IN COUNTRY  STRATEGY  PAPERS  DOES  NOT MEET  THE GUIDELINES
 21.  Although it was already EC policy to consult with NSAs15, in three of 
the four countries audited (the exception was South Africa), little  
evidence was found of NSA involvement in the preparation of the  
2002–06 country strategy papers (CSPs) due to lack of adequate  
records at Commission Delegations. In South Africa there had been 
limited consultations. Since then, there has been a genuine attempt, in Ethiopia, starting with the joint annual reviews of the strategy from 
2004 and continuing with the 2007–13 CSP, to operate a sustained and structured tripartite dialogue between the government, the EC and representatives of NSAs (see Box 2 ).
 22.  By contrast, in Bangladesh and Peru — and as before in South Africa — 
the Delegations did not systematically involve NSAs in the 2007–13 
programming process except for holding ad hoc consultations. These 
typically took the form of one-day seminars at which presentations 
were made and ideas gathered from the NSAs present, rather than a 
sustained dialogue. Moreover, in Peru and South Africa, no evidence 
was found that the results of these consultations were incorporated in the country strategy papers. The audit noted other weaknesses in 
the consultation process: there was an absence of clear mechanisms 
for managing the consultations (e.g. absence of an action plan with 
a stable and predictable schedule of consultations over time), delays 
in distributing documents, late invitations, consultations at a late  stage in the programming process, limited choice of NSAs, difficulty 
for NSAs to comment on the proposals, and insufficient feedback to 
NSAs on the results of the consultations.15 COM(2000) 212 final, 
the European Community’s 
Development Policy, point 5.2.
EXAMPLE OF A GOOD APPROACH TO STRUCTURING DIALOGUE BETWEEN 
THE GOVERNMENT, THE EC AND NSAs
Ethiopia: the Cotonou Task Force
In 2003, a group of national and international NGOs and networks operating in Ethiopia organised themselves into the 
so-called Cotonou Task Force (CTF) to engage in dialogue with the Delegation and the Government on EC development 
cooperation. Th  e Delegation and Government have eff  ectively engaged in an active dialogue and consultation with the 
Cotonou Task Force, especially for the Joint Annual Reviews from 2004 onwards and for the formulation of the new country strategy paper for the 10
th EDF.BOX 2
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation16
 23.  For all four Delegations audited, the involvement of NSAs in the devel-
opment process was limited to the definition of the overall strategy 
and did not therefore go beyond to include (as the guidelines pre-scribe) consultation on sectoral strategies and involvement of NSAs 
in project implementation, monitoring and evaluation in each area 
of development.
 24.  In addition, the Court analysed information held by Commission head-
quarters16, which showed similar weaknesses for other Delegations. 
Although there was some kind of consultation in virtually all ACP  countries, Commission headquarters only considered the involvement of NSAs satisfactory in relation to the guidelines (i.e. involvement  going beyond ad hoc consultations) in half of them
17. Likewise, for 
the 24 Asian and Latin American (ALA) countries reviewed, the Court found that there was generally some form of consultation but the  
involvement of NSAs went beyond ad hoc consultations in only four 
of the Latin American countries and in none in Asia.
 25.  The involvement of NSAs was greater in the ACP countries, under the 
remit of the Cotonou Agreement — under which NSAs have the right 
to be involved — than in Asian and Latin American countries. Before 
the new DCI in 2007, the former ALA regulation18 did not require  
involvement of NSAs on cooperation policies and strategies.
 26.  Commission staff experienced practical difficulties in engaging with 
NSAs. It was found, inter alia, that: (i) involvement with NSAs depends 
very much also on the stance of the partner country government; (ii) it is difficult to know which are the relevant NSAs to engage with;  
(iii) when engaging with NSAs (either individually or as a platform) 
the issues of their representativity and accountability arise; (iv) many 
NSAs do not have the capacity and/or the resources to engage in the 
development cooperation process and will not participate if they  
know they have little chance of receiving funds as a result; (v) NSAs 
do not always advocate the views of the most marginalised groups.
 27.  Even where there have been substantial efforts to engage with NSAs 
problems of implementation meant that the results were not always successful (see Box 3 ).16 Including the exceptional case 
of Guatemala (see Box 3).
17 This assessment is supported 
by the results of a consultation 
exercise by the European 
Economic and Social Committee 
on NSAs’ and local authorities’ 
participation in the elaboration of the 10th EDF Country Strategy 
Papers in ACP countries.
18 Council Regulation (EEC) 
No 443/92 of 25 February 1992 on 
financial and technical assistance 
to, and economic cooperation with the developing countries in Asia 
and Latin America 
(OJ L 52, 27.2.1992, p. 1).
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation17
SPECIFIC  TRAINING  AND DETAILED  GUIDANCE  ON HOW  TO INVOLVE  NSA S NEED  
TO BE FURTHER  DEVELOPED
 28.  The limited involvement of NSAs in many cases, and widespread weak-
nesses in the timing and the way the consultations were organised, 
show that translating the ambitious goal of involving NSAs in all EC 
development cooperation into reality remains a major challenge. For 
many Delegation staff, NSA involvement is mostly limited to service delivery or to ‘one-shot’ consultations at certain moments of the  
programming cycle. The Commission has not yet invested sufficient time and resources to really engage Delegation staff with NSAs at all levels. Specific training is to be further developed.
 29.  The guidelines in use by the Commission at the time of the audit (see 
paragraph 12) recognise many of the issues, but except for recom-
mending a mapping study to identify relevant NSAs and assess their 
representativity, they do not set out detailed instructions, for example 
concerning key issues such as the role of NSAs in the aid effective-
ness agenda, and the participation of NSAs in the definition of sector 
strategies including budget support.
EXAMPLE OF DIFFICULTIES IN INVOLVING NSAs IN EC DEVELOPMENT COOPERATION
Guatemala: the ‘Mesodiálogo’
Th e Mesodiálogo was launched in 2000 with the participation of the Commission Delegation, Member States, Government, 
European NGOs and NSAs from Guatemala. Th  e aim was to support implementation of the 2002–06 country strategy 
paper (CSP), through direct involvement in identifi  cation, implementation and monitoring of the CSP programmes. 
Around 150 organisations and 800 people, organised into working groups, participated in the process, which included 
draft ing of strategic documents, accompanying identifi  cation and formulation missions, creation of regional networks, 
etc. However, the organisational burden for the Delegation, the feeling that the Mesodiálogo was exceeding its role by 
intervening in topics that were exclusive competences of the EC, and the lack of clear government ownership and guar-
antees of sustainability, led to a progressive decline in the process which was fi  nally closed in 2005.
Sources : RELEX/L3 Working document on involvement of NSAs in the programming process in the countries of Asia 
and Latin America; EC aid to Guatemala — Background Country Study Paper, December 2006; and Desk Study, August 
2006 commissioned by CIDSE (Coopération Internationale pour le Développement et la Solidarité/International Coop-
eration for Development and Solidarity) and Caritas Europa.BOX 3
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation18
19 One of the programmes 
provided for by the Development 
Cooperation Instrument 
(see paragraph 9).
20 Article 20(2) of Regulation (EC) 
No 1905/2006.
21 The European NGO 
Confederation for Relief and 
Development (CONCORD) was 
set up in January 2003 as the 
representative and interlocutor body contemplated in Regulation 
(EC) No 1658/98 laying down the 
NGO co-financing programme. 
It regularly engages in dialogue 
with the EU institutions, and coordinates cooperation between 
NGOs. Its 22 national associations 
(platforms) and 20 international 
thematic networks represent 
over 1 600 NGOs.
22 It was also sent directly to 
CONCORD, the European Economic 
and Social Committee, the 
Committee of Regions, and the 
Council of European Municipalities 
and Regions for dissemination among their members.
23 It was launched on 31 July 2006 
and ran to 11 September. This 
is less than the eight weeks 
prescribed as a minimum period 
for consultation.THEMATIC PROGRAMME ON NON-STATE ACTORS 
AND LOCAL AUTHORITIES IN DEVELOPMENT
 30.  This new programme19 is the successor of the former co-financing with 
European NGOs and decentralised cooperation programmes, and,  like its predecessors, is one of the more important and stable EC  sources of financing for the activities of NSAs and support of their 
own initiatives.
 31.  In drawing up the strategy papers for such thematic programmes the Com-
mission is required to consult other development actors, including 
representatives of NSAs and local authorities, at an early stage of the programming process
20. European NGOs (ENGOs) through CONCORD21 
have traditionally been heavily involved in dialogue on the manage-ment of the NGO co-financing programme. The new programme is  also open to NSAs and local authorities from partner countries which thus should also be involved in the consultation.
 32.  After establishing the strategy paper for this programme, Commission 
headquarters requested Delegations to produce, on the basis of fur-
ther consultations with local NSAs, concept notes assessing the rele-
vance of the programme for their partner countries and justifying the 
appropriate level of expenditure. The Court examined the effective-
ness of both phases of consultation, again using as criteria those set out in the Commission’s 2002 communication (see paragraph 20).
 33.  For the overall strategy, the Commission ran an online public consult-
ation, aimed at both European NSAs and those originating from the 
partner countries (Southern NSAs), through a questionnaire pub-
lished on the Commission’s website and sent to Delegations22. At the 
European level, viewed in the context of routine ongoing contacts between the Commission and CONCORD, this method of consultation was effective. However, consultation of Southern NSAs was not organ-ised effectively. The questionnaire was sent out to ACP Delegations, 
which were expected to inform NSAs of the consultation and pass the 
questionnaire on to them. However, the timing of the consultation — 
at the peak leave period for Delegation staff — was inappropriate  
and so short as to be impracticable
23 (the ACP Delegations visited for 
this audit, Ethiopia and South Africa, were not able within the short deadline to consult NSAs). Furthermore, such a request was not sent 
to Delegations in ALA countries, and thus NSAs in ALA countries were 
not made aware that the consultation was running.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation19
24 For Ethiopia and South Africa, 
their respective Commission 
Delegations decided not to participate in this programme.
25 On sustainability in practice, 
see paragraphs 63 to 68. 34.  For the second phase, due to delays in adopting the DCI regulation 
and the strategy paper, Delegations had only a month to prepare  
the concept notes and most of them could not involve NSAs in any structured way. In Bangladesh an ad hoc workshop with NSAs took 
place. For Peru, however, the Delegation did not consult NSAs
24, and 
a review of a sample of concept notes (Angola, Chile, Malawi, Namibia and Nepal) provided further evidence of lack of consultations with NSAs on this programme.
 35.  In the Court’s view the Commission gave too little attention to methods 
of consultation with Southern NSAs. Very active facilitation by Delega-
tions — in addition to the passive method of placing a questionnaire 
on the Internet — is evidently necessary in many countries, and was partly envisaged (for the ACP countries) but not fully implemented anywhere. Furthermore, attention was not given to the potential limi-tations of consulting the potential recipients of grants about priority 
areas, a consultation in which they could hardly be disinterested; and 
alternatives such as networks, umbrella and regional bodies were not 
explored.
DO THE COMMISSION’S MANAGEMENT SYSTEMS 
EFFICIENTLY ENSURE THAT ACTIVITIES IMPLEMENTED BY NSAs ARE RELEVANT AND LIKELY TO PRODUCE THE INTENDED RESULTS?
 36.  The Court audited the management systems for NSA grant contracts 
at Commission headquarters as well as on the spot at four Delega-tions, including examination of 16 individual projects (see Annex III ). 
The audit covered the procedures for selecting projects, control and supervision arrangements, the monitoring done and the tools used 
for this, and the question of sustainability.
SELECTION PROCEDURES
 37.  The aim of the audit of selection procedures was to determine the extent 
to which the procedures applied ensured the selection of projects  
that were relevant, timely and likely to be sustainable25.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation20
THE CALL FOR PROPOSALS  PROCEDURE  PROMOTES  FAIR COMPETITION  
BUT CAN STILL  BE CUMBERSOME  IN OPERATION  AND DOES  NOT ASSURE  TIMELY  
COMPLETION  OF PROJECT  DESIGN
 38.  The standard selection procedure has been, since 2000, by means of 
calls for proposals. Although the procedure is recognised as allow-ing fair competition among NSAs and therefore should improve the likelihood of selecting relevant projects, it continues to represent an 
administrative challenge for both the Commission and for applicant NSAs. Calls for proposals raise considerable interest among NSAs  
and the number of funding requests has always greatly exceeded the 
available funds
26. This has led to lengthy procedures and required the 
assistance of external experts. Also, calls under the co-financing with 
NGOs programme have been too general and unfocused, increasing the likelihood of less relevant applications being transmitted. Finally, the implementation of the detailed procedures can be cumbersome for small NSAs.
 39.  Whereas the calls for proposals audited generally led to the selection 
of relevant projects, the audit showed that for the projects audited 
the average time between the submission of proposals and the actual 
signing of contracts was more than a year, making it difficult for NSAs 
to plan effectively. The Court also found that the methods used to 
advertise the calls (mainly through the Internet and newspapers) were 
not always suited for reaching relevant NSAs at grass-roots level27.
 40.  The Court welcomes that the Commission has taken measures in 2006 and 
2007 to improve the efficiency of the Call for Proposals procedure, 
although it is not yet possible to assess the full effects. The measures include:
introduction of the restricted procedure which allows a first selec- (a) 
tion of applicants based on a short concept note, with the full  proposal (including project design) being submitted to a second stage of selection;
the combined use of two years’ budget in a single call for  (b) 
proposals;26 For a budget of 284 million euro 
for the 2007–08 calls for proposals 
under Thematic programmes 
managed at central level by 
EuropeAid, 4 565 applications were received, amounting to total 
requests for 3 650 million euro. 
After a first selection based on a 
concept note, 1 088 applications 
amounting to 989 million euro 
passed to the second stage of 
selection, and only 212 were finally selected.
27 For example, because only 
European languages are used, 
or because newspapers are not rapidly distributed to 
remote areas.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation21
EXAMPLE OF POOR PROJECT DESIGN
Promotion of the incorporation of women micro-entrepreneurs and family-based economic units 
in the formal labour system — Peru
Th e local NGO partner implemented this project in four regions including Junin which was visited by the Court in 
February 2008, and where the NGO did not have a previous presence. Although a results oriented monitoring exercise as recently as 2007 had not forecast such problems, the Court found no evidence that the NGO had involved the rel-
evant public authorities in the design of the project activities. Nor did the NGO coordinate with the existing networks 
and organisations supporting the micro-enterprises in the region. During the project implementation the local NGO 
partner had to contract one such network to carry out basic research to identify potential benefi  ciaries and economic 
opportunities. Th  e project design was based on the idea that it would be replicated and expanded by the public authori-
ties. However, the Court found that the relevant authorities were either not involved in the project at all, did not work 
as they were supposed to, or did not have enough fi  nancial and human resources to take over the project activities.BOX 4the introduction of an online registration service (PADOR)  reducing (c) 
duplication of work for applicants;
the increasing use of ‘tailor-made’ local calls for proposals where (d) 
the objectives have been adapted to the local situation and locally-
based organisations have more chance of being selected.
 41.  However, problems with project design, which may profoundly affect the 
effectiveness and sustainability, remain widespread. For several of the projects audited, insufficient preparation for the formulation of activities meant that the first year of the projects had to be devoted to project design (carrying out diagnostics, identification of beneficiar-ies, studies). This reduced the time available for effective implemen-tation, making the project more vulnerable to delays, and worsening the prospects for sustainability. The example in Box 4  serves as an 
illustration.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation22
CONTROL AND SUPERVISION PROCEDURES
 42.  The aim of the audit of the Commission’s control and supervision proced-
ures was to determine the extent to which they ensured a smooth  
implementation of NSA project activities. While numerous evalu ations have found that stakeholders find procedures cumbersome
28, which 
has also been a matter of concern to Parliament29, the Court recog-
nises the efforts made by the Commission to address the problem. 
High level initiatives taken by the Commission include setting up  an inter-service committee to simplify procedures, strengthening  
the dialogue between the Commission and CONCORD on financial  
and contractual issues (leading to a Reader on the standard grant  
contract) and issuing new practical guides and simplified forms and 
documents. The devolution of the thematic programmes has  generally also helped improve the dialogue between the EC and NSAs.
 43.  The control and supervision procedures were operating correctly in many 
respects, but there remain some specific problems which lead to  
errors30.
THE GUIDANCE  PROVIDED  TO NSA S ON HOW  TO APPLY  THE RULES  IN PRACTICE  
HAS NOT BEEN  SUFFICIENT
 44.  Practical guidance on how to apply the EC’s financial and contractual 
rules needs to take into account the turnover of staff in the Com-mission’s Delegations and, within NSAs, a limited level of knowledge about these rules. Among the methods used to improve knowledge 
are training courses held in the Delegations for both staff and bene-ficiaries, and the endorsement of a hands-on guide produced in  
cooperation with CONCORD (the so-called Reader on standard grant 
contracts).
 45.  The training is useful but for the beneficiaries mostly consists only of 
one-day workshops after the conclusion of the calls for proposals.  
The Court found this to be insufficient to ensure that the NSAs ‘insti-
tutionalise’ the knowledge required to apply the rules correctly in  
the course of a typical project implementation period.28 The issue was also raised 
in a letter from CONCORD 
to Commissioner Nielson of 
17 March 2004 on the impact 
of the financial regulation and 
its derived documents and 
procedures on NGOs.
29 The European Parliament in 
the 2004 discharge stated that it: 
‘regrets [ ... ] the vastly increased 
complexity of the new procedures, 
which are cumbersome and take 
far too long to implement, points out the need for real simplification, 
while not losing sight of the 
original objective’ (Resolution 
of the European Parliament with 
comments forming an integral part of the decision on the 
discharge for implementation 
of the European Union general 
budget for the financial year 2004, 
Section III — Commission 
(OJ L 340, 6.12.2006, p. 5), 
point 185).
30 Similar findings resulted from 
the Court’s DAS audits: see the 
Court’s Annual Reports concerning 
the financial year 2007 on the implementation of the budget, 
paragraph 8.9; and on the 
European Development Funds 
(EDFs), paragraph 22.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation23
 46.  The audit found little evidence that the Reader was used by Delegation 
staff or by beneficiary NSAs. Its non-legally-binding nature may be 
one of the reasons why staff in Delegations decided against using it as a standard reference document.
 47.  When changes in the Practical Guide and contract conditions occur (the 
Practical Guide has been modified five times in last seven years) they 
have not been communicated systematically to the grantees. More-over, there have been inconsistencies in the interpretation of the  
rules, which meant that grantees in some instances have been asked 
by the Commission to operate under new conditions even when they 
were not applicable retrospectively.
PROJECT  AUDITS  WERE  NOT ALWAYS  OF SUFFICIENTLY  HIGH  QUALITY
 48.  For several of the projects examined in this audit, shortcomings were 
noted in the quality of project audits. They did not effectively detect errors affecting the eligibility of transactions at grantee and imple-
menting partner level. The specific assessments of EDF and external 
actions in the context of the Court’s annual reports
31 noted similar 
shortcomings in project audits.
 49.  In an effort to address these shortcomings the Commission has developed 
revised terms of reference to ensure that the audit work is compre-hensive, which became obligatory for project contracts from Febuary 2006. For the projects audited, it was too early to assess the effect 
of this change.
INCONSISTENCIES  IN THE INTERPRETATION  AND APPLICATION  OF PROCEDURES  
LED TO UNNECESSARY  ADMINISTRATIVE  BURDENS  ON NSA S
 50.  The audit noted that some practical administrative problems in the 
 management of grant contracts persist, including:
inconsistent interpretations of the rules of origin for supplies  (a) 
purchased under EC-financed contracts, which may have burdened 
NSAs unnecessarily (example in Box 5 );31 For instance paragraph 8.24 
in Chapter 8 of the Court’s Annual 
Report concerning the financial year 2007 (OJ C 286, 10.11.2008, 
p. 182).
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation24
difficulty for NSAs in obtaining tax exemption or recovering taxes (b) 
in some partner countries;
the requirement to use an EC-notified exchange rate (instead of (c) 
the rate in fact obtained), that could penalise projects in some 
circumstances;
delays by the Commission in approving payment requests, which (d) 
might result in project delays;
additional requirements inconsistently imposed on projects by  (e) 
Delegations, adding unnecessary administrative burdens on the 
NSAs, such as: (i) additional periodic reports or audit reports;  
(ii) the use of separate, specific bank accounts for each project; 
(iii) payment options different from the one laid down in the  general conditions (e.g. smaller instalments).
EXAMPLE OF INCONSISTENT INTERPRETATIONS OF THE RULES OF ORIGIN
Purchases of motorcycles — the case of Ethiopia
Japanese vehicles are generally preferred by NGOs in Ethiopia because their quality is reliable under local conditions. 
However, the Delegation invited NGOs within the framework of Food Security projects to consider Chinese vehicles also, partly because it believed that derogation was needed for Japanese but not for Chinese vehicles.
Refl ecting the Delegation’s assumptions on the derogation rules, one NGO purchased 10 Chinese motorcycles without 
requesting derogation. As several of these broke down the NGO on 14 December 2006 requested permission and dero-
gation from the rules of origin to buy an additional two motorcycles of more robust Japanese manufacture, which was initially rejected by the Delegation. On 11 September 2007, the Delegation eventually did accept the request when it was 
resubmitted with a request for a budget amendment.
Meanwhile, the Court found that the Delegation had consulted Headquarters in April 2007 when both parties had con-
cluded that derogation was not required for Japanese goods purchased in Ethiopia under a thematic budget line, while derogation was and always had been required for Chinese goods.
Th e rules, however still appear to be open to diff  ering interpretations
32.BOX 5
32 Under the Council Regulations on access to Community external assistance, especially Articles 3(2), 3(3) and 5 and 
Annex II, projects financed by the thematic programmes in Ethiopia could benefit as from 28 December 2005 from goods 
originating both from Japan and China without any request for derogation, since Ethiopia is classified as a least-developed country. Contrary to this, goods specifically originating from China require a request for derogation in case of a grant 
contract financed by the EDF. The EDF regulation also allows purchase of goods, irrespective of their origin, on the local 
market up to 30 000 euro.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation25
33 Logical Framework Approach 
and Logical Framework Matrix 
(the Logframe) are analytical and 
management tools widely used 
in development cooperation by 
donors and partner governments. The typical design of a Logframe 
involves tasks such as formulating 
SMART indicators (Specific, 
Measurable, Achievable, Relevant 
and Timed), identifying adequate 
sources of verification, setting 
realistic targets for each indicator, and collecting baseline values for 
later measurement of progress 
and results achieved. An adequate 
performance-monitoring system 
would therefore include regular collection of data on the actual 
results. NSAs are sometimes also 
asked to collect data and report 
not only on inputs, processes and 
outputs, but also on mid-term 
outcomes and long-term impacts.MONITORING INCLUDING TOOLS AND ASSESSMENTS 
OF THE EFFECTIVENESS OF NSA ACTIVITIES
 51.  Effective monitoring is an essential part of the management of projects, for 
which the Commission uses a number of tools and procedures. The aim of the Court’s audit was to determine, in the light of the existing Com-mission procedures, if: (i) the IT systems provide the necessary manage-
ment information to take decisions and monitor NSA activities; (ii) a 
management reporting system is in place; (iii) Delegations ad equately monitor the projects, receive sufficient feedback from external moni-
toring and evaluations, and follow up on them; (iv) suitable tools for 
assessing outputs and results of activities are used; (v) adequate tools 
for assessing the long-term impact of activities are used.
THE COMMISSION ’S COMPUTERISED  INFORMATION  SYSTEM , CRIS, 
HAS NOT BEEN  USED  TO ITS FULL  POTENTIAL
 52.  As noted in paragraph 5, there is at present no readily available source 
of data in EuropeAid concerning NSA funding in the field of develop-
ment cooperation. The data in the Common RELEX Information System 
(CRIS) is incomplete and the identification of operators unreliable. 
It provides little information in the form of analysis and syntheses 
of the state of play for ongoing and completed projects, including 
assessments and conclusions. The CRIS Implementation Report, a  
monitoring tool, does not fully meet users’ needs and is often not  properly used.
PROJECT  REPORTS  HAVE  NOT ALWAYS  PROVIDED  AN ACCURATE  ASSESSMENT  
OF THE STATE  OF IMPLEMENTATION
 53.  NSAs benefiting from a grant must provide technical and financial  
reports, which should allow for a comparison between the project  proposal and what was achieved during the reporting period. For half of the projects audited these reports did not present a comprehen-sive assessment of the state of implementation. In general, reports tended to underemphasise the most challenging issues and focus on the positive achievements.
 54.  Under the current procedures, NSAs have to apply a logical framework, 
including quantitative performance indicators33. However, for 13 of 
16 projects audited, the technical reports did not provide a direct com-
parison between the expected and achieved results using the logical 
framework. Hence the Logframes in several of the projects audited were 
gradually losing their relevance as tools for project monitoring.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation26
 55.  The Court noted in its benchmarking exercise that some agencies apply 
a quality assurance mechanism with respect to Logframes, including 
quantitative and qualitative performance indicators.
INSUFFICIENT  PROJECT  FIELD  VISITS  CARRIED  OUT BY COMMISSION  STAFF
 56.  Proper monitoring of projects by Delegations includes regular and direct 
contacts with the NSA partners, and discussions on implementation issues affecting project performance. The audit examined to what  extent the Commission carried out physical, on-site inspections of  projects including checking the accounts and supporting documents of projects in the offices of the grant beneficiaries and their imple-menting partners. The Court found that the level of on-site controls was insufficient.
 57.  Moreover, many NSAs interviewed expressed regret about the lack of 
on-site support from the Delegations. Their responses suggested  that many errors related to the financial and contractual rules could 
be avoided by on-site checks at the appropriate point in time, as  
 incorrect practices would become visible and could be rectified.
 58.  Six out of the 16 audited projects had not been visited by Delegation 
staff at all. For the projects visited, there was generally no systematic pattern. Sometimes visits were made in connection with events organ-ised by the NSAs, sometimes they were made jointly with external  
monitoring missions. In some cases specific and concrete plans to  
carry out field visits at defined stages of the projects’ lifetime were indeed laid down. However, in all these cases the plans were not fully 
implemented due to a lack of resources. There was no standard for 
the monitoring reports established by the Delegations visited by the 
Court. Before December 2007, staff had no operational guidelines for project monitoring.
 59.  Projects may also be selected for external monitoring through the results-
oriented monitoring missions of the Commission (ROM). This tech-
nique, however, does not compensate for an absence of monitoring at 
operational level: most projects involving NSAs have an EC contribu-tion of less than 1 million euro, and under the ROM system only about 
10 % of projects below this value are selected for monitoring.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation27
34 The last generation of grant 
contracts signed in Peru already 
foresees this.EXTERNAL  EVALUATIONS  HAVE  NOT PROVIDED  ADEQUATE  ASSESSMENTS  
OF THE IMPACT  OF NSA PROJECTS
 60.  NSA grant contracts generally provide for external evaluations at the 
end of the project and/or at mid-stage. The standard terms of refer-ence for evaluations are not compulsory for this type of evaluation, and there is a risk of conflict of interest as under current practice the 
contracting of evaluators is done by the beneficiaries. The Court noted 
in benchmarking that certain development agencies operate a quality assurance mechanism with respect to evaluations  commissioned by 
the beneficiary NSAs.
 61.  The evaluations carried out, together with the other assessment and 
reporting instruments currently in use (NSAs’ reports, field visits and ROM reports), do not provide adequate assessments of the impact of NSAs’ individual projects. This is either because the objectives are expressed in such broad terms that they cannot be associated with measurable indicators of impact, or because the means of verification are inadequate or too costly.
 62.  The Commission is moving towards results-based management with more 
emphasis on measuring the impact and results and evaluating the  
added value of its development cooperation. This puts greater pres-
sure on NSAs to develop systems to monitor not only outputs but also outcomes and impacts
34, and requires that more practical guidance 
is provided by Commission services to ensure that Logframes and  performance indicators are appropriate and remain relevant.
PROSPECTS FOR SUSTAINABILITY
 63.  The project selection process includes the assessment of sustainability, 
that is of the prospects for the project results to be permanent. The Commission has recently introduced ex post  results-oriented monitor-
ing that covers sustainability and impact at project level.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation28
 64.  While the 16 projects audited have achieved or are likely to achieve good 
results in the short term, their prospects for sustainability were much 
less positive. At the time of the Court’s audit, sustainability was uncer-tain for 12 of the projects, either because of a lack of funds after the 
end of the project or due to inadequate institutional arrangements. 
An example of the latter is provided in Box 6 .
 65.  The prospects for sustainability for the remaining four projects were good 
not because they were intrinsically sustainable, but rather because 
they are run by international NGOs with long-term commitment, which 
are able to secure funding from other sources than the European  
Union.
 66.  Long-term commitment and funding, together with the need to ensure 
institutional arrangements allowing the relevant stakeholders to take 
over the activities, are essential elements of sustainability. The Court’s 
audit has shown that project duration is generally insufficient to  
ensure sustainability even after extensions35. In addition the actual 
implementation period is in practice often shortened by late start-up 
(see paragraph 41).
 67.  The current project approach is also faced with the potential contradic-
tion of using short-term interventions to address structural problems that need long-term commitment. Sustainability is especially a prob-lem for the capacity-development element of projects because this 
typically requires social and attitude changes which require much  
more time than is generally available for project implementation.35 The average period for the 
projects audited was 37 months, 
extensions included.
SUPPORT TO POLICING OF CRIMES AGAINST WOMEN AND CHILDREN IN THE EASTERN 
CAPE (SOUTH AFRICA) — VICTIM FRIENDLY CENTRES
Whereas the South African police authorities were able to continue to cover the running costs of the care centres for 
victims of violence aft  er the project ended, there was a risk that volunteers working in the centres would not be available 
in the future as the Social Welfare Department had not yet assumed the responsibility for their supervision and training 
as foreseen in the project design.BOX 6
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation29
 68.  The Court noted in its benchmarking exercise that other development 
agencies avoid some of the problems of poor design and short project 
duration by using a range of instruments in addition to specific  projects, including long-term framework partnership agreements  
with competitively selected NSAs
36.
DOES THE COMMISSION ADEQUATELY ENSURE 
THE PROVISION OF CAPACITY DEVELOPMENT TO NSAS?
 69.  This section addresses the question whether the Commission has translated 
both the legal requirements and the policy statements on capacity-
development support for NSAs into a strategy in all the beneficiary countries and regions, and carried it out through relevant activities 
effectively implemented.
STRATEGY FOR CAPACITY DEVELOPMENT OF NSAs
 70.  Capacity development is intended to strengthen NSAs’ role both as part-
ners in the development process and as implementing actors37. In  
order to support it effectively, and to ensure coherence and comple-
mentarity with other programmes and donors, the Commission needs to devise a strategy for each country setting out which NSAs, sectors and themes should be targeted, and what working methods to use.
 71.  The Court examined whether such a strategy existed for the ACP coun-
tries (where the provision of capacity development to NSAs is bind-ing), and for Asian and Latin American countries, where the former 
ALA regulation did not mention capacity development. The Court  
also examined whether the entry in force in January 2007 of the DCI, 
which repealed the ALA regulation and mentions the provision of  
capacity development to NSAs, has meant any change in the existing 
strategies.36 Several development agencies 
use framework partnership 
agreements which typically run for four to eight years.
37 Capacity-development 
support to NSAs is meant to 
strengthen their role as partners 
in development cooperation (see 
paragraph 8 and Box 1) but it also includes training in project 
management to improve the 
quality of their projects and to 
increase their capacity to apply for 
and raise funds from donors.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation30
EXISTENCE  OF TWO DIFFERENT  APPROACHES
 72.  Following the signature of the Cotonou Agreement (see paragraph 8), 
in most of the ACP countries strategies have been developed and  
programmes set up for capacity development of NSAs, financed by 
the EU38. For Asian and Latin American countries there are neither  
particular strategies for EC-supported capacity development of NSAs 
nor such programmes39. This difference does not result from an over-
all assessment of needs, but mainly reflects the fact that capacity-development support to NSAs in ACP countries is legally required, 
whereas for ALA countries it was not.
 73.  The DCI, applicable since 2007 for ALA countries, includes capacity-
development for NSAs in the areas of cooperation covered by geo-
graphic programmes and sets out as an important principle that these 
programmes should be the normal instrument for providing support, 
since they are based on assessments of needs and strategic partner-
ships with governments. Thematic programmes, on the other hand, 
are only to be used if the geographic programmes are not appropriate, for example in countries with difficult partnerships
40 or having popu-
lation groups out of reach of mainstream services and resources and 
excluded from the policymaking process. Despite this clearly stated 
principle, there has been no change in the way in which capacity-
development support is funded in ALA countries since the entry into force of the DCI, and the existing support continues to be funded by the thematic programme (non-state actors and local authorities in development).
 74.  The lack of a particular strategy is further underlined by the fact that 
for Asian and Latin American countries, where funds for NSA cap-
acity development are more limited, the possibilities to mainstream 
involvement of and support to NSAs in the main sectoral programmes 
financed in these countries (e.g. health or education) have neverthe-
less not been fully explored. The Commission is preparing a docu-
ment41 with the aim of producing guidelines for Delegations that will 
help to address this issue.38 In the ACP countries there are 
around 46 capacity-development 
programmes in 43 countries, 
amounting to 226 million euro.
39 There are some exceptions 
usually resulting from highly specific circumstances such 
as Bangladesh because it 
has a very large NGO sector 
(206 000 organisations) or 
Colombia because of its internal armed conflict.
40 Situations of difficult 
partnership are defined as those 
where for one of the following 
reasons the usual cooperation 
instruments cannot be fully used to support initiatives undertaken 
by stakeholders other than central 
governments: (1) countries where 
cooperation has been suspended; 
(2) countries where the authorities are not committed to objectives 
of poverty reduction and to other 
basic principles of development 
policy, including good governance 
and participation of NSAs and 
decentralised authorities; 
(3) countries where the dialogue on participatory approaches 
to development is very limited.
41 The participation of NSAs in 
poverty-reduction strategies, 
sector approaches and monitoring 
of project implementation (draft paper of EuropeAid E.4, 
August 2008).
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation31
PROGRAMMES ON CAPACITY DEVELOPMENT OF NSAs
 75.  The Court examined seven programmes amounting to 72,1 million  
euro ( Annex III ) to assess their relevance and how efficiently they  
have been implemented42. These programmes combine capacity-
development activities with the funding of a series of small  projects.
 76.  The Court examined whether the programmes started on time, whether 
they were implemented within reasonable timescales, and whether 
the management procedures were sufficiently flexible and suited local 
realities, especially of small and community-based organisations.
PROGRAMMES  ARE RELEVANT  ALTHOUGH  THERE  IS A LACK  OF DETAILED  SITUATION  
ASSESSMENTS  IN ALA COUNTRIES
 77.  The programmes examined were found relevant and addressed clear 
needs and priorities of the NSAs. The Commission guidelines recom-
mend that Delegations should carry out a detailed situation assess-
ment or ‘mapping study’ to identify in each country representative 
NSAs and assess their capacities, constraints and potential, as well the work of other donors. However, in the ALA countries, where the-matic programmes are in practice the main instrument for the provi-sion of capacity-development support to NSAs, the value of mapping 
studies is less strongly perceived. For the six countries reviewed
43 
only Delegations in ACP countries (Ethiopia, Mali and Uganda) have 
undertaken full mapping studies and their quality varies.
DELAYS  IMPINGE  ON THE EFFICIENCY  AND EFFECTIVENESS  OF THE PROGRAMMES
 78.  Inherent features of the programmes, the effects of which had not been 
sufficiently foreseen, led to significant delays in six of the seven  programmes examined. Most important was the cumulative effect  
of the lengthy management procedures required first to contract  
international technical assistance, then for the technical assistants to 
prepare calls for proposals, and finally to evaluate proposals and sign 
the grant contracts. A second factor was the tripartite management structure, involving government, NSAs and Commission Delegations. 
Although this structure is essential to ensure ownership it entails long 
debates and negotiations both to build initial consensus amongst the 
parties concerned and to implement it.42 Due to the late start of the 
programmes, it was generally too 
early to assess their effectiveness.
43 Bangladesh, Ethiopia, Mali, Peru, 
South Africa, and Uganda.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation32
44 In the case of the Ariane 
programme in Mali, the lifespan of 
the projects for the two last calls for proposals had to be reduced 
to only six months.
45 For example, in Ethiopia 
only 11 (5 %) out of 208 applicants 
were selected in the first call, 
all either international or capital-based NGOs. 79.  These delays effectively limit the period of implementation of the activ-
ities, especially those of the grantees, leading to decommitment  
of funds and cancellation of activities, and particularly to reduc-tion of the lifespan of projects, thus damaging the prospects for  
 sustainability
44 (see paragraph 83(b)).
THE IMPLEMENTATION  OF CALLS  FOR PROPOSALS  DOES  NOT ALWAYS  FAVOUR  
THE NSA S MOST  IN NEED  OF CAPACITY  DEVELOPMENT
 80.  Since capacity development of NSAs is the focus of these programmes, the 
process of project selection must target beneficiaries that, being pre-
cisely those lacking in certain organisational capacities, may have dif-ficulty meeting the many requirements prescribed by EC proced ures. 
The Court found that even though many applications were received, in 
the outcome calls for proposals tended to favour the best-resourced, 
mainly urban-based, organisations over under-resourced and mainly 
rural-based organisations
45.
 81.  Delegations, in the framework of geographic programme implementation, 
drew lessons from these first experiences for the subsequent calls: (i) 
encouraging partnerships between weak NSAs and stronger ones; (ii) 
funding strong NSAs to train and mentor wider groups of weaker NSAs; (iii) selecting remote regions; (iv) allocating funds by geographical distribution. However, the Commission action does not address all the concerns originally set out in the Commission’s communication 
and guidelines (see paragraphs 11 and 12), which mention the aim 
of reaching out to as large a proportion of the populations as pos-
sible, and emphasise that special attention will be given to small and 
grass-roots organisations, especially in countries that cover a large geographical area and where many groups and areas are isolated  
from the consultation and decision-making process.
TOO EARLY  TO ASSESS  EFFECTIVENESS  
OF MOST  OF THE CAPACITY -DEVELOPMENT  PROGRAMMES
 82.  Due to the late start of the programmes, it was generally too early to 
assess their effectiveness. Where mid-term evaluations have been  
conducted, good results have generally been reported.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation33
46 The ACP capacity-development 
programmes, resulting from a 
consistent strategy, have common organisational characteristics 
including the use of technical 
assistance. By contrast the few 
ALA programmes were established 
ad hoc and vary in structure.
47 In Mali, the Court found 
that technical assistance had 
duplicated the call for proposals 
and project-control procedures 
by contracting additional 
external assistance to evaluate proposals but reassessing itself 
the evaluations made. The reason 
was that technical assistance did 
not want to incur financial risk (it 
was asked to provide a financial 
guarantee for the running of the 
programme).
48 Under Article 4 of the Cotonou 
Agreement non-state actors are to 
’be provided with 
capacity-building support in critical areas in order to reinforce 
the capabilities of these actors, 
particularly as regards organisation 
and representation, and the 
establishment of consultation 
mechanisms including channels of 
communication and dialogue, and to promote strategic alliances’. 83.  However, in the ACP programmes examined46, the Court found indica-
tions that the following aspects require further attention from the 
Commission:
since the programmes combine capacity-development work with (a) 
the funding of a series of small projects, the specialised technical 
assistance teams, which have particular competences in capacity development, also have to carry out routine project management administration
47. As regards capacity development, the teams have 
concentrated on training in project management rather than on enhancing NSAs’ skills in policy analysis, advocacy work, watch-
dog functions, promoting human rights, promoting networking, 
etc., thus underemphasising the policy dialogue role (see para-
graph 3(a)), which is also part of the capacity-development agenda 
defined in the Cotonou Agreement
48;
the Court found that impact and sustainability are insufficiently (b) 
addressed in these programmes. The overall funding was too low, 
and in some cases too scattered over too many small projects to 
have a significant impact. Project duration was short, ranging from 
as little as six months to a maximum of 24 months, whereas, since 
capacity development is a long-term process, the Court considers that a longer implementation period is needed.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation34
CONCLUSIONS AND 
RECOMMENDATIONS
THE COMMISSION DOES NOT ADEQUATELY 
ENSURE THAT NSAs ARE INVOLVED EFFECTIVELY 
IN THE DEVELOPMENT COOPERATION PROCESS
 84.  Through its Delegations the Commission has tried to involve NSAs in the 
preparation of country strategies in virtually all beneficiary countries. However, in many cases the involvement has been limited to one-day seminars rather than the sustained and structured dialogue envisaged 
by the EU legislation and the Commission’s own guidelines. There are widespread weaknesses in the detailed consultation procedures.
 85.  As regards the new thematic programme on NSAs, Southern NSAs were not 
adequately involved either in the overall or the local strategies, even though this is a programme primarily designed for these actors.
RECOMMENDATIONS ON INVOLVEMENT OF NSAS
The Commission should make further efforts to strengthen the involve-
ment of the relevant NSAs in its development cooperation process. This 
involvement should go beyond the definition of the country strategies 
and include sectoral strategies and projects.
The Commission should take the following steps to strengthen the  
process by:
identifying the relevant NSAs; —
establishing clear and predictable schedules of consultations, for  —
both geographic and thematic strategy papers;
providing the necessary documentation and enough time for NSAs  —
to prepare themselves properly, and feedback on the results of  
these consultations;
developing further guidance and training for the Delegation   —
staff.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation35
THE COMMISSION’S MANAGEMENT SYSTEMS GENERALLY 
ENSURE THAT ACTIVITIES IMPLEMENTED BY NSAs 
ARE RELEVANT AND LIKELY TO PRODUCE THE INTENDED RESULTS, BUT THERE ARE SHORTCOMINGS
 86.  The Call for proposals procedure can still be cumbersome and in oper-
ation does not ensure sufficient attention for, and timely completion of, project design.
 87.  There is insufficient guidance and training for NSAs on the practical 
application of the financial rules, and inconsistent interpretations  
as well as specific practical problems persist.
 88.  There are weaknesses in monitoring and evaluation.
 89.  Prospects for long-term sustainability are poor mainly because of the 
short project duration, lack of long-term funding and inadequate  
institutional arrangements.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation36
RECOMMENDATIONS ON MANAGEMENT  
OF ACTIVITIES IMPLEMENTED BY NSAs
Selection procedures
Measures already in train to improve implementation of the Call   —
for Proposals procedure should be carried through with particu-lar emphasis on aspects that could help to assure good project  design.
Control and supervision procedures
Besides resolving outstanding issues, the Commission should ensure  —
that guidance and support on procedures are more accessible to 
the potential beneficiaries.
The Court would like to reiterate its view that there is scope for pre- —
venting errors relating to financial and contractual rules by means of 
enhanced targeting of monitoring and support by Delegations49.
Monitoring
In light of its intended move to results-based management the Com- —
mission should ensure that sufficient resources, guidance and exper-
tise are available to both Delegations and NSAs to develop, apply, 
monitor and report on quantitative and qualitative  performance  
indicators.
Sustainability
In order to improve sustainability, the Commission should consider  —
the use of a mix of instruments when working with NSAs and not 
only projects.
The Commission should carry out selective post-implementation —
reviews of the sustainability and long-term impact of NSA  
projects.49 Paragraph 8.18 in Chapter 8 
of the Court’s Annual Report 
concerning the financial year 2007.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation37
THERE IS A STRATEGY FOR CAPACITY DEVELOPMENT 
OF NSAS IN ACP COUNTRIES BUT NOT YET FOR MOST 
OF THE ALA COUNTRIES
 90.  A strategy does not exist for most of the ALA countries. Unlike in the ACP 
countries, where geographic programmes are used, in ALA countries there is too much dependence on the thematic programme on NSAs for funding capacity development. In the Court’s view this is not  
appropriate because it is contrary to the principle stated in the DCI Regulation that geographic programmes should be used whenever 
possible.
RECOMMENDATIONS ON STRATEGY DEVELOPMENT
The Commission should develop strategies for capacity development of 
NSAs in ALA countries setting out which NSAs, sectors and themes are 
to be targeted, what working methods will be used, and how coherence 
with other programmes is assured. It should reconsider the disparity in the approach as between ACP and ALA countries.
ALTHOUGH THE CAPACITY-DEVELOPMENT 
PROGRAMMES ARE RELEVANT THEY HAVE NOT REACHED THEIR FULL POTENTIAL
 91.  The audited programmes were found highly relevant although needs 
assessments in the form of comprehensive ‘mapping studies’ were  not carried out for the ALA countries. The programmes have not, how-
ever, reached their full potential mainly because their management 
procedures and structures are inherently complex. The consequences 
of this were not fully appreciated from the start, and the resulting delays had a direct impact by reducing the time available for the  active life of projects, so worsening their prospects for effectiveness and sustainability.
 92.  These programmes are faced with the potential contradiction of sup-
porting capacity development of the NSAs most in need by means  of a procedure (Call for Proposals) which is designed to select the  
best-performing NSAs.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation38
RECOMMENDATIONS ON IMPLEMENTATION  
OF CAPACITY-DEVELOPMENT PROGRAMMES
The Commission should take full account of their inherent complexity 
when planning these programmes. It should also consider the inter-
action between the necessarily complex structures and the legal frame-work, and devote resources to examining ways of delivering the policy aims within this constraint.
Alternatives to the current procedures should be explored, both to  
allow a more strategic approach (such as a better use of the capabilities of technical assistance, use of partnership agreements, multi-donor funding) and to better reach the grass-roots organisations (such as  
the use of cascading grants).
  This Report was adopted by the Court of Auditors in Luxembourg at its 
meeting on 18 and 19 March 2009.
  For the Court of Auditors
Vítor Manuel da Silva Caldeira
President
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation39
CONTRACTED AMOUNTS WITH NSAs
According to EuropeAid, the contracted amounts with NSAs in  
2006 and 2007 can be estimated at 836,43 and 915,26 million euro ( excluding Humanitarian aid
1), as follows: 
(million euro)
DOMAIN Year 2006 Year 2007
Thematic Programmes 555,04 430,11
NGO Co-fi  nancing 200,10 207,89
Decentralised Cooperation 6,30 0,18
Human Rights and Democracy 97,28 40,72
Environment 59,14 21,08Food Security 74,84 109,26Gender Equality 2,90 0,85Health 91,64 25,60
Anti-Personnel Landmines 4,99 8,97
Migration and Asylum 16,28 15,56
Illicit Drugs 1,57 0,00Rehabilitation/Refugees 17,02 21,64Other Programmes 0,45 18,1
Geographical Programmes 73,92 164,00
Asia 19,62 116,93
Latin America 3,55 4,26
Mediterranean 45,49 6,85
Tacis 5,26 35,96
Total General Budget 646,43 633,85
European Development Fund 190,00 281,41
GRAND TOTAL 836,43 915,26ANNEX I
1 NGOs have been actively 
cooperating in the implementation 
of humanitarian aid actions 
since the 1990s. DG ECHO 
has long-term Framework 
Partnership Agreements with a list of NGOs. About 50 % of 
the ECHO funding goes to NGOs 
(about 353 million euro in 2007).
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation40
ANNEX II
MAIN PROVISIONS OF THE COTONOU AGREEMENT 
RELATED TO NSAs
Article 4:
… the parties recognise the complementary role of and potential for 
contributions by non-state actors and local decentralised authorities to the development process. To this end, … non-state actors and local 
decentralised authorities shall, where appropriate:
be informed and involved in consultation on cooperation pol- —
icies and strategies, on priorities for cooperation especially in  areas that concern or directly affect them, and on the political  dialogue;
be provided with financial resources, …, in order to support local  —
development processes;
be involved in the implementation of cooperation project and   —
programmes in areas that concern them or where these actors  
have a comparative advantage;
be provided with capacity-building support in critical areas in   —
order to reinforce the capabilities of these actors, particularly as 
regards organisation and representation, and the establishment 
of consultation mechanisms including channels of communication and dialogue, and to promote strategic alliances.
Article 6: 
1. The actors of cooperation will include:
 — non-state:  (a) private sector;  (b)  economic and social partners, including trade union  
organisations;
  (c)  civil society in all its forms according to national  
characteristics.
2. Recognition by the parties of non-governmental actors shall  
depend on the extent to which they address the needs of the  
population, on their specific competencies and whether they are 
organised and managed democratically and transparently.
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation41
Article 7: Capacity building
The contribution of civil society to development can be enhanced  
by strengthening community organisations and non-profit non-
governmental organisations. This will require:
encouraging and supporting the creation and development of   —
such organisations;
establishing arrangements for involving such organisations in the  —
design, implementation and evaluation of development strategies 
and programmes.
Article 10:
provides that greater involvement of civil society organisations shall 
be associated with this [political] dialogue. 
Article 19: Principles and objectives
1. …
2. … 
3. Governments and non-state actors in each ACP country shall  
initiate consultations on country development strategies and   community support thereto. 
Article 33: Institutional development and capacity building
… Cooperation shall span all areas and sectors of cooperation to  foster the mergence of non-state actors and the development of their capacities; and to strengthen structures for information, dialogue and consultation between them and the national authorities, including 
at regional level.ANNEX II
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation42
Article 57:
… Without prejudice to the provisions above, eligible non-state actors 
may also be responsible for proposing and implementing programmes 
and projects in areas concerning them …
Article 58: Eligibility for financing
… Non-state actors from ACP states and the Community which have a local character shall be eligible for financial support under this  
Agreement, according to the modalities agreed in the national and 
regional indicative programmes.
Article 4 of Annex IV: 
the draft indicative programme shall contain: … the types of non-state actors eligible for funding, in accordance with the criteria laid down by the Council of Ministers, the resources allocated for non-
state actors and the type of activities to be supported, which must 
be not-for-profit; … 
Article 5 of Annex IV: 
… [the joint annual review] shall in particular cover an assessment of: … the use of the resources set aside for non-state actors.ANNEX II
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation43
LIST OF THE PROGRAMMES, PROJECTS AND LOCAL CALLS 
FOR PROPOSALS EXAMINED
LIST OF PROGRAMMES OF NSAs’ CAPACITY-DEVELOPMENT SUPPORT
Domain Project description Country/regionEU contribution 
(Euro)
ALA EU-Andean Community in Action with Andean civil society Andean Community 4 100 000
ALA Small Initiatives by Local Innovative NGOs (SMILING) Bangladesh 8 000 000
EDF Civil Society Fund Ethiopia 10 000 000
EDF Appui et Renforcement des Initiatives des Acteurs 
Non-Etatiques (ARIANE)Mali 7 000 000
South Africa Support to Civil Society Advocacy Programme (CSAP) South Africa 10 000 000
South Africa Foundation for Human Rights in South Africa (FHR) South Africa 25 000 000
EDF Civil Society Capacity Building Programme Uganda 8 000 000
TOTAL AMOUNT 72 100 000
LIST OF NSA PROJECTS
Domain Project description Country/regionEU contribution 
(Euro)
EIDHR Promotion of Human Rights of Indigenous People 
in Bangladesh — NGO: IPDSBangladesh 88 587
ONG Underprivileged Children Preparatory Education Project — 
NGO: Secours catholiqueBangladesh 253 179
ONG Advancing Rural capacity in Haor (ARCH) — NGO: Concern 
World WideBangladesh 471 970
Food Security Food Security Increased through Rights Promotion and 
Sustainable Livelihoods Training (FOSHOL) — NGO: Action AidBangladesh 2 322 170
Food Security Preservation of Farm Resources and Improvement of Food 
Security for the Vulnerable Rural Families of Damot Gale and Kachira Bira — NGO: Inter AideEthiopia 700 000
ONG Woreda Capacity Building — NGO: Farm Africa Ethiopia 1 096 597
Food Security Food Security Capacity Building in Shashogo and Alaba 
Woredas — NGO: LVIAEthiopia 630 500
EIDHR Social Integration of Menja Ethnic Minorities of Chena and 
Gimbo Woredas — NGO: ActionAidEthiopia 90 000
EIDHR Promotion of practices of respect and defence of human 
rights for the reduction of torture and rehabilitation of victims of political violence — NGO: CAPSPeru 94 415
Gender Promotion of the incorporation of women micro-
entrepreneurs and family-based economic units in the formal labour system — NGO: M. Manuela RamosPeru 665 458ANNEX III
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation44
ONG Integration of poor micro-enterprises, with competitive 
potential, into the economic activity of local and regional markets — NGO: Oxfam NovibPeru 1 500 000
ONG Institutional strengthening and promotion of the local 
economy to fi  ght poverty in the department of Junín — 
NGO: Frères des HommesPeru 715 780
ONG Access to social security rights in South 
Africa — NGO: DanChurchSouth Africa 587 820
ONG The Salesian Youth Capacity Building Project — 
NGO: Coop. Mission au DeveloppementSouth Africa 400 000
South Africa Support to Policing of Crimes against Women and Children 
in Eastern Cape — NGO: FAMSASouth Africa 59 204
South Africa Support to Policing of Crimes against Women and Children 
in Eastern Cape — NGO: NICRO — Victim SupportSouth Africa 85 435
TOTAL AMOUNT 9 761 115
LIST OF LOCAL CALLS FOR PROPOSALS
Domain Call for proposals description Country/regionEU contribution 
(Euro)
Food Security Food Security 2003 Call for proposal Bangladesh 4 500 000
EIDHR European Initiative for Democracy and Human Rights (EIDHR) 
Call for proposals — Micro-projects Bangladesh — 2006Bangladesh 525 000
EIDHR 2006 European Initiative for Democracy and Human Rights 
(EIDHR) micro-projects programme for the campaign ‘Promoting the democratic process’Ethiopia 975 000
Food Security 2005 Food Security Programme — Allocation for NGOs Ethiopia 5 000 000
EIDHR 2005 European Initiative for Democracy and Human Rights 
micro-projects programmePeru 575 000
EIDHR 2006 European Initiative for Democracy and Human Rights 
(EIDHR) micro-projects programmePeru 380 000
South Africa Support to Policing of Crimes against Women and Children 
in Eastern CapeSouth Africa 750 000
TOTAL AMOUNT 12 705 000ANNEX III
LIST OF NSA PROJECTS
Domain Project description Country/regionEU contribution 
(Euro)
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation45
DEVELOPMENT COOPERATION ACTORS VISITED ON THE SPOT
Country*State bodies 
(including local 
authorities)NGOs
Other NSAs Other donors
North South
Ethiopia Ministry of Finance 
and Economic Development
Ministry of Capacity 
Building
Water Resource 
Development and Natural Resources Development Offi  ces in Alaba and 
Dale Gale Woredas (Districts)Inter Aid
LVIA
CAFOD/Trocaire
Oxfam GBCISP
German Agro 
ActionAcord
Hundee
Farm Africa Cotonou Task Force
EOC-DIDAC
ARRD-AFM
Woreda (District) 
Development Association in Konso
Derashe Peoples’ 
Development Association
Bedene Irrigation 
Cooperative in Alaba Woreda
Kebele Iddirs in Dale 
Gale WoredaCanada (CIDA)
Sweden (SIDA)
Irish AidUK (DFID)
Bangladesh Comptroller and 
Auditor General
Ministry of Foreign 
Aff airs
Ministry of Finance 
(Economic Relations Division)
NGO Aff  airs BureauActionAid 
Bangladesh
Caritas 
Bangladesh
Concern 
Worldwide
Save the Children 
USBRAC 
Indigenous 
Peoples’ Development Services
Noakhali Rural 
Development Society
Private Rural 
Initiative Programme (PRIP Trust)Federation of NGOs 
in Bangladesh
Defuliapar School 
Management Association
Bhubankura School 
Management Association
East Barahipur 
Farmers’ Group
Ramkrishnopur 
Farmers’ Group
Livestock Services 
Centre EwajsbaliaAustralia (AusAID)
Canada (CIDA)
Netherlands
UK (DFID)UNDP (United 
Nations Development Programme)
World Food 
Programme
* See Annex III  for details of the projects and calls for proposals examined.ANNEX IV
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation46
ANNEX IV
Country*State bodies 
(including local 
authorities)NGOs
Other NSAs Other donors
North South
Peru Regional 
Administration for Work and Employment Promotion Junin
Provincial Council of 
Huancayo
Town Council of 
Tarma
Town Council of 
PalcaOxfam Novib,
Assoc. Frères des 
Hommes
German Agro 
ActionCAPS
Mov. Manuela 
Ramos
IdesiAdec/Atc
Action for the 
ChildrenCopeme
Coremype JuninChamber of 
Commerce Junin
Two women’s 
associations Puente Piedra
Farmers’ association 
Huallquin
Craftmen’s 
Association Huancayo
Shoemakers’ 
Association Huancayo
Community 
Committee  San Juan Lurigancho
Community 
Association PaucamarcaBelgium 
Spain (AECI)UNDP
South Africa Civil Society 
Advocacy Programme (CSAP)
Commission for 
Gender and Equality (CGE)
SA Human Rights 
Commission (SAHRC)
State Policy in Port 
Elizabeth
Ministry of Finance 
(Department for International Cooperation Development)
Ministry of Justice 
(unit in charge of donor coordination) in PretoriaSalesian Centre, 
Cape Town
Black Sash 
National
FAMSA
NICRO
Victim Friendly 
Centre, Port Elizabeth
Foundation for 
Human Rights (FHR)Southern Africa 
AIDS Trust
Africa Institute of 
South Africa
Centre for Police 
Studies
Institute for Security 
Studies
Khulumani Support 
Group
Lawyers for Human 
Rights
South Africa 
Institute for International Aff  airs
SOSTsogang SechabaFrance
Germany
Greece
IrelandNetherlands
UK (DFID)
UN offi   ce on drugs 
and crime
* See Annex III  for details of the projects and calls for proposals examined.
REPLY OF THE 
COMMISSION
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation47
REPLY OF THE COMMISSION
EXECUTIVE SUMMARY
I.
The evolving context rightly recalled by the 
Court should however be considered in all 
its aspects.
There are indeed the evolving approaches  
discussed within the international com-
munity of Donors and to some extend with recipient Governments but there are also tre-
mendous changes in the number and quality 
of NSAs — international and local — present 
in the development playing field (please also 
refer to point 18 below).
The Commission notes that there is no  
agreed definition of the term non govern-
mental organisations and is ready to discuss 
this issue with the European Parliament in 
line with their request (point 19, discharge 
2006).
The different legal frameworks of EDF and  
General Budget deserve to be considered  
also for the provisions concerning the  
 activities to be implemented by NSAs.
III.
A very significant increase in interaction  
between Commission Delegations and local NSAs has occurred since the deconcentra-tion of the relevant programmes and, espe-
cially, the management by Delegations of  local calls for proposals.
Several other factors which influence NSA  
involvement in the development  cooperation process must be mentioned:
differences between geograph- •
ical (budget and EDF) and thematic  
programmes;
partner governments priorities and   •
ownership;
aid effectiveness agenda; •
changes within the NSA world (number,  •
quality and type).
REPLY OF THE 
COMMISSION
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation48
IV.
The selection procedures applied by the  
Commission aim to identify the proposals  that would maximise the overall effective-
ness of the programme through considering, 
in addition to the criteria mentioned by the Court, the feasibility and cost-efficiency of the proposed actions as well as the financial 
and operational capacity of the applicant  
and partners.
The Call for Proposals mechanism results  
in wide publication, transparency, clear  
guidelines and consistent interpretation of 
 procedures and financial rules.
There are a number of the ex post  evalu-
ations and monitoring exercises conducted 
by the Commission, which look also at the 
 sustainability of these actions at project  
level.
V.
As observed by the Court, the issue of NSA 
engagement is treated in different ways  
under the Cotonou Agreement compared to 
the Regulations applicable to non-ACP coun-
tries. This also extends to the availability of 
funding for in-country capacity-building of NSAs. And thus funding for capacity-building 
of NSAs in non-ACP countries is essentially limited to the thematic programme.
Within these limitations, significant work  
has been initiated to bring forward in a  
more systematic manner the interaction  
with NSAs, and an assessment exercise was 
undertaken by HQs with regard to engage-ment with NSAs (report provided to the  Court).VI.
Despite the fact that former ALA regulation 
didn’t formally envisage capacity building  support to NSAs, various studies and pro-
grammes are being carried out in this issue 
in both Latin America & Asia.
A significant number of projects/
programmes in Asia and Central Asia which 
are/will be implemented through non-governmental organisation have been  
adopted in 2007 and 2008. While their pri-
mary objective is to contribute to poverty  
eradication, improvement of access to social 
services and improvement of governance and rule of law, they support non state actors in pursuance of these goals.
VII.
The Commission is strengthening the  
involvement of NSAs by:
better knowledge management through  •
PADOR and better dissemination of  
knowledge through CISOCH;
launching of pilot mapping studies   •
designed, if possible, in close  cooperation 
with government;
improving predictability and trans- •
parency related to the consultation  process.
The Commission will continue with the simpli-fication of calls for proposal, shortening the procedure and promoting  implementation  at local level.
REPLY OF THE 
COMMISSION
Special Report No 4/2009 — The Commission’s management of non-state actors’ involvement in EC Development Cooperation49
The Commission believes that the control  
system in place ensure a sound financial and 
contractual monitoring.
Delegation and NSA staff will continue to be 
trained, including on the use of performance 
indicators.
A mix of instruments is being considered in 
view of the regulatory framework created by 
the Financial Regulations, EDF, DCI, EIHDR  
and ENPI.
Capacity development should preferably  
be channelled through geographic pro-
grammes, the principle of alignment of aid 
requires that partner country governments 
define strategies, sectors and themes within 
this context. The Commission will continue to promote the involvement of NSAs.
More and more interaction is structurally  
organised between different instruments  
and programmes to allow a better comple-mentarity with activities supported by the 
bilateral, thematic and regional contexts.  In addition, the Commission participates  actively in the donors’ coordination mech-anisms. The Commission is of the opinion  that other channels such as the extension of 
the sub-granting must be considered.INTRODUCTION
2.The Commission notes that there is no  
agreed definition of the term non govern-
mental organisations and is ready to discuss this issue with the European Parliament in line with their request (point 19, discharge 
2006).
5.
Please refer to reply to paragraph 52.
AUDIT SCOPE AND APPROACH
OBSERVATIONS
18.
Since its early days the Commission has been 
championing the role of NSAs in develop-
ment and has developed supporting policies and financing activities for facilitating their 
involvement. Reference texts such as com-
munications and guidelines highlighted by 
the Court are a clear demonstration of this 
importance.
The ‘European Consensus on Development’ 
rightly recalled by the Court should, how-ever, be considered in all its aspects.
There are, indeed, evolving approaches  
(alignment to partner governments prior-ities, ownership, harmonisation …) but there 
are also tremendous changes in the number 
and quality of NSAs — international and  
local — present in the development field.
This evolution is paramount to understand 
the possibilities and limits of NSA involve-ment in the development cooperation  process.
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Moreover methods are sharply different  
when dealing within a bilateral context from methods of works applied within thematic  
programs.
21.
Although not legally obliged, the Commis-sion confirms that as far as possible it has  always tried to consult with NSAs, this was a political objective where local conditions were conducive to such consultations.
There has been increased consultation effort 
with civil society undertaken by the EC in  the course of the 2007–13 programming  
exercise compared with previous exercises. 
Furthermore, the need for close consultation 
of civil society has been reiterated in the  
guidelines for the mid-term review of the  
2007–13 Strategy Papers.
At the time of the preparation of the 2002–06 
CSP, there was no general legal obligation 
for programming in Asia and Latin America 
to involve NSAs and devolution was at its  
beginning. The Delegations visited by the  Court were devolved in the three different 
waves (1
st South Africa and Mali, 2nd Ethiopia 
and Peru, and third Bangladesh) and thus  for some of them, the preparation of the  CSP was essentially carried out under the  
responsibility of HQ.
See also reply to paragraph 22.22.
The level of involvement of the various  
stakeholders in the programming process  in heavily dependent on the specific situ-
ation of every country and the applicable  
legal framework of cooperation. Within the bilateral cooperation and accordingly with the conclusions of the Paris Declaration  
and of the European Consensus, when even 
possible the partner governments should  be the in driving seat and this should more 
and more be up to them to organise the  
consultations of the various stakeholders.  
The Commission is obviously supporting any 
consulting process but final priorities and  objectives have to be owned by the partner 
country and not imposed.
The NSAs consultation process followed for 
the preparation of the Peru CSP represented 
the first attempt at a structured approach, 
at a time when, under the then-prevailing  AL Regulation, no consultation was formally 
required. This approach will be built upon  
in future programming exercises.
23.
Guidelines are orientation papers. They  have to be implemented when possible in a pragmatic manner taking into account the  specific context.
24.
The situations of ACP and DCI countries are not comparable as the political and legal  
framework contexts are very different. There is on the one hand a mutual agreement of all ACP and EU countries for matters concerning the involvement of NSAs and on the other  
hand a DCI regulation decided by EU only.
25.
This is in line with the legal basis and  
requirement in force at the time.
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26.
The Commission agrees and would like to  
emphasise these essential considerations  should be borne in mind throughout the  
report:
The Commission signals in particular that  —
despite the difficulties for NSA involve-ment Delegations have systematically  made efforts to engage on dialogue with NSAs.
These difficulties are all inherent weak- —
nesses of the NSAs community, which  
is not a homogeneous bloc, and lacks  organisation and representativeness.  
These factors — coupled with national  
legislative and regulatory issues in the 
partner countries are another major  
stumbling block precluding the involve-
ment of the NSA community ‘as one’ into 
the EC’s development cooperation.
27.See replies to paragraphs 24–26
The Guatemala example illustrates the dif-
ficulties in, and need for, establishing a def-inition of the legal limitations of a sustained consultation process with civil society.
28.
Translating the ambitious goals of involv-
ing NSAs in the development cooperation  is a major challenge. This is however to be 
understood as a major ‘political challenge’ 
much more that a commitment to ensure the 
involvement of each and every NSA from a specific country.
The Commission would like to stress that as 
far as NSAs are concerned, there is no one 
size fits all for training as the NSAs ‘architec-ture’ varies immensely between countries.Since 2004/05 EuropeAid has provided  
tailor-made upstream guidance during the instruction phase of NSAs programmes, and 
downstream during implementation. Dele-
gations are also provided with operational guidance: firstly through its intranet where guidelines and good practices are posted;  
secondly through regional seminars where 
knowledge about commitment in dialoguing with NSAs and exchanges with colleagues  
are enhanced and finally through studies.
In addition, EuropeAid organised in 2008 var-
ious seminars designed to provide training to Delegations and CSOs on thematic opera-
tions management and CSO  consultations  
(total cost EUR 900 000):
EC internal trainings — : three seminars  
(Brussels, Tbilisi and Addis Ababa)  
gathering in total 185 representatives  of almost 70 Delegations + four train-
ing sessions organised in Brussels  
(120  representatives of Delegations and 
HQ)
EC trainings for SCO —  (open to represent-
atives of European & local SCO): three  regional seminars (Porto  Alegre, Yaoundé, Manila) gathering 49 representatives of 28 Delegations and 193  representatives of European & local SCOs.
These events enabled both HQ and Delega-tions to revive the ‘civil society focal points 
network’ used to disseminate  methodological 
tools in-house.
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In 2009, in addition to the organisation of  
five other Regional seminars, EuropeAid will make operational the Civil Society Helpdesk 
(CISOCH) established at the end of 2008 and 
intend to develop an online tool that will  strengthen both coordination of the differ-ent services of the Commission and dis sem-
in ation of ‘best practices’ as far as NSAs are 
concerned.
29.
NSA involvement in aid effectiveness was  
not on the international political agenda  
when the guidelines were drafted in 2004. Taking stock of the impact of this recent evo-
lution on civil society and on the practice of 
the Commission, EuropeAid has developed 
a draft guidance document on the issue of 
civil society participation in new aid modal-
ities, including general budget support and 
sector programmes implemented through  budgetary aid (see point 74 where the Court 
also takes stock of this evolution).
31.
The consultation process is very heavy and time-consuming. In order to respect dead-
lines and a centralised and accessible tech-nical tool has to be put in place, in order to provide a quick and common access to the same ‘space’ of discussion.
The ‘Civil Society Helpdesk (CISOCH)’, under 
the form of a documental database (‘wiki’), 
will provide part of the solution.
33.
See replies to paragraphs 21 and 69.34.
This is indeed the result of the late legal  
adoption of the regulation which will not  occur again on condition the partner coun-
tries are willing to actively take part in this 
process.
After the Court’s audit, most of the Delega-
tions (including Peru) consulted NSAs, and 
this procedure will continue for next years.
35.
The fundamental purpose was to secure the 
widest possible coverage of countries under 
the thematic programme.
In addition see also replies to paragraphs:  
21, 22, 31, 84 and 85.
38.
As of 1.1.2003 the Financial Regulations  
require by default the use of ‘call for pro-posals’ to award grant contracts. The insuf-
ficiency of the available budget is on the  
one hand a sign of its success and on the  
other hand unavoidable in term of scarce  
financial resources for external aid. With  reference to the old NGO co-financing  
programme and at the explicit request of  the European Parliament had to stepup  the inclusiveness character and foster the  NGOs’ right of initiative and thus could not have a more focused approach (see reply  
to paragraph 35). We could concur that the detailed procedures are cumbersome but  
we are obliged to respect the compulsory  
regulatory framework to foster sound finan-
cial management. Although there is no clear definition of a ‘small NGO’ the existing data shows that NGOs of all different sizes par-ticipate in the Calls of proposals in an appli-cants (leader) capacity or partner capacity. 
This is all the more true as from 2006 with the introduction of the Concept Notes there 
has been a decrease in the proposal submis-
sion  requirements at the first stage of the  
procedure.
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39.
The deadlines are imposed by the regulatory 
framework and although within the allowed margin for flexibility, important improve-
ments have been made. While the projects 
audited by the Court relate to a previous  period, the current average delay between the submission of proposals and the actual 
signing of contracts is now much less than 
a year.
It is hereby also reminded that the existing 
regulatory framework for publicising Call for 
proposals, concern the legal minima; hence 
creative imagination of operational actors  can be useful for additional means for pub-
licity. Accordingly, in addition to the legal 
requirements, information on the Call for  
Proposals is normally channelled through  
bulletins or other means by NGOs platforms. 
In addition, for more than a year Europe-
Aid has been systematically sending e-mails to umbrella organisations for information  
 dissemination purposes.
Reaching local NSAs at grass-roots level  
remains a major challenge. Local Calls for  Proposals published by Delegation since  
2007 will help meet this challenge.
However, the Commission, although it is  
adapting its tools to ensure the enforcement of the publicity requirements, states that  there are limits to its possibility to reach  all NSAs at grass-roots level for its services and is wondering if this is the Commission’s role.40.
The Commission welcomes the positive appre-
ciation of the Court regarding the measures taken in view of improving the efficiency of 
the Call for Proposals procedures.
Experience shows that this new method (a) 
has generally obtained good results (see point 39). Indeed, the restricted pro-ced ure already simplifies the selection  procedure.
This system provides a longer and more (b) 
manageable time frame for all parties.  
This increases the possibility of foresee-ing our actions both for the Commission 
internal use of resources as well as for  
the NSAs in order to plan their strategy 
and investments for the submission.
PADOR (Potential Applicant Data Online (c) 
Registration) simplifies and decreases  the selection time process.
Indeed, the possibility of adapting calls (d) 
for proposals increases the efficiency of 
the process in selecting relevant NSAs, as demonstrated by the first experiences 
in local calls for proposals.
41.In selecting proposals, evaluators carefully check the presence of some elements of  
the logframe approach in the full applica-tion (preparatory, stakeholders and prob-
lems analysis as well as the analysis of the 
objectives and strategies of the project  
proposal).
For certain types of project, carrying out  
diagnostic identification of beneficiaries or studies can be an inherent part of the project itself: aiming for instance at em powering  grass-roots organisations and improving  ownership.
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The Commission would like to note that  
this project was monitored in 2007, by an  external independent evaluator, as part of 
the results-oriented monitoring exercise,  
obtaining different conclusions about the  ‘project design’.
The project was qualified as highly relevant 
and with a good quality design (b = good). Also the potential sustainability is qualified 
as A (= very good); the alliance with Minis-
try of Labour and Employment is mentioned 
as one of the major achievements of the  
project, at the same time as a real closeness with the local and regional authorities.
The ROM exercise is one of the most useful 
working instruments for Delegations moni-
toring follow-up tasks. In addition, there was 
a monitoring of the project in 2006, at the 
beginning of the action.
42.
The Commission makes sure that CONCORD 
readers are published on the EuropeAid  
intranet page and it has been addressed to 
all Sub-delegated Authorising Officers by  
separate note.
43.
The Commission attaches the highest atten-tion to continuously improve its control sys-tems and has introduced over the past years numerous measures to further re inforce  them, among which the new terms of ref-erence for mandatory expenditure verifica-tions for grant contracts (February 2006)  and for audits launched by the Commission (October 2007).44.
The different viewpoints of representative of 
the NSAs and Delegations should be analysed in view of the different roles. Considerations 
concerning the management of the Delega-
tion’s staff turnover in a devolved context are independent from NSAs but are closely monitored by the Commission to ensure  
continuity of service and maintenance of  
level of quality. However, the ‘zero growth in staff’ policy combined with the increase 
of funds and the new opening of Delegations 
is creating organisational stress.
EuropeAid arranges training courses in  
 Brussels for staff (basic level as well as  
advanced) on grants procedures every  
quarter. Training and workshops are also  
regularly given at regional seminars (Brus-
sels and in-country). An e-learning course  
(basic level) is being developed during 2009 
so that more staff in delegations can have  access to training. EuropeAid has recently  
published FAQs on the intranet, which also 
covers grants. There are plans to hold joint 
seminars with Concord members (train the 
trainers), information days are organised on the occasion of many Calls for proposals.
45.
The geographic programmes usually provide specific capacity to NSAs on implementa-tion rules in the framework of a more global 
capacity-building strategy. Capacity build-ing on these issues is therefore more regular 
and built on a longer-term vision.
As far as trainings is concerned, please refer 
to point 28 (Seminars and CISOCH — Civil  Society Helpdesk).
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46.
The Commission considers that the non-
legally-binding nature of the Reader is not necessarily the reason it is not used. The  
Commission publishes the CONCORD Read-
ers on the EuropeAid intranet page and they have been communicated to all Sub-dele-gated Authorising Officers.
Nevertheless, it is obvious that assessment 
of factual findings and decisions in individ-ual cases remain the responsibility of the  responsible authorising officer.
The Commission is also developing new tools 
which aim to provide a one-stop shop for  
the Frequently Asked Questions and other  
information needs (CISOCH).
47.
Communications have always been provided 
in a timely manner and as appropriate and in most cases, the modifications have been 
implemented to address the request made 
by NSAs via CONCORD.
The Practical Guide (PRAG) has to be adapted 
whenever the legislator proceeds to modi-fications of the legal bases (budget/EDF),  or of the financial legal framework (FR & IR) (e.g. autonomous IR revision of 08/06, 2007 new legal bases, 2007 revised FR & IR, 2008 
new Annex IV EDF).
Any modifications are thoroughly dis sem-
in ated and always made public through  
the Internet (also through important mes-
sages, technical fiches, and modifications  listings).
Nevertheless, even in the case of those up-
dates of the PRAG, on the basis of the princi-
ple pacta sunt servanda , concluded contracts 
(and the attached applicable General Con-
ditions thereof) go on applying as initially 
agreed and their interpretation respects the 
rules applicable when concluded.New rules have systematically been pre-
sented to and clarified with CONCORD, e.g. in the context of the elaboration of Readers.
In some cases, upon request of the NSAs, the 
Commission has authorised the application of more flexible rules when they were not  automatically applicable retroactively (e.g. 
note 22238 of 16.8.2005 on exchange rate  reference).
48.
In its Annual Reports, the Court has noticed 
improvements in the audit system due to  recent measures introduced by the Commis-
sion. At the same time, most of the audit  
reports reviewed by the Court in the frame-
work of the DAS 2007 were linked to con-
tracts signed before February 2006. As a  
consequence, the new Terms of Reference  
set up by EuropeAid for expenditure verifica-tions of grant contracts and put into force for 
new contracts signed as from this date  were 
not applicable in the cases analysed. The aim 
of these new Terms of Reference is precisely 
to detect errors such as the ones mentioned by the Court. The Commission expects that 
the effects of these  improvements become more and more visible.
49.
The new terms of reference for external  
‘financial audits’ (i.e. agreed upon pro ced-ure of expenditure verification) launched  
by the beneficiaries in compliance with the 
requirements of their EC grant are in force 
for all new standard contracts signed as  from February 2006 (as stated above under point 48). The new terms of reference for  the audits launched by the Commission  were applicable from October 2007. While  
the use of the former depends on the date of signature of the contract, the latter were 
immediately applicable.
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50.
(a)Responsible Authorising Officer — Current legal bases no longer allow for such misun-derstandings since the legal environment  with regards to rules of origin is now more settled and user friendly. Annex A2 of the  Practical Guide lists in a user friendly man-ner all countries eligible under each legal  base.
(b)
The applicable rules are contained in the  legal bases and transposed to standard  Financing Agreements (when applicable).
DCI and EIHDR Regulations forbid the finan-
cing of local taxes by EU funds and thus in 
the framework of the mid-term review of the 
legal bases, the Commission is proposing a 
draft providing for more flexibility on the  
issue of taxes.
Furthermore Delegations services try to  
assist locally in the area of tax exemption  
by taking appropriate measures vis-à-vis the beneficiary country, whenever allowed by  
the local legal framework (e.g. their NSAs  
status often doesn’t allow the exemption  
procedure).
(c)
The exchange rate system by its nature is  
likely to produce exchange losses or gains. The special nature of the grant contract and 
the need for a reliable and accessible source of exchange rate reference when a reference is set in the contract.
For the Commission, the administrative  
burden related to the practical application and the calculation in cases where the grant 
bene fi ciar ies use such exchange rate sys-tems are minor in comparison to the clarity, transparency and fraud-preventing effect  provided by such a system.(d)
The approval of the interim payment is  subject to the analysis and approval of  reports and/or documents as required by  the  Financial Regulations.
(e)
On the one hand there has been harmonisa-
tion of financial and contractual procedures; 
on the other hand there is the discretional judgement of the responsible Authorising  
Officer for sound financial management.
In particular:
for the additional periodic reports or audit reports, the specific environment of project-management that may require more frequent or in-depth information; for the use of sepa-
rate specific bank accounts (very appreci-
ated to ease tasks of funds-tracking in case 
of audit and to identify interest pertaining 
to the EC), the relevant general conditions enable the beneficiary to have an account or 
sub-account which identifies the funds paid 
by the Contracting Authority and allows the 
calculation of the interests yielded on such funds. If payment options differ from the  
standards foreseen by the General Condi-
tions, the specific working environment or 
specific project may require a reduction of 
the pre-financed funds by the responsible  
Authorising Officer for a better risk-control 
and sound financial management. In fact,  
the responsible Authorising Officer may  be obliged to reduce the amounts of the  
pre-financing payments and/or to obtain  further information/clarification prior to  authorising them as foreseen by the  general 
conditions.
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52.
Work is underway to improve the:
quality of data in CRIS with data   —
 dictionary and data flow;
quality and number of reports, lists and  —
statistics through the DataWareHouse  
tool.
New modules are being introduced to   complete CRIS:
PADOR and administrative data in order  —
to know better our partners and to get a more ‘horizontal’ approach;
Audit module; —
Prospect module: online registration of  —
proposals, evaluation and follow up;
Publication: online access of all calls   —
launched by EuropeAid.
In 2008, the Commission published the list of final beneficiaries for 2007 and this will 
continue.
53.
Project follow-up is being strengthened via 
training and guidance; standard format for 
reports are available in the contract. Infor-
mation in the reports are completed with  other sources of information such as ROM  
reports and field visits.
54.
In the Commission’s view, the Logframe  
approach is a very important part of the  
majority of the projects.However, the quantification of results is a  
costly mechanism often disproportionate for the small-scale projects.
55.
Performance indicators have been the sub-ject of many studies carried out not only by the Commission but also by various NSAs,  research centres, international organisa-
tions and other donors and it is very diffi-
cult to define them in a consensual way and 
to perform a generally-recognised bench-marking.
However, for some very specific domains,  
benchmarking might be possible. During its quality check of programmes and projects, EuropeAid assesses the relevance of the  
quantitative and qualitative indicators  
contained in the logframes of NSAs’ pro-
grammes. A list of quantitative and quali-tative indicators has been posted on the  
Intranet in order to guide Delegations when 
drafting or checking Logframes.
56.
Many support and control activities are car-
ried out by HQ and the Delegations
1, among 
which field visits. All these mechanisms  
represent important elements in the whole 
control and support process of the projects 
implemented by NGOs/NSAs.
Field visits have to be considered in their  
interaction with the other monitoring and  control activities as well as in the context  of the availability of the human resources, 
keeping in mind the huge number and var-
iety of organisations of the civil society with 
which EuropeAid works.
1 These include, among other things, checks on the 
internal management capacities of the implementing 
partners prior to signing the contracts, [development of a series of standardised guides and manuals to be used 
by these partner/s], ex ante and/or ex post checks on 
the transactions carried out by them, regular monitoring 
missions and field visits, expenditure verifications by 
external auditors before making the final payment, training sessions and replies to any request for advice or 
information.
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57.
Delegation staff are available to answer the questions local organisations may have with regard to the rules in force when contracting with the EC. Manuals and training material are also available to Delegation staff.
On-the-spot visits by staff delegations can 
improve the situation. However, specific  
controls, like financial or system audits, are established to efficiently deal with financial, 
accounting and expenditure documentation 
issues.
58.
Guidelines for project internal monitoring  were drafted, published and disseminated  to the delegations in December 2007.
59.
The ROM methodology, which is one of the 
elements of the control system, includes  sampling of the devolved projects as well  
as sampling of the centrally managed ones, 
often of higher contractual amount.
Annual ROM monitoring missions always  
include NSA projects. The list of projects  
to be monitored is agreed consensually  
between EuropeAid, the Delegation and the 
ROM monitors.
EuropeAid is working to strengthen its moni-
toring methodology and is consulting other donors on the possibility of establishing a 
joint monitoring methodology based on the Accra and Paris declarations.60.
There are ToRs for evaluations available on the EuropeAid website and they provide  guidance for intermediate, final and ex post  
evaluations. The Commission asks services to 
respect the structure of the document. The Commission reminds that for evaluations  the decisive element must be the quality  
and professionalism of the entity recruited 
for the task. The latter ensures objective  evaluations.
61.
The  impact is one of the five DAC criteria  
definitely corresponding to EC require-ments for evaluation of projects and pro-grammes. Moreover, the impact is taken  into consideration during the monitoring  
of EC operations. EuropeAid has developed 
a methodology for ex post  ROM that aims to 
measure the impact and sustainability of all 
EC-funded projects.
Indeed, thematic projects are normally much 
smaller scale and sometimes the means of  
verification (baseline data and ex post  data) 
are too costly in comparison to the cost of the action itself. However, with reference to 
EIHDR for instance, evaluations carried out 
at present often cover a group of projects  
and always try to include recommendations 
per project, even when they are ex post , as 
they can be used as lessons learnt for future 
actions.
62
On guidance on Logframe and performance indicators, please refer to points 54 and  55.
63.
The Commission agrees with the fact that  
sustainability has to be checked ex ante and ex post. As a result, ex post  ROM are car-
ried out two years after the completion of  projects. (Please refer also 64 & 65).
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A qualitative study based on projects moni-
tored by ROM has been realised in 2008 iden-tifying 17 fundamental aspects for project  performance. It will be published in 2009.
64.
Even if sustainability of projects is essential, 
the Commission acknowledges that some  
local and grass-roots NSAs do not always  have the capacity to ensure this sustain-
ablity. The Commission underlines the need 
to ensure, at the same time, the sus tain abil-ity of our projects and the main objective to strengthen local NSAs. For this reason the  Commission is encouraging genuine part-nerships between European (rather strong) NSAs & local (rather weak) actors.
65.
A real advantage of international NGOs is  
their diversification of funding. However, a possible way of correcting this situation is to 
encourage real partnerships between strong 
(international) NGO and rather weak (local) 
NGOs. In EuropeAid Calls for Proposals pro-cedure, is a possibility for applicants to elab-
orate ‘consortiums’ involving a leader and  
partners organisations. NSAs (international 
ones especially) should be able and willing 
to favour transfer of knowledge between  
themselves.
66.
The Financial Regulations impose the Call  for Proposals mechanism for action grants  while limiting to one year the operating  grants: long-term commitment and fund-ing against the regulatory framework. That said, the project duration has no time limits imposed by the Financial Regulations.67.
A matrix of tools is used on the basis of  the possibilities offered by the regulatory  and operational framework while project  approach remains the most used with  NSAs.
Flexibility is required as regards implemen-
tation periods. This is the case for human  
rights promotion where short-term projects can contribute to structural changes.
68.
The evaluation process used by the Commis-sion should ensure that selected projects are well designed. However, to a certain extent, and, in some specific contexts, short projects might not be always sustainable. It is the  reason why EuropeAid through increased  
knowledge of the partners via PADOR is  
complementing the project-approach with 
partner-approach.
69.
The issue of NSA engagement is treated in 
different ways under the Cotonou Agree-ment compared to the Regulations applic-
able to non-ACP countries. This also extends 
to the availability of funding for in-country 
capacity building of NSAs. Thus funding for 
capacity building of NSAs in non-ACP coun-
tries is essentially limited to the thematic  
programme.
Within these limitations, significant work  
has been initiated to bring forward in a  more systematic manner the interaction with NSAs, and a assessment exercise was under-
taken by HQs with regard to engagement  
with NSAs (report provided to the Court).
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70.
The Commission agrees with the fact the  regional and national strategies to support NSAs should be carried out. The evaluation recently conducted on ‘Civil society as a  channel for aid delivery’ has led to a similar conclusion. Along this line, several stud-ies and regional seminars (Central America, Eastern and Southern Neighbourhood, East-ern Africa and Central Asia) to be conducted in 2009 on civil society will put a specific  emphasis on this issue, in a period where  the mid-term review of instruments and   programmes will be conducted.
However, the setting up of specific strat-
egies for each country (mapping) are con-ditioned by the budget & human resources available.
72.
Despite the fact that former ALA regulation didn’t formally envisage capacity building  
support to NSAs, various studies and pro-
grammes are being carried out on this issue 
in both Latin America & Asia.
Asia: several projects/programmes in Asia  
and Central Asia which are/will be imple-
mented through non-governmental or gan-
isa tion have been adopted in 2007 and 2008. 
While their primary objective is to contrib-
ute to poverty eradication, improvement of 
access to social services and improvement of governance and rule of law, they support 
non-state actors in pursuance of these goals. This is the case notably in Afghanistan,  China, Pakistan, Kyrgyzstan and Tajikistan.Latin America: EuropeAid services have  
recently sensitised all Delegations in Latin America about the importance of mappings. In addition, a methodological note will be  produced on how to feed dialogue and  co operation through geographic or thematic instruments.
ACP: a recent study has been launched to  
introduce more light into this issue also  
for the EDF (Etude de capitalisation des  
programmes d’appui au renforcement des  capacités des acteurs non-etatiques sous le 9
e FED).
73.
It is not possible to fully achieve the main 
objectives of the DCI in two years time. How-
ever, as explained above (72), various pro-
grammes supporting NSAs are, indeed, being 
implemented in some ALA countries. This is because the funding of NSA capacity build-
ing under the geographical programmes of 
the DCI is only possible if it is identified — 
as a result of the dialogue with the partner country — as a priority sector for the EC  
cooperation programme.
74.
As mentioned before, EuropeAid services  
have prepared a draft document on the issue 
of participation of civil society in new aid  
modalities. This document contains oper-ational recommendations about the entry  
points for the involvement of civil society  in macroeconomic and sector programmes, the instruments to be used according to the 
context in which the programme will operate 
and the type of capacity building required 
for civil society to effectively participate.  This document will be further developed in 
2009. This second phase will aim at refining the methodology proposed and at providing good operational practices.
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77.
The necessity of elaborating a mapping  largely depends on the context in the coun-try concerned. In the case of Bangladesh  for instance, given the number of NSAs in   Bangladesh formal mapping is not possible but the Delegation has good knowledge of the local NSAs and their capacity.
78.
Beside the time frame determined by the  
regulatory framework and the building of  
the project social structure, increased atten-tion is, and will be, provided to timely pro-cedural management. The Commission can continue its efforts in training and guidance but only for the steps under its control.
79.
Implementation of the actions can always be 
extended before its conclusion if necessary. 
For certain sensitive situations, extension of the implementation duration is necessary  
and possible for the sound financial man-
agement of the project. The effect of de-
commitment of funds in the General Budget and the EDF is not the same.
80.
It is important to remember that the or gan-
isa tions applying for a Call for proposals  
must also be able to implement the opera-
tional and financial components of the con-
tract that could be subsequently awarded.Accordingly, in order to guarantee the  
financial interests of the institution the  Evalu ation Committees must consider the  financial and operational capacity of the  applicants and partners in relation to the  size, scope and budget of the proposed  action. The possibilities given by the Calls for Proposals launched in the context of  the new Co operation Instruments to sub-mit project proposals for amounts as low as EUR 20 000 have increased the possibilities of small rural-based organisations to partici-pate successfully in the respective calls.
Reaching rural-based organisations is a very 
difficult task, and has been achieved by a  number of Delegations through decentral-ised information sessions or publications  
on websites, newspapers, etc. It is true that 
calls for proposals are ill-suited to small and 
grass-roots organisations but the procedure is compulsory under the present Financial  
Regulation. Moreover, there are also limits to 
the need and the capacity of the  Commission 
to reach such entities.
Currently, the existing but very limited pos-
sibilities for sub-granting make it possible to 
reach some of these grass-roots-level organ-
isations and also to contribute to capacity 
building.
This difficulty has been matched in geo-
graphic programmes where calls for pro-posals are normally part of a more global  capacity-building strategy. However the  Commission is of the opinion that other  channels such as the extension of the sub-granting as proposed by the report of the  Court of Auditors must be considered.
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81.
Communications and guidelines for staff  
mentioned by the Court contain political  objectives not commitments. Neverthe-less, through the launching of local call for 
proposals and of new waves of capacity-
building programmes in the context of geo-graphical programmes, good progress has  
already been achieved in favour of a better 
 involvement of local NSAs.
Local organisations need time to get familiar 
with the new geographic programmes and procedures, thereby avoiding errors and mis-understandings. Improvement is also linked 
to the enlarged new tasks of  Delegations  
within the new instruments.
The Commission questions whether it can  
effectively involve the majority of grass-
roots and community-based organisations, 
even if this would be relevant to the develop-
ment cooperation process. The Commission should insist that partner country govern-
ments play the leading role in promoting  
NSAs’ active involvement in development  
issues.
83.
(a)
The new backbone strategy of EuropeAid on ‘Reforming cooperation Technical Coopera-
tion and Project Implementation Units’ pro-motes a better differentiation, in the design of technical cooperation, between manage-
ment tasks and the provision of thematic  
expertise which calls for different types  
of experts’ profiles. More attention is thus drawn to the quality of the latter.
(b)
See replies to paragraphs 63 to 68.CONCLUSIONS AND 
RECOMMENDATIONS
84.
The Commission agrees with the principle  
that NSAs must be fully involved in the  development cooperation process, but this level of involvement differs according to  
the various legal bases considered. In the  
framework of the Cotonou Agreement, the need for consultations is agreed and legally 
binding both for the Commission and Part-
ner States. For DCI countries, the Commis-sion applies an EU regulation: EU efforts to consult effectively NSAs have to be matched by the willingness of national authorities to do so.
Furthermore, in the Commission’s view,  
these texts should also however be framed 
within new realities such as alignment to  
partners’ governments, and ownership. EC  action in support to NSAs takes indeed into 
account the dual reality of supporting the  
right of initiative of Civil society organisa-
tions and the rising need of ensuring ‘align-ment’ to partners governments priorities.
See also response to paragraphs 24 to 26.85.
In the programming phase of the new  
NSA&LA program, the EC duly consulted  
Dele gations via concept notes. Two main  correlated factors explain the limited south-
ern NSAs consultations:
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the new ‘opening’ towards southern NSAs  •
certainly requested a quick adaptation  from Delegations (who had to deal with a new kind of stakeholder) but mainly  
from the local NSAs themselves;
delays in the approval of the DCI not   •
of the Commission’s responsibility pre-
vented the organisation of genuine and relevant consultations in Delegations  during its first year of application.
In the very near future (in the framework  of the mid-term review & upcoming local  
calls for proposals), the Commission will do 
its best to improve consultations. The Com-
mission however, would like to stress that  
it is hardly feasible to reach all the local  stakeholders. We should, for instance, rec-
ognise that the Commission cannot ef fect-
ive ly involve the majority of grass-roots and 
community-based organisations, even if they would be very relevant to the development 
cooperation process.
Recommendations on involvement 
of NSAs
The Commission reiterates that the inclusion 
of NSAs is one of the main cornerstones of its 
action. However, this involvement has to be balanced with the cooperation with sover-
eign States. NSAs inclusion will be strongly supported, but cannot be imposed, by the  Commission.In the near future, the Commission will  
strengthen the involvement of NSAs by:
improving its knowledge of relevant   •
NSAs through the launching of pilot  
mapping studies designed, if possible,  in close cooperation with government  
(national authorities should remain  
the main stakeholders in charge of  the  elaboration of such socio-political  mapping);
improving predictability and transpar- •
ency related to the consultation pro-
cess by elaborating, as often as possible, 
specific calendars and communication  
material to facilitate the interaction with 
NSAs.
The Commission intends also to improve  guidance for Delegation staff with the launch-ing of a Civil Society Helpdesk  (CISOCH): an online capitalisation and dissemination tool designed to provide Commission services  
(Delegations and Headquarters) and NSAs  
with clear and coherent information on and 
for civil society. In addition, please refer  
also to point 28 related to specific guidance, 
seminars and training planned.
86.
The Commission acknowledges that, espe-cially for local NSAs, calls for proposals may be cumbersome. However, this procedure  
is under the present regulation the only  
legal possible system and is compulsory to 
be used for the award of grant contract. It is needed to ensure both the sound man-
agement of operations and the equality of  treatment between candidates.
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In order to reach local organisations more  
easily the Commission has simplified this  procedure, it has also introduced the PADOR 
database which is contributing to a reduc-
tion in the delays between the launch of  calls and the signature of the contracts.
87.
The Commission is doing its best on train-ing and specific guidance. Furthermore, the 
Commission will ensure the optimum dis-
semination of practical tools which have  
been made available to the Delegations. In 
addition, with the launch of the Civil Society Helpdesk (using an interactive Web tool),  
the Commission will provide stakeholders  
with a user-friendly synthesis of its legal and 
financial instruments. (See paragraphs 28,  
31 and 46).
88.
In the last few years, the Commission  
devolved the responsibilities of project  
implementation to Delegations in order to 
ensure improved monitoring and evaluation 
capacity in country. Moreover, the Com-mission is the only donor to complement  
its internal monitoring capacity through  seven regional external results oriented  monitoring contractors.
In order to further improve implementation 
and monitoring, the Commission has taken the initiative of consulting other donors on 
the development of a joint monitoring sys-
tem based on the Paris Declaration and the 
Accra Agenda.
Evaluation is a standard feature for all  
projects/programs. The EC is also develop-ing an IT database for its project evaluation to enhance the dissemination of lessons  learnt and best practices for improved   implementation and future project design.89.
As stated in point 64, the Commission agrees 
that sustainability of projects is essential  and acknowledges the complexity involved 
in ensuring simultaneously the sustainabil-
ity of actions funded and the strengthen-ing of local NSAs. Integrated and long-term approaches are being implemented through 
geographic programs designed in close col-
laboration with the partner state (especially in the framework of the Cotonou agree-
ment). As far as thematic programmes and 
instruments are concerned, the Commission 
would like to underline their specific added 
value. Thematic operations have been cre-ated and supported by the European Parlia-
ment in order to:
enable the EU to operate even in case of  •
very difficult partnerships;
address a specific issue worldwide   •
as opposed to a regional or national  
concern.
This illustrates the willingness of the EU to 
spread its common political/strategic  values around the world (protection of human  
rights, protection of environment etc).
The Commission will continue with the  —
new practice of call for proposals at local level. It will also extend the use of PADOR as a knowledge management tool.
In order to improve accessibility, coher- —
ence, transparency and standardisation 
of procedures, a tool called ‘CISOCH’  is being developed to ensure a better  guidance and support Additional Human Resources for the Delegations would be necessary if the control system is to be 
modified and based on the on-the-spot visits by Commission staff.
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The Commission believes that the control  
system in place ensure a sound financial and contractual monitoring.
Delegation and NSA staff will continue to  
be trained, including on the use of perform-ance indicators. However, the Commission  underlines the fact that training all NSAs  
potentially interested in participating in EC programmes is clearly out of reach.
A mix of instruments is being considered  —
in view of the regulatory framework cre-
ated by the Financial Regulations, EDF, DCI, EIHDR and ENPI.
The Commission has developed a meth- —
odology for ex post  ROM with the aim of 
measuring the impact of projects.
90.The situation for ACP is very different from 
ALA countries where the formal involvement 
of NSAs is more recent.
Furthermore, as in the vast majority of DCI 
countries, the national authorities have not identified NSA capacity building as a pri-ority. Geographic programmes cannot be  used for this purpose, leaving the thematic  programme as the only option.
In line with the statement of the Court that 
capacity development should preferably be 
channelled through Geographic programs,  
the principle of alignment of aid requires  
that partner country governments define  strategies, sectors and themes within this  context. (cf. Paris Declaration on aid ef fect-ive ness and the European Consensus for  
development and the conclusion of Accra). 
The Commission will undoubtedly continue 
to promote the involvement of NSAs.91.
The Commission welcomes the Court’s recog-
nition of the high relevance of the financed projects.
92.
The two issues are not in contradiction:  selection of the most appropriate NSAs for the implementation of the action does not 
preclude the support for specific capacity  development need, which could concern the 
same entity or a different one, with a view 
to time improvement.
With the Geographical programmes, which 
are complementary to the Thematic pro-
grammes, it is also possible to reach the  
less efficient NSAs, for instance in terms of 
capacity building.
The Commission is fully aware of the com-
plexity. More and more interaction is struc-turally organised, e.g. by the involvement  
and empowerment of the Geographical  
Directorate in the preparation and delivery 
of Thematic programs to allow a better com-
plementarity with activities supported by  the bilateral and regional contexts. While  
there is a political willingness to ensure  inclusion of grass-roots organisations, there are clear limits, inherent to:
the respect of the organisational set up (i) 
of sovereign states;the respect of sound financial manage- (ii) 
ment as per the Financial regulation;
the availability of human resources; (iii) 
the time constraint; (iv) 
the enormous number of potential  (v) 
actors.

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European Court of Auditors
Special Report No 4/2009
The Commission’s management of Non-State Actors’ involvement in EC Development Cooperation
Luxembourg: Office for Official Publications of the European Communities2009 — 65 pp. — 21 x 29.7 cmISBN 978-92-9207-273-5

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IN THIS SPECIAL REPORT, THE EUROPEAN COURT OF AUDITORS 
ANALYSES HOW THE EUROPEAN COMMISSION ENSURES THAT NON-STATE ACTORS (NSAs) ARE INVOLVED IN DEVELOPMENT 
COOPERATION, CONSIDERING THEIR ROLES IN POLICY DIALOGUE AND 
AS IMPLEMENTERS OF DEVELOPMENT PROJECTS.
THE REPORT FINDS SOME ASPECTS OF THE COMMISSION’S  
MANAGEMENT AND PROCEDURES THAT NEED IMPROVING. IT MAKES A SERIES OF RECOMMENDATIONS AIMED AT INCREASING THE EFFECTIVE INVOLVEMENT OF NSAs IN THE DEVELOPMENT COOPERATION PROCESS, BETTER ENSURING THAT ACTIVITIES IMPLEMENTED BY NSAs ARE RELEVANT AND PRODUCE THE INTENDED RESULTS, AND 
ENHANCING THE PROVISION OF CAPACITY DEVELOPMENT TO NSAs 
MOST IN NEED.
EUROPEAN COURT OF AUDITORSQJ-AB-09-004-EN-C
ISBN 978-92-9207-273-5