Special Report No 12 // 2015#The EU priority of promoting a knowledge-based rural economy has been affected by poor management of knowledge-transfer and advisory measures #(pursuant to Article 287(4), second subparagraph, TFEU)
Date: 2015-07-22
Institutions: European Court of Auditors
Subjects: EU Member State, EU investment, agricultural advisory services, agricultural education, consultancy, fund (EU), knowledge economy, knowledge management, provision of services, rural development

EN 

2015 

NO 12

Special Report  The EU priority of 

promoting a 
knowledge-based  
rural economy has been 
affected by poor 
management of 
knowledge-transfer and 
advisory measures 

EUROPEAN
COURT
OF AUDITORS

 
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Luxembourg: Publications Office of the European Union, 2015

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EN 

2015 

Special Report

NO 12

The EU priority of 
promoting a  
knowledge-based rural 
economy has been  
affected by poor 
management of 
knowledge-transfer and 
advisory measures 

(pursuant to Article 287(4), second subparagraph, TFEU)

Audit team

02

The ECA’s special reports set out the results of its performance and compliance audits of specific budgetary areas or 
management topics. The ECA selects and designs these audit tasks to be of maximum impact by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming developments and political and 
public interest.

This performance audit was produced by Audit Chamber I — headed by ECA Member Augustyn Kubik — which special-
ises in preservation and management of natural resources spending areas. The audit was led by ECA Member Jan Kinšt, 
supported by Alejandro Ballester Gallardo, head of private office; Michael Bain, head of unit; Klaus Stern, team leader and 
Els Brems, deputy team leader. The audit team consisted of Stuart Ballantine; Malgorzata Frydel; Athanasios Koustoulidis; 
Lorenzo Pirelli; Maria Eulàlia Reverté i Casas; Michael Spang and Diana Voinea. Secretarial assistance was provided by Terje 
Teppan-Niesen and language support by Milosz Aponowicz, Cathryn Lindsay, Michał Machowski, Paulina Pruszko and 
Charlotta Törneling.

Contents

03

Paragraph

Glossary

I-XI 

Executive summary

1-15 

1-3 

4-12 

13-15 

Introduction

Investment in knowledge and skills in the European Union

Rural-development support for knowledge-transfer and advisory services

Coordination with other EU support for knowledge-transfer and advisory services

16-21  Audit scope and approach

22-88  Observations

22-51 

Part I — The procedures to identify and select the most effective knowledge-transfer and advisory 
services

23-29  Member States identified the skills needs of rural operators in such broad terms that almost any kind of 

activity could be funded

30-34  Member States do not always verify the qualifications and experience of providers

35-46 

47-51 

52-65 

The selection of activities and providers suffers from a lack of fair and transparent competition

Commission guidance to the Member States on knowledge-transfer and advisory measures was limited

Part II — Procedures to ensure cost-effective and coordinated delivery of knowledge-transfer and 
advisory services

52-53  Member States approved training activities without carrying out effective checks that their costs were 

reasonable …

54-55  … and there are indications that they sometimes paid too much for training or advice services which were 

insufficiently justified

56-57 

58-65 

The Commission’s audit coverage did not provide sufficient information on the weaknesses found by the 
Court

EU funds and other sources of financing are not coordinated to provide efficient delivery of 
knowledge-transfer and advisory services

 
Contents

04

66-88 

Part III — Procedures to monitor and evaluate the results of the knowledge-transfer  
and advisory activities

69-73 

74-78 

Direct feedback from training participants is often collected by training providers  
but seldom used by Member State authorities to improve subsequent actions

Some examples of good practice exist, with Member States making efforts  
to collect useful information regarding the impact of knowledge-transfer  
and advisory activities

79-88 

The data collected to show the aggregated results of knowledge-transfer  
and advisory services at EU level are not reliable

89-102  Conclusions and recommendations

Annex I  — 

 Implementation of knowledge-transfer and advisory measures in the  
Member States audited

Annex II  —  The ‘Kirkpatrick four levels’

Reply of the Commission

 
 
 
Glossary

05

CAP: common agricultural policy: the set of legislation and practices adopted by the European Union to provide 
a common, unified policy on agriculture.

CMEF: EU-wide common monitoring and evaluation framework for rural development in the 2007-2013 
programming period.

CMES: EU-wide common monitoring and evaluation system for rural development in the 2014-2020 programming 
period.

Deadweight effect: A situation where a subsidised activity or project would have been wholly or partly undertaken 
without the grant aid.

European Structural and Investment Funds (ESI Funds, ESIF): A new term for five EU funds providing support 
under cohesion policy in the 2014-2020 programming period.  
These five funds are: the European Regional Development Fund (ERDF); the European Social Fund (ESF); the 
Cohesion Fund (CF); the European Agricultural Fund for Rural Development (EAFRD); the European Maritime and 
Fisheries Fund (EMFF).

Framework agreement: An agreement between one or more contracting authorities and one or more economic 
operators, the purpose of which is to establish the terms governing contracts to be awarded during a given period, 
in particular with regard to price and, where appropriate, the quantity envisaged1.

Managing authority: A national or regional body designated by the Member State to manage a rural-development 
programme (RDP).

Measure: An aid scheme for implementing a policy. Each measure sets out specific rules to be complied with by 
the projects or actions that can be financed. There are two main types of measures: investment measures and 
area-related aid.

Programming period: Multiannual framework to plan and implement EU policies such as rural-development policy.

Public procurement: Tender process to be followed by public bodies when purchasing goods, works and services 
above a certain price threshold. The aim is to obtain the best value offer by creating sufficient competition between 
suppliers and to ensure that contracts are awarded fairly, transparently and without discrimination. Directive 
2004/18/EC and Directive 2004/17/EC set out the legal framework for public procurement which needs to be 
implemented by the national authorities.

Rural-development programme (RDP): A document prepared by a Member State or region, and approved by the 
Commission, to plan and monitor the implementation of the rural-development policy.

Rural operators: For the purpose of this report, farmers, forest holders and other rural businesses and stakeholders 
are referred to as ‘rural operators’, unless otherwise indicated.

Shared management: Method of implementation of the EU budget where implementation tasks are delegated to 
the Member States2. To that end, Member State authorities designate bodies responsible for the management and 
control of EU funds.

1  Article 1(5) of Directive 2004/18/EC of the European Parliament and of the Council of 31 March 2004 on the coordination of procedures for the award of 

public works contracts, public supply contracts and public service contracts (OJ L 134, 30.4.2004, p. 114).

2  Article 59 of Regulation (EU, Euratom) No 966/2012 of the European Parliament and of the Council of 25 October 2012 on the financial rules applicable to 

the general budget of the Union and repealing Council Regulation (EC, Euratom) No 1605/2002 (OJ L 298, 26.10.2012, p. 1).

Executive summary

06

I
Knowledge-transfer and advisory activities have been 
upgraded to a high-level priority, both for the EU as 
a whole and for rural development in particular. The 
importance of vocational education and training, skills 
development, lifelong learning and knowledge trans-
fer has been underlined by the European Parliament 
and successive EU agriculture commissioners, and is 
reflected in the EU’s legal framework.

II
This audit examined the provision of knowledge- 
transfer and advisory activities co-funded through 
the EU budget for Rural Development (EAFRD) and 
Member States’ own budgets for the period 2007-2013. 
Total EU funding allocated to these activities for that 
period amounts to 1.3 billion euro; co -financing will 
bring total public support to 2.2 billion euro.

III
In order to be effective and to have the desired 
impact the funds allocated to knowledge-transfer 
and advisory activities must be spent in response to 
identified needs, be provided at a reasonable cost and 
by appropriately qualified and experienced providers. 
The results should be measurable and assessed to pro-
vide information on what has actually been achieved. 
However, the Court’s audit revealed that, because of 
weaknesses in the Member States’ and the Commis-
sion’s management of the activities, this was not the 
case.

IV
The audit found that the delivery of the knowledge- 
transfer and advisory activities was not sufficient 
relative to the measures’ importance and the expected 
outcomes for such activities. Too often Member States 
relied on the providers’ proposals and any type of 
training was seen as ‘good’ and eligible to receive 
public support; only infrequently was there proper 
analysis made of whether the training could make 
a real impact.

Executive summary

07

V
The procedures in place did not always ensure fair and 
transparent competition to promote the selection of 
high-quality providers and knowledge-transfer and 
advisory activities at the best price.

VI
Cost-effective delivery of knowledge-transfer and 
advisory services is essential to protect the public 
purse in respect of both EU and national budgets. 
The Court found weaknesses in the checks Member 
States must carry out, both at application stage and 
at payment stage. There are indications that Member 
States paid too much for certain services and that 
related costs were insufficiently justified.

VII
The audit further revealed that a considerable number 
of similar services are financed by different EU funds 
(e.g. from the ESF as well as through the EAFRD). This 
implies the risk of double-financing and requires the 
duplication of costly management structures, which 
the Court considers to be uneconomic. For the 2014-
2020 programming period complementarity between 
EU funds is stressed above the previous policy of 
demarcation; this implies a greater need for coordina-
tion to avoid the risks outlined above.

VIII
There was a lack of detailed evaluation of what was 
actually achieved with the public funds and only 
rather simplistic indicators such as number of persons 
trained or number of training days financed were col-
lected. In addition the Court found problems with the 
reliability of the data that is collected.

IX
The weaknesses set out in this report mainly concern 
the Member State management of the measures. 
However, given the importance attached to the 
knowledge-transfer and advisory activities, the Com-
mission’s role in guiding and supervising the Member 
States was also found to be inadequate and should be 
improved.

X
On the basis of these findings the Court makes a series 
of recommendations aimed at improving the situation 
for the current rural-development programme period 
(2014-2020) and ensuring that the ambitious objec-
tives set for the activities stand a greater chance of 
being achieved.

XI
Specifically the Court recommends that:

 ο

 ο

 ο

The Member States should have procedures in 
place to analyse the knowledge and skills needs 
of rural operators, that go beyond the setting of 
broad themes, notably for the calls for propos-
als or tender periods. The Member States should 
ensure, as part of recurrent procedures, that 
relevant knowledge-transfer and advisory services 
are specified and selected on the basis of such an 
analysis and avoid the risk of the process becom-
ing provider-driven.

The Commission should provide additional guid-
ance on how Member States should carry out such 
recurrent analyses and encourage Member States 
to formulate these analyses in specific rather than 
general terms.

The Member States should ensure that support for 
the setting-up of new advisory services is granted 
only where there is a demonstrated deficit in 
relevant services in the area concerned and where 
the need for financing new staff, facilities and/or 
equipment exists.

Executive summary

08

 ο Member States should select the service providers 

to receive public funds through fair and transpar-
ent competition, regardless of whether they use 
calls for proposals or formal public procurement 
procedures. In particular, Member States should 
ensure that their selection or award criteria do not 
favour certain providers or types of providers.

 ο

The Commission should provide additional specif-
ic guidance on in-house delivery, subcontracting 
and the assessment of service delivery by consor-
tiums. Furthermore, the Commission should ad-
equately monitor the Member States’ procedures 
to ensure that the selection of knowledge-transfer 
and advisory activities is competitive, fair and 
transparent.

 ο Member States should establish feedback systems 
that use monitoring and evaluation information to 
improve upcoming calls for proposals or tender-
ing procedures. These systems should require 
pro viders to furnish information not only on the 
participants’ satisfaction with the services, but 
also to test whether they have learned what they 
were supposed to.

 ο

The Commission should provide guidance on how 
Member States may execute such recurrent feed-
back procedures and monitor that Member States 
have them in place. The results of such feedback 
may also be used by evaluators to concentrate the 
evaluation work on the analyses of the activities at 
result and impact level.

 ο With regard to effective checks of cost-reasonable-

 ο

Finally, the Commission should increase, without 
delay, the risk profile of knowledge-transfer and 
advisory measures and enhance its supervision 
and management accordingly, to provide greater 
assurance that the Member States deliver the 
respective services effectively.

ness, the Commission and Member States should 
implement the recommendations in the Court’s 
Special Report on this subject3. In particular for 
the knowledge-transfer and advisory activ ities, 
the Member States should assess the need to 
support activities, which are readily available on 
the market at a reasonable price. When this need 
is justified, Member States should ensure that the 
costs of the supported activities do not exceed the 
costs of similar activities offered by the market.

 ο

The Commission should build on the first steps 
taken to ensure complementarity between EU 
funds, for example through specific inter-service 
working groups, to carry out a thorough assess-
ment of the complementarity between different 
EU funds proposed by the Member States for the 
2014-2020 programming period. This assessment 
should result in a coordinated approach to sup-
porting knowledge-transfer activities in order to 
mitigate the risk of double-funding and duplica-
tion of administration.

3 

See Special Report No 22/2014 ‘Achieving economy: keeping the 
costs of EU-financed rural development project grants under control’ 
(http://eca.europa.eu).

Introduction

09

Investment in knowledge 
and skills in the European 
Union

01 
The importance of vocational educa-
tion and training, skills development, 
lifelong learning and knowledge 
transfer has been voiced by numerous 
politicians and underlined in several 
high-level documents, including the 
Europe 2020 strategy for smart, sus-
tainable and inclusive growth4.

03 
The EU legislation for the 2014-2020 
programming period8, places partic-
ular emphasis on knowledge-transfer 
and advisory services as core activities 
for achieving sustainable development 
in rural areas. ‘Fostering knowledge 
transfer and innovation in agriculture, 
forestry, and rural areas’ is a horizontal 
priority in the field of rural develop-
ment, i.e. it is considered to be an im-
portant tool to improve the implemen-
tation of other priorities and measures 
in the field of rural development.

‘Boosting the knowledge base of 
our farm sector is an important 
aspect of the rural-development 
programmes’5

Phil Hogan (European Commissioner for 
Agriculture and Rural Development)

‘The agriculture of the future has to 
be knowledge-based’6

Dacian Cioloș (former European Com-
missioner for Agriculture and Rural 
Development)

02 
The Treaty on the Functioning of the 
European Union (TFEU) explicitly refers 
to ‘an effective coordination of efforts 
in the spheres of vocational training, 
of research and of the dissemination 
of agricultural knowledge’ in order for 
the objectives of the common agricul-
tural policy (CAP)7 to be attained.

Rural-development 
support for 
knowledge-transfer and 
advisory services

04 
Financial support for knowledge-trans-
fer and advisory services in rural areas 
is granted under the European Agri-
cultural Fund for Rural Development 
(EAFRD). In the 2007-2013 program-
ming period this support was granted 
through the following four measures9.

 ο Measure 111 — Vocational training 

and information actions.

 ο Measure 114 — Use of advisory 

services.

 ο Measure 115 — Setting up of 

management, relief and advisory 
services.

 ο Measure 331 — Training and 

information.

4  COM(2010) 2020 final of 

3 March 2010 ‘EUROPE 2020 
— A strategy for smart, 
sustainable and inclusive 
growth’.

5 

6 

European Commission 
—  press release: ‘A further 18 
rural development 
programmes get green light’, 
Brussels, 13 February 2015 
(http://europa.eu/rapid/
press-release_IP-15-4424_
en.htm).

Statement on 
knowledge-based farming 
12 October 2011 (https://www.
youtube.com/
watch?v=QqOqVed_atA).

7  Article 41 of the TFEU.

8 

Regulation (EU) No 1305/2013 
of the European Parliament 
and of the Council of 
17 December 2013 on support 
for rural development by the 
European Agricultural Fund 
for Rural Development 
(EAFRD) and repealing Council 
Regulation (EC) No 1698/2005 
(OJ L 347, 20.12.2013, p. 487).

9  Measure 341 (Skills acquisition 
and animation with a view to 
preparing and implementing 
a local development strategy) 
and Measure 431 (Running the 
local action group, skills 
acquisition, animation) also 
include training, but are 
relevant only to Leader and 
similar groups under Axis 3 
and are intended to help such 
groups implement their local 
strategies. They are therefore 
not considered any further in 
the context of this audit.

Introduction

10

Farmers, forest holders and other rural 
businesses and stakeholders are here-
after referred to as ‘rural operators’.

05 
The aim of the first three measures 
was to enhance the competitiveness 
of farmers and forest holders. Meas-
ure 331 was directed at other rural 
businesses and stakeholders with the 
aim of both increasing their ability to 
contribute to diversifying the rural 
economy and improving the quality 
of life in rural areas. Measures 111 and 
331 covered training courses, work-
shops, farm visits, coaching, etc. and 
are referred to as knowledge-transfer 
measures. Measures 114 and 115 were 
advisory measures that were intended 
to provide guidance to individuals or 
groups of farmers and forest holders. 
The individual knowledge-transfer 
and advisory activities were offered 
to the participants either for free or at 
a reduced fee.

Examples of knowledge-transfer and advisory services funded by the EAFRD

1
x
o
B

Training for farm women

Training for farmers

Farmers’ working group (field visit)

© ZAMm/ Gerald Lechner

© ECA

© BMLFUW/LFI/weinfranz 

 
Introduction

11

06 
Within the framework of rural- 
development policy, knowledge-trans-
fer and advisory measures are subject 
to shared management by the Com-
mission and the Member States. Rural- 
development programmes (RDPs) are 
proposed by the Member States and 
approved by the Commission. The 

Member States then select the pro-
jects to which funding is to be allocat-
ed, based on the programmes submit-
ted. Figure 1 shows how funding is 
allocated to relevant projects under 
the regulatory framework.

1 Regulatory framework for allocating EAFRD funding to projects
e
r
u
g
i
F

Rural development policy established at EU level
(Community strategic guidelines, Council regulation)

Proposed by the 
 Commission and 
approved by the
Council

Strategic programming at Member State level
(National strategic plan, rural development programme)

Proposed by the 
Member State and 
approved by the
Commission

Detailed rules and procedures at Member State level
(National or regional legislation, procedures, guides)

Project
selection

€

Funding allocated to knowledge transfer and advisory
projects

Source: European Court of Auditors.

 
12

10  The figures are based on 

information provided by the 
European Commission. They 
include both the figures 
provided in the 56 of the 118 
RDPs approved and those still 
under discussion. The figures 
are therefore indicative at the 
present time (10/07/2015).

Introduction

07 
As far as the 2007-2013 period is con-
cerned, approximately 1.3 billion euro, 
i.e. 1.4 % of EAFRD funding, was set 
aside for knowledge-transfer and ad-
visory measures. By 31 December 2013 
some 744 million euro, or 57 % of the 
planned EAFRD funding, had been 
spent by Member States. All measures 
are co-financed by the Member States 
(for details, see Table 1). However, as 
already indicated, the overall impor-
tance attached to knowledge-transfer 
and advisory measures far exceeds 
their value in purely monetary terms.

08 
Member States do not necessarily 
implement all four EAFRD know-
ledge-transfer and advisory measures. 
An analysis of 2012 data received from 
the Commission revealed that, out 
of a total of 88 RDPs, measures 111, 
114, 331 and 115 were not utilised in 
19 %, 52 %, 66 % and 74 % of the RDPs 
respectively.

09 
For the future the four individual 
meas ures have now been merged into 
two for the 2014-2020 rural-develop-
ment programming period.

 ο Measure 01 — Knowledge-transfer 

and information actions.

 ο Measure 02 — Advisory services, 
farm management and farm relief 
services.

10 
Planned EAFRD expenditure for meas-
ure 01 amounts to 1.16 billion euro 
and that for measure 02 to 742 mil-
lion euro, i.e. 1.9 billion in all10. When 
combined with national co-financing 
the total public spend may exceed 
4 billion euro. This constitutes an in -
crease of around46 % compared to the 
expenditure planned in the previous 
programming period.

1 Total public (EAFRD plus national co-financing) and EAFRD expenditure by measure
e
l
b
a
T

Incurred between 2007 and 2013

Planned for 2007-2013

Measure

Description of the measure

Vocational training and  
information actions

Use of advisory services

Setting-up of management, relief 
and advisory services

111

114

115

331

EAFRD (euro)

Total public (euro)

EAFRD (euro)

Total public (euro)

947 013 157 

1 599 928 390 

556 561 212 

974 023 090 

197 958 811 

338 640 512 

50 307 450 

76 068 793 

98 320 876 

26 540 966 

62 498 154 

169 488 261 

43 419 212 

122 427 257 

Training and information

115 516 980 

226 388 227 

Knowledge-transfer and advisory measures

1 310 796 398 

2 241 025 922 

743 921 208 

1 309 357 820 

Source: Data from the European Network for Rural Development (updated in February 2014).

 
Introduction

11 
Whereas participants in training and 
recipients of advice, as well as service 
providers, were potential beneficiar-
ies of the measures in the 2007-2013 
programming period, this has now 
changed. In the 2014-2020 period, 
the beneficiaries of financial support 
 under measures 01 and 02 will be 
service providers, namely the entities 
providing advice or training to the 
final recipients (rural operators).

12 
Although not compulsory, some 
Member States were already using 
public procurement procedures to 
select providers of knowledge-transfer 
and advisory services in the 2007-2013 
programming period. Under the new 
legislation, public procurement rules 
must be applied before service con-
tracts are concluded with providers of 
services under measure 02. In the case 
of measure 01, public procurement is 
not compulsory for selecting service 
providers.

13

11  As set out in Article 9 of 

Regulation (EU) No 1303/2013 
of the European Parliament 
and of the Council of 
17 December 2013 laying 
down common provisions on 
the European Regional 
Development Fund, the 
European Social Fund, the 
Cohesion Fund, the European 
Agricultural Fund for Rural 
Development and the 
European Maritime and 
Fisheries Fund and laying 
down general provisions on 
the European Regional 
Development Fund, the 
European Social Fund, the 
Cohesion Fund and the 
European Maritime and 
Fisheries Fund and repealing 
Council Regulation (EC) No 
1083/2006 (OJ L 347, 
20.12.2013, p. 320).

12  The Fund-specific investment 
priorities are set out in the 
following documents. 
—  ESF: Article 3 of Regulation 
(EU) No 1303/2013. 
—  EFRD: Article 5 of 
Regulation (EU) No 1301/2013 
of the European Parliament 
and of the Council of 
17 December 2013 on the 
European Regional 
Development Fund and on 
specific provisions concerning 
the Investment for growth and 
jobs goal and repealing 
Regulation (EC) No 1080/2006 
(OJ L 347, 20.12.2013, p. 289). 
—  EAFRD: Article 5 of 
Regulation (EU) No 1305/2013.

Coordination with other 
EU support for 
knowledge-transfer and 
advisory services

13 
EU support for knowledge-transfer 
and advisory services is not limited to 
the area of rural-development policy. 
At a very general level, and taking into 
account the mandate of each fund, 
training projects are supported via 
the European Social Fund (ESF) and 
the European Regional Development 
Fund (ERDF), the objective of which 
is to contribute to growth and jobs. 
These funds, along with the EAFRD 
and two other funds, are referred to 
as the European Structural and Invest-
ment Funds (ESI Funds) The legislative 
framework for 2014 to 2020 requires 
better coordination between the ESI 
Funds than was previously the case 
at both EU and Member State level. 
The new framework is illustrated in 
Figure 2.

14 
The ESI Funds are a means of imple-
menting the Europe 2020 strategy. In 
order to provide effective support, 
the ESI Funds should focus on con-
tributing to 11 thematic objectives11. 
The Fund-specific regulations provide 
a further breakdown of these objec-
tives into investment priorities.

15 
The thematic objective relevant to this 
audit is No 10, which comprises ‘invest-
ing in education, training and voca-
tional training for skills and lifelong 
learning’. Further detailed investment 
priorities are set out in the specific 
regulations of the ESF, the EFRD and 
the EAFRD12 (see Figure 2).

Introduction

14

2 Legal framework for the 2014-2020 programming period
e
r
u
g
i
F

Europe 2020
Initiatives for smart, sustainable and
inclusive growth

ESI Funds — Common Strategic Framework

Reflecting Europe 2020 through 11 common thematic objectives
(10) investing in education, training and vocational 
training for skills and lifelong learning; 

Partnership Agreement
Member State documents outlining the
intended use of the ESI Funds

ESI Funds — fund-specific regulations

Fund-specific investment priorities reflecting thematic objective
(EAFRD, ESF, ERDF)

Operational programmes
Rural development programmes

Source: European Court of Auditors.

 
Audit scope and approach

15

19 
The audit covered the 2007-2013 
programming period and made the 
link, insofar as possible, with the next 
programming period, in which only 
entities providing training and advice 
to final recipients (rural operators) will 
benefit from the measures. The audit 
therefore focused on this type of ben-
eficiary over the 2007-2013 period.

13  For the purposes of this report, 

‘Member State’ may be taken 
to mean the country or 
a region or autonomous 
community in that country.

14  The Court conducted a survey 
of 19 Member States, covering 
a sample of 25 RDPs in order 
to ascertain the reasons why 
Member States had not made 
full use of all the measures 
available.

20 
The audit was carried out between 
July 2014 and February 2015.  Audit 
evidence was collected through 
documentary reviews, audit visits 
to the managing authorities and to 
service providers in five Member 
States13 (Spain (Galicia), Austria, Poland, 
Sweden and the United Kingdom 
(England)) and a survey14. The situation 
with regard to the various measures 
implemented in the Member States 
visited is illustrated in Annex I.

16 
The Court conducted an audit of 
the procedures for the management 
and control of the spend on know-
ledge-transfer and advisory measures 
in the 2007-2013 programming period 
(see also paragraph 4) with a view to 
providing meaningful recommenda-
tions regarding the new programming 
period. This is so that Member States 
can take them into account when 
developing the implementation rules 
and procedures for their programmes 
and the Commission can use them in 
particular to improve its monitoring of 
the Member States’ management and 
control systems.

17 
The audit focused on answering the 
following question:

Are there management and control 
systems in place to deliver rural- 
development knowledge-transfer 
and advisory measures effectively?

18 
With regard to this, the Court’s report 
provides answers to the following 
sub-questions.

 ο Are there procedures in place to 
identify and select the most rele-
vant knowledge-transfer and ad-
visory services for rural operators?

 ο Are procedures in place to ensure 
cost-effective and coordinated de-
livery of knowledge-transfer and 
advisory services?

 ο Are procedures in place to moni-

tor and evaluate the results of the 
knowledge-transfer and advisory 
activities?

Audit scope and approach

16

21 
The expenditure planned and incurred 
in respect of knowledge-transfer and 
advisory measures was high in these 
Member States (see Figure 3). The 
Court’s choice of Member States was 
determined by its objective of cover-
ing all four measures (see paragraph 4) 
and having a balanced geographical 
spread. The audit visits and the survey 
covered the Member States responsi-
ble for more than 65 % of the  
expenditure of knowledge-transfer 
and advisory measures.

the 20 RDPs with the highest expenditure as at December 2012

3 2007-2013 rural-development period - Knowledge-transfer and advisory measures: 
e
r
u
g
i
F

million euro
80

30

20

10

70
0
...................................................................................................................................................... ................................................................................ ..........................................................................................................................................................................................
........................ ................................................................................ ............................................................................................................................................ ........................................ ............
......
....
.................... .................................... .................... ................
........ ....
....
.................... .................................... ....................................................
......

40

60

50

Sweden
UK – England
Austria
Hungary
France – Réunion
Denmark
France – Hexagone
Poland
Finland – Mainland
Slovakia
Portugal – Mainland
Spain – Galicia
Spain – Andalucía
Belgium – Flanders
Czech Republic
UK – Wales
Lithuania
Romania
Italy – Piemonte
France – Guadeloupe

..................................................................................................................
..

..
............................................................................
..

Knowledge-transfer measures

Advisory measures

Source: Data from the European Network for Rural Development.

 
Observations

17

Part I — The procedures 
to identify and select the 
most relevant 
knowledge-transfer and 
advisory services

Member States identified 
the skills needs of rural 
operators in such broad 
terms that almost any kind of 
activity could be funded

23 
The selection and implementation of 
needs-driven activities requires Mem-
ber States to analyse and determine 
rural operators’ individual preferences 
and identify the objective knowledge 
and skills needs of the rural economy 
and society before entering into the 
planning and/or selection of training 
activities. These needs may change in 
the short or medium term. The analyt-
ical and planning procedures should 
therefore be flexible enough to be 
able to respond to these changes.

24 
Consequently, the Court would expect 
Member States to examine the know-
ledge and skills needs over a longer 
time frame for strategic purposes (for 
practical reasons, the programming 
period) and to have recurrent pro-
cedures for determining short- and 
medium-term needs. Following such 
analyses, the Member States should 
have sufficient information at their dis-
posal to specify the services required 
for calls proposals or tenders. This is 
illustrated in Figure 4.

22 
In order to assess whether the most 
relevant knowledge-transfer and 
advis ory activities were selected, the 
Court applied the following criteria.

 ο

 ο

 ο

 ο

The EAFRD should only be used 
for financing activities that help to 
attain the Member States’ specific 
objectives set for the measures in 
order to avoid arbitrary financing 
of any kind of training or advice to 
rural operators. A prerequisite for 
this is an analysis of the knowledge 
and skills needs of rural operators 
which is sufficiently specific to 
allow Member States to target the 
aid at concrete activities.

The EAFRD should finance only 
high-quality training and advice. 
High-quality providers are of key 
importance, and Member State 
authorities should therefore have 
relevant requirements and proced-
ures in place.

Providers and activities should be 
selected through fair and transpar-
ent competition.

The Commission should approve 
only RDPs which clearly identify 
the knowledge and skills needs 
of rural operators. If necessary, 
the Commission should provide 
guidance to Member States to help 
them establish better needs as-
sessment procedures.

Observations

18

and advisory activities

4 Recurrent needs analysis for the selection of rural-development knowledge-transfer 
e
r
u
g
i
F

Long-term needs analysis and programming

Procurement 
speciﬁcation

Short-term
needs analysis

Project
selection

Project
implementation

Year 1

Year 3

Year 7

Evaluation

Year 2

Next 
period

Final evaluation

Source: European Court of Auditors.

25 
The Court reviewed the national strat-
egy plans and RDPs and other strategic 
documents, and also available studies, 
implementing rules and the service 
specifications related to the specific 
procurement of these types of activ-
ities. The Court found that the Member 
States audited had identified and de-
fined the knowledge and skills needs 
of rural operators only in broad terms, 
which serves the strategic purpose. 
However, none of the Member States 
audited went on further to identify the 
most relevant activities (i.e. concrete 
training courses) within these areas. 
This implies the risk that generic and 
provider-driven activities, such as basic 
computer courses, are financed, which 
may not be based on identified needs 
(see Box 2).

 
Observations

19

2
x
o
B

Examples of broad definitions of knowledge and skill needs not further 
specified for procurement purposes

United Kingdom (England)

The United Kingdom (England) used procedures at several management levels to identify the knowledge and 
skills needs of rural operators. However, this did not result in the detailed specification of knowledge-transfer 
services at procurement level. As a result, the authorities relied on the detailed proposals from the providers.

The RDP refers generally to skills deficits in the farm, food and forestry sectors and training as a priority to 
improve their competitiveness and to contribute to a better environment and healthy and prosperous com-
munities. With support from an assembly of stakeholders, a broad framework of six groups of courses was 
developed, which constituted the basis for any tendering procedure conducted by the authorities. A series 
of mini-competitions was then launched to procure the actual activities. However, the Court found that the 
service specifications for the mini-competitions remained very general and the authorities relied on the pro-
viders’ delivery plans, which had been submitted with each offer.

Austria

Similarly in Austria, the RDP referred to relevant EU priorities and to the low level of formal education in the 
primary sector. The thematic areas for the measures concerned were defined in the relevant implementing 
rules15 but remained quite broad (e.g. ‘Improving the efficiency and the competitiveness of agricultural and 
forestry businesses’). The implementing rules set out that a dedicated conference, including stakeholders, 
would propose further specifications and priorities to the Ministry of Agriculture (BMLFUW), which had to 
be taken into account by the approving authorities for project selection. Despite ten meetings having taken 
place, no further specification was provided and, consequently, the project selection was made only on the 
basis of the broad thematic areas mentioned in the implementing rules.

15  Sonderrichtlinie des Bundesministers für Land- und Forstwirtschaft, Umwelt und Wasserwirtschaft zur Umsetzung von Maßnahmen im Rahmen des 

Österreichischen Programms für die Entwicklung des ländlichen Raums 2007 – 2013 ‘Sonstige Maßnahmen’.

 
Observations

20

27 
An insufficient analysis of the pro-
posals from service providers implies 
not only the risk of financing irrele-
vant activities, but also the risk of 
duplicating training activities that are 
already readily available on the market 
and of paying above the market price 
(see paragraphs 54 to 55). This con-
stitutes unnecessary public expend-
iture and may distort existing service 
markets.

26 
The Member States audited involved 
providers and stakeholders in the 
process of defining priorities or the-
matic areas for knowledge-transfer 
and advisory services, either through 
meetings and working groups, or 
by giving them the opportunity to 
submit written proposals. Provider and 
stakeholder involvement should lead 
to services that better respond to the 
needs of the target groups. However, 
stakeholders may also have an interest 
in promoting services that are popular 
or already readily available, instead of 
addressing the actual knowledge and 
skills gaps of rural operators.  Member 
States should therefore consider exter-
nal opinions and proposals, but should 
eventually take an impartial decision 
on whether or not the activ ities pro-
posed by the service providers actually 
address the real needs of rural opera-
tors and are easily available in the mar-
ket at a reasonable price. The Court 
found no evidence that this was the 
case. As a result, the authorities  relied 
on what is essentially a bottom-up 
procedure in which providers propose 
courses that should actually be pro-
cured, rather than providers respond-
ing to clearly defined needs expressed 
by the authorities themselves.

21

16  Article 25 of Council 

Regulation (EC) No 1698/2005 
of 20 September 2005 on 
support for rural development 
by the European Agricultural 
Fund for Rural Development 
(EAFRD) (OJ L 277, 21.10.2005, 
p. 1): ‘support (…) shall be 
granted in order to cover costs 
arising from the setting up of 
farm management, farm relief 
and farm advisory services as 
well as forestry advisory 
services and shall be 
degressive over a maximum 
period of five years from 
setting up’.

Observations

28 
Another example of weak assessments 
in this respect refers to measure 115. 
Through measure 115 the EAFRD 
should finance the costs incurred in 
setting up services (such as staff costs, 
costs for new premises, equipment, 
etc.)16. However, the Court found that 
measure 115 had sometimes been 
used to finance long-standing ad-
visory  bodies for the setting-up of 
services that were in fact not new. 
They concerned the inclusion of new 
subjects (deriving from new regulation 
requirements) in the advice. While 
in the United Kingdom (England), 
potential providers of new services 
had to demonstrate the deficit in the 
provision of appropriate advice in 
a specific area, this was not the case in 
Spain (Galicia) (see Box 3). In the other 
audited Member States measure 115 
was not used.

3
x
o
B

Spain (Galicia) — Funding the setting-up of ‘new’ services that were in fact 
not new

Spain (Galicia) grants funding for the setting-up of supposedly ‘new’ advisory services to providers that in fact 
already existed before the 2007-2013 RDP was implemented. The funding is for advice topics that are consid-
ered to be new, irrespective of whether or not there is a demonstrated need or demand from the rural oper-
ators and/or whether the existing structures are sufficient to absorb these new topics (i.e. whether providing 
advice on new topics requires the recruitment of new staff, renting additional facilities and/or buying new 
equipment).

In light of the fact that it reduced its staff at the end of the five-year support period, the service provider 
 audited also seems to depend on EAFRD funding to cover its running costs.

Apart from financing existing service providers, there is also a risk of over-financing of providers’ staff costs. 
Staff costs are covered by measure 115, but they are also financed via measure 114, which subsidises the fees 
farmers pay to providers for advice.

 
 
Observations

22

29 
The audit showed that, in spite of 
insufficient needs analysis, relevant 
knowledge-transfer and advisory 
actions are also being co-financed by 
the EAFRD. However, this was not the 
result of the identification and target-
ing of specific needs (see Box 4).

4
x
o
B

Examples of relevant and innovative projects funded

Sweden — ‘Generationsskifte’

‘Generationsskifte’ (Generation shift) concerns the handover of a farm from the older to the younger gener-
ation. This is increasingly important, given the age trend in the population actively involved in farming (more 
that 50 % of farmers in Sweden and the EU are 55 and older17). The one-day training course examined in 
Sweden primarily provides information on economic and financial issues (particularly taxation) and matters of 
civil law. Psychological and emotional aspects, which are also significant in the handover of a family farm, are 
touched upon, but are dealt with in greater detail in coaching sessions that are also available.

Sweden — ‘Grön Arena’

‘Grön Arena’ is a project that aims to support farms that provide services relating to social care, education, 
health and recreation, e.g. providing on-farm activities for elderly people or children after school, ‘feel good 
activities’ in the countryside or with animals, etc. This project serves societal needs and provides possible 
income diversification for farmers. After being tested in one region, the project was expanded to the whole 
country.

Austria — Management course for women in rural areas

The objective of this management course was to encourage and enable women to take over responsible 
pos itions in rural business and societal groups, and thereby also serve as role models and encourage other 
women to become more active in rural development. The relevance of this course derives clearly from the 
Community Strategic Guidelines for the 2007-2013 programming period18, which set out the explicit objectives 
to encourage the entry of women into the labour market and to consider the training needs of women (for 
add itional information on this course, see also Box 9).

17  European Commission (2015): Member States factsheets (Sweden, p. 13, and European Union, p. 17) (http://ec.europa.eu/agriculture/statistics/

factsheets/index_en.htm).

18  Council Decision 2006/144/EC of 20 February 2006 on Community strategic guidelines for rural development (programming period 

2007 to 2013) (OJ L 55, 25.2.2006, p. 20).

 
23

19  See Article 15(2) of 

Commission Regulation (EC) 
No 1974/2006 of 15 December 
2006 laying down detailed 
rules for the application of 
Council Regulation (EC) No 
1698/2005 on support for rural 
development by EAFRD (OJ 
L 368, 23.12.2006, p. 15): 
‘2. The authorities and bodies 
selected to provide advisory 
services to farmers shall have 
appropriate resources in the 
form of qualified staff, 
administrative and technical 
facilities and advisory 
experience and reliability with 
respect to the requirements, 
conditions and standards 
referred to in points (a) and (b) 
of the second subparagraph 
of Article 24(1) of 
Regulation (EC) No 1698/2005’.

Observations

Member States do not always 
verify the qualifications and 
experience of providers

30 
With a view to ensuring the quality and 
effectiveness of the knowledge-trans-
fer and advisory services that are on 
offer, bodies providing such services 
should be competent as regards both 
staff qualifications, experience and 
regular training, and administrative 
and technical capabilities.

31 
With regard to advisory services, the 
Court found that the expected stand-
ards19 had been met by all Member 
States, which allowed farmers and 
forest holders to choose from a list of 
authorised providers. In Sweden, how-
ever, the requirements for qualification 
and experience concerned only advice 
on cross compliance and occupational 
safety, because other types of advice 
to farmers were offered under meas-
ure 111, for which no such require-
ments had been set.

32 
In the absence of relevant EU rules, 
Sweden had not defined any require-
ments concerning knowledge-trans-
fer measures. Other Member States 
 audited had set out relevant eligibility 
or award criteria, although, despite 
some good practices encountered, 
the audit revealed that the procedures 
to assess the qualifications of pro-
viders were rather ineffective.

33 
Austria and the United Kingdom 
(England) have strong requirements at 
provider level. In Austria, providers of 
knowledge-transfer services are only 
eligible if they hold a quality-manage-
ment certificate that is valid for adult 
training institutions, and in the United 
Kingdom (England), interested service 
providers must prove their financial, 
technical or professional abilities at the 
first stage of a three-stage tendering 
procedure. However, in both cases the 
audit revealed that the authorities did 
not systematically check the qualifica-
tion and experience of the firms that 
deliver courses and their trainers (see 
also Box 5).

5
x
o
B

Austria: Quality-management certificates of training providers not 
checked

In order to check the eligibility criterion that providers of knowledge-transfer services hold a quality-man-
agement certificate, the Austrian authorities have included relevant points for checking in their checklists. 
However, the Court found that in four out of 30 cases, the authorities confirmed the respective point in their 
checklist even though no quality-management certificate existed.

The total public expenditure paid to these four providers amounted to 3.6 million euro (EAFRD: 1.8 mil -
lion euro), of which approximately 3.1 million euro (EAFRD: 1.6 million euro) related to one provider alone. In 
October 2014 the same provider announced that it had now obtained the quality-management certificate, 
whereas it had been providing training since 2007.

 
Observations

24

34 
Similar problems of insufficient checks 
on providers’ qualifications were 
found in Poland and Spain (Galicia). 
The authorities relied on the providers’ 
information, without checking it on 
the basis of supporting documents. 
As soon as the authorities in Spain 
(Galicia) delivered training courses 
themselves, the qualifications and 
experience of its staff and its technical 
and administrative capacities were 
taken for granted and no checks were 
made.

The selection of activities 
and providers suffers from 
a lack of fair and transparent 
competition

35 
Competition encourages providers 
to improve the quality of their ser-
vices, offer good prices and propose 
needs-driven services and should 
thus provide greater value for the EU 
taxpayer’s money. The basic prin-
ciples of competition are fairness and 
transparency. Furthermore, as already 
stated in paragraph 24, the authorities 
responsible should have a clear idea 
of the services needed in order to be 
able to specify the services required 
in calls for either proposals or tenders, 
or establish pertinent criteria for the 
selection of relevant activities.

36 
With regard to knowledge-transfer 
measures, the Member States  audited 
have different ways of selecting 
providers and services, ranging from 
no competition to in-house provision 
by the authorities or affiliated  bodies, 
single calls for proposals and the 
application of public procurement 
procedures. However, despite the 
wide range of procedures used, the 
Court found that, in general, it was 
the proposals of long-standing and 
well-established providers of know-
ledge-transfer services that were 
recurrently selected and received most 
of the EAFRD funding. The Court con-
siders that this was because of a lack of 
competition and/or because of a lack 
of fairness and transparency.

37 
In the following paragraphs the Court 
presents the procedures encountered 
in the different Member States audited 
and certain risks and findings related 
to these procedures:

No competitive selection of 
providers and services — 
Austria and Sweden

38 
Project proposals may be sought or 
submitted at any time throughout the 
programming period, i.e. without any 
fixed periods or deadlines. As a con-
sequence, a competitive assessment 
and selection of projects and pro viders 
is not possible and providers have 
no incentive to propose particularly 
needs-oriented and well-designed 
services, i.e. the risk that the bulk of 
the financial support is spent on pro-
vider-driven services is high.

25

20  Mandl, C. and Kuttner, T., 
‘Bildungsevaluierung 
Ländliche Entwicklung LE 
07-13 — Endbericht’, Vienna, 
2013, p. 107. 
Deadweight effect: A situation 
where a subsidised activity or 
project would have been 
wholly or partly undertaken 
without the grant aid.

41 
In Sweden, in-house projects were 
processed in the same way as projects 
carried out by external training pro-
viders, i.e. a different organisational 
unit under the same authority ap-
proved the activity. However, projects 
were not ranked and the Court found 
that several checks were only pro 
 forma (see paragraph 53).

42 
In-house projects were also out-
sourced, but the cost of the associated 
administrative activities (e.g. drafting 
a tender notice, checking incoming 
offers), which actually comprised part 
of the authorities’ normal duties, were 
charged to the project. Furthermore, 
the audit found instances of in-house 
projects delivery by the authorities 
that were significantly more expen-
sive than those already available in 
the market without EAFRD support 
(see paragraph 55).

Observations

39 
At the time of the audit a group of 
public body training institutes in 
Austria had received 77.3 % of the 
EAFRD funding available for meas-
ure 111 and 54.3 % of that for meas-
ure 331. These training institutes have 
a competitive advantage over other 
providers, because no other providers 
had the opportunity to participate 
in official meetings organised by the 
authorities, where new courses and 
implementing rules were discussed. 
An evaluation report commissioned by 
the Austrian authorities found that the 
provinces [Bundesländer] approved, 
almost exclusively, training courses al-
ready offered by these institutes, with 
potentially high deadweight effects20.

In-house provision of services – 
Spain (Galicia) and Sweden

40 
In-house delivery of services was 
extensive in Spain (Galicia) (89 % of 
the budget for measure 111) and in 
Sweden (61 % of the budget for meas-
ure 111 and 35 % for measure 331). 
Private providers were not given the 
opportunity to carry out such projects, 
which were instead approved direct-
ly by the Member State authorities. 
The Court found no documented 
decision-making procedure in which 
a financial ceiling had been fixed and/
or in-house delivery had been jus-
tified (e.g. the presence of in-house 
expertise and capacity, skills needs not 
covered by the market).

Observations

26

Calls for proposals — Spain 
(Galicia)

43 
In Spain (Galicia), only 11 % of the 
 budget for measure 111 was imple-
mented through a competitive selec-
tion procedure, i.e. the annual calls 
for proposals. The proposals received 
were assessed on the basis of a system 
of merit points for different criteria, 
which were communicated to po-
tential providers. However, the audit 
revealed that there was no objective 
method of awarding the merit points. 
This resulted in applications being 
granted either 0 points (when the 
information required in the application 
is missing) or the maximum possible 
points (when the related fields are 
filled in, even with non-specific infor-
mation). As a result the selection pro-
cedure was not transparent and gave 
no assurance that the best providers 
and services were selected.

Public procurement — United 
Kingdom (England) and Poland

44 
Public procurement or tendering is 
a competitive selection procedure that 
follows formalised rules. If correctly 
applied, it should provide reasonable 
assurance of fairness and transparency 
and good results in terms of the selec-
tion of providers and projects. How-
ever, the Court found several issues 
that give rise to concerns.

45 
An issue encountered in the United 
Kingdom (England) relates to subcon-
tracting. The multistage procurement 
procedure and size of the lots favour 
the major providers. Smaller providers 
can only become part of a delivery 
structure through subcontracting. The 
English authorities require tenderers to 
provide relevant information, e.g. their 
agreements with subcontractors, con-
tract management, and the communi-
cation planned to ensure the desired 
outcome is achieved. On the other 
hand, they have no direct control over 
subcontracting and rely on the main 
provider as regards both the selection 
of subcontractors and the invoicing of 
services delivered. The latter resulted 
in excessive profits paid by the author-
ities to the main contractor, an aspect 
which is further developed in Part 2 of 
this report (see Box 8).

46 
In Poland, the procurement procedure 
was jeopardised by a poorly-designed 
award system that favours well-estab-
lished consortiums over new pro-
viders. The Court’s findings also show 
that it is not sufficient for the author-
ities to carry out a global assessment 
of the consortiums applying, but the 
capaci ties and roles of the individ-
ual members must also be assessed 
(see Box 6).

Observations

27

6
x
o
B

The award system in Poland is poorly designed and implemented

Newly-established providers with less than two years’ experience can never achieve the minimum 
number of points for organisational experience and are a priori excluded from financial support, 

regardless of the quality of their proposed activities.

Furthermore, the Polish implementing regulation allows three points to be awarded for ‘sharing experience 
in organising training (…)’ in cases where an agricultural organisation is a member of a consortium that is ten-
dering. The Court found that the authorities had awarded three points to such a consortium, though the agri-
cultural organisation’s role in delivering a service was minor and did not even give rise to a payment. Analysis 
of several successful tenders revealed that these three points may be crucial in winning a competition.

planning procedures). Based on the 
programming documents that were 
available at the time of the audit, the 
Court did not find evidence that Mem-
ber States have better analysed the 
knowledge and skills needs (see para-
graphs 23 to 29).

Commission guidance to 
the Member States on 
knowledge-transfer and 
advisory measures was 
limited

47 
The Commission approved the RDPs 
at the beginning of the programming 
period and did not require Member 
States to clearly identify the know-
ledge and skills needs of rural oper-
ators in their programming documents 
or describe their selection procedures. 
Furthermore, the Commission pro-
vided no appropriate guidance in the 
2007-2013 programming period that 
might have helped Member States 
establish better procedures. As re-
gards the new programming  period, 
the Commission prepared more 
extensive guidance on the measures, 
without going into detail on how to 
identify knowledge and skills needs 
(e.g. through flexible analytical and 

 
 
28

21  Articles 14(3) and 15(3) of 

Regulation (EU) No 1305/2013.

22  Article 15(3) of Regulation (EU) 

No 1305/2013.

23 

In accordance with Article 32 
of Directive 2004/18/EC.

24  Measure fiche ‘Knowledge 
transfer and information 
actions’, October 2014 version.

Observations

48 
The Commission did not issue guide-
lines to the Member States, in addi-
tion to the existing legal provision 
for advis ory services in 2007-2013, 
on ensuring that providers of know-
ledge-transfer and advisory services 
are reliable, appropriately qualified 
and experienced, and have the ne-
cessary administrative and technical 
capabilities. With regard to the 2014-
2020 programming period, certain 
improvements may materialise, in 
particular because the EU provisions 
concerning the providers’ capacities 
and qualifications have been extended 
to cover knowledge-transfer services21 
(see paragraphs 30 to 34).

49 
For the 2007-2013 programming 
 period, the Commission was not 
always aware of the problems related 
to the procedures in place for select-
ing providers and services and thus, 
could not require the Member States 
to apply corrective actions (see para-
graphs 35 to 46).

50 
As regards the 2014-2020 program-
ming period, the legislation requires 
the procedure for selecting providers 
of advisory services to be governed 
by public procurement law22. There is 
therefore a risk that the procurement 
results in only one winner per geo-
graphical and/or thematic area and 
reduces the choice for rural operators. 
This risk could be mitigated by the fact 
that Member States may sign frame-
work agreements with several pro-
viders23, thus allowing rural operators 
to choose from amongst a number of 
service provider(s).

51 
As regards the selection of know-
ledge-transfer services and provid-
ers, there is no explicit provision in 
the relevant legislation, but Member 
States ‘can choose between various 
procedures according to their national 
law, including tenders, (…) and the 
in-house procedure’24. In the absence 
of further specific guidance by the 
Commission, the problems identified 
by the Court in respect of the 2007-
2013 programming period, such as 
in-house delivery without transpar-
ent decision-making procedures or 
justification, subcontracting that is not 
subject to administrative checks and 
the same standards as normal con-
tracts, and award procedures that are 
not transparent and/or fair, may well 
persist.

Part II — procedures to 
ensure cost-effective and 
coordinated delivery of 
knowledge-transfer and 
advisory services

Member States approved 
training activities without 
carrying out effective 
checks that their costs were 
reasonable …

52 
Ensuring that the cost of rural-devel-
opment grants is kept under control is 
a key element of the ‘sound financial 
management’ required by the EU’s 
financial regulations, whereby all man-
agers of the EU budget are expected 
to apply the principle of economy, 
i.e. support the right things at the right 
price. This should be done by check-
ing costs ex ante, i.e. prior to the grant 
approval, and before the payment.

Observations

29

53 
As the Court highlighted in its Spe-
cial Report No 22/201425, Member 
State authorities do not do enough 
to ensure that the costs underlying 
the grants approved for rural devel-
opment are reasonable. In the case of 
knowledge-transfer measures, pro-
ject applications often lack sufficient 
detail to allow meaningful assessment 
of costs in relation to the activities 
planned. Nevertheless, the author-
ities in Austria and Sweden approved 
such general project applications and 
indicated on their checklists that the 
reasonableness of costs had indeed 
been checked. Other examples illus-
trating weaknesses in ex ante checks in 
Member States are given in Box 7.

… and there are indications 
that they sometimes paid 
too much for training or 
advice services which were 
insufficiently justified

25  See Special Report No 22/2014 
‘Achieving economy: keeping 
the costs of EU-financed rural 
development project grants 
under control’ (http://eca.
europa.eu).

54 
As described above, Member State 
authorities are required to check that 
the grants they approve are based on 
reasonable costs. However, it is not 
unusual for the costs incurred to differ 
from the costs approved at applica-
tion stage: both the specifications 
and prices may change. Member State 
authorities therefore need rules and 
systems in place to detect significant 
devi ations from approved project 
costs and to check that the revised 
costs are still reasonable before paying 
the grant.

7
x
o
B

Examples illustrating weaknesses in ex ante checks on reasonableness of 
costs

United Kingdom (England)

The authorities received only one offer from a training provider in response to a call for tenders. They accept-
ed the offer without comparing the prices with historical costs or other benchmarks. The Court found that 
the price per trainee claimed from the authorities was between twice and eight times as high as the standard 
price advertised in the provider’s leaflet.

Spain (Galicia)

An increase in the budget of a training project was accepted without any supporting documents having been 
requested to justify the proposed increase.

Austria

The budget of one big project was increased twice, resulting in an overall grant of 2.7 million euro. The au -
thorities approved the budget increase with the argument that the submitted cost calculations were based on 
the actual payments made for similar activities in the previous years. However, the Court found no evidence of 
appropriate checks.

 
Observations

30

55 
The Court found several weaknesses 
in procedures at the payment stage 
which resulted in incorrect payments, 
overpayment or uncertainty as to the 
correctness of the amount paid, as 
illustrated below.

 ο Compulsory training for farm-

ers, e.g. on the handling of phy-
tosanitary products and animal 
welfare, delivered directly by the 
regional authorities for 2 680 and 
2 030 euro respectively, was avail-
able in the area at a much lower 
price (150 and 200 euro respec-
tively) (Spain — Galicia).

 ο

 ο

 ο

Payments were not adjusted on 
the basis of participants’ actual at-
tendance of training, even though 
the project was to be charged on 
this basis (Spain — Galicia).

Training-attendance lists were 
unreliable: they were either 
pre-signed, showed signs of hav-
ing been changed by a person 
other than the participant, or could 
not be interpreted because of the 
different signs and codes used 
(Poland, Spain — Galicia).

The costs charged to the Member 
State authority for training courses 
were very much higher than the 
amounts actually paid to the sub-
contractors (United Kingdom — 
England, see Box 8).

 ο

 ο

In the case of projects carried out 
by the Member State authorities 
themselves, it was not possible 
to establish the link between the 
costs of an individual training 
activity and the corresponding 
payment claim submitted to the 
paying agency within a reasonable 
time frame (Sweden).

There was either no obligation 
to keep time sheets, or time-re-
cording rules were unclear or did 
not allow for correct accounting 
of actual time spent on training 
activ ities by either providers or 
the public authorities themselves 
(Sweden, Poland, Spain). In the 
case of public authorities, this 
means that there is a risk that ac-
tivities that fall within the normal 
remit of the author ities will be 
charged to projects co-financed by 
the EAFRD (see also paragraph 42).

 ο

Some advisory services were fully 
financed (Sweden), contrary to the 
legal provisions, which limit the 
financing rate to 80 %.

 ο Clear agreements with external 

trainers or speakers do not always 
exist and their invoices are not suf-
ficiently detailed to allow both the 
correctness and reasonableness 
of the costs and the link with the 
project to be established (Austria, 
Sweden).

Observations

31

8
x
o
B

Excessively high profits in the United Kingdom (England)

In the United Kingdom (England), despite the application of a public procurement procedure, the Member 
State authorities paid excessively high prices for several training courses. A payment claim for three courses 
submitted by one provider showed costs that were 13.8 times higher than the direct training costs this pro-
vider had paid to its subcontractors. The lack of value for money of this contract had also been pointed out 
by an inspector from the paying agency (prior to the Court’s audit), but with no consequence as far as the 
payment made was concerned. As a consequence, the United Kingdom authorities envisage putting in place 
a more rigorous delivery plan monitoring regime.

Course

A

9 %

B

8 %

C

13 %

91 %

92 %

87 %

Total payment²
(participant fees and
public funding) 

£5 536

£16 540

£9 420

Direct training costs paid to subcontractors¹
Gross proﬁt

1  Few other costs would be advertising and administrative costs. 
2  According to payment claim.

Source: European Court of Auditors.

 
32

26  Article 59(2) of Regulation (EU, 
EURATOM) No 966/2012.

27  Financial corrections may be 
made by the Commission 
where expenditure, 
transactions or practices are 
irregular and have not been 
corrected by the Member 
State. Financial corrections 
may also be made where there 
is a serious deficiency in the 
management and control 
system which has put at risk 
the EU contribution already 
paid to a programme, or 
where a Member State has not 
investigated irregularities and 
made the corrections 
required.

28  Article 60 of Regulation (EC) 

No 1698/2005.

29  Article 24(5) of Commission 

Regulation (EC) No 65/2011 of 
27 January 2011 laying down 
detailed rules for the 
implementation of Council 
Regulation (EC) No 1698/2005, 
as regards the implementation 
of control procedures as well 
as cross-compliance in respect 
of rural-development support 
measures (OJ L 25, 28.1.2011, 
p. 8).

Observations

The Commission’s audit 
coverage did not provide 
sufficient information on the 
weaknesses found by the 
Court

EU funds and other sources 
of financing are not 
coordinated to provide 
efficient delivery of 
knowledge-transfer and 
advisory services

56 
The Commission, through its  audits, 
must monitor the management 
and control systems established in 
the Member States26. Knowledge- 
transfer and advisory services are 
considered to be of high importance 
to the further development of rural 
society and its economy. However 
the Commission’s audit coverage to 
monitor the management of these 
measures did not provide sufficient 
relevant information on the Member 
State implementation and control pro-
cedures and did not detect or  remedy 
any of the weaknesses highlighted 
above.

57 
The Commission has not con-
ducted any specific audits of 
 knowledge-transfer and advisory 
measures in 2007-2013 on the grounds 
that the amount of funding involved 
is relatively low. In 2010, one wider 
audit covered measure 111 as part of 
its scope. It revealed several weak-
nesses in the management and control 
system (key controls) and gave rise to 
a financial correction27.

58 
As already indicated in paragraph 13, it 
is possible for knowledge-transfer and 
advisory activities for rural operators 
to be financed by sources other than 
the EAFRD. During the audit visits and 
on the basis of its survey (see para-
graph 20) the Court found that other 
EU funds (in particular the ESF), as 
well as national and regional funding 
sources, provide such financing.

59 
In order to avoid double-financing of 
the same activities by different funds, 
Member States are required to draw 
demarcation lines between the various 
funds in their RDPs28 and to implement 
effective management procedures29.

60 
Demarcation between the different 
EU funds was not only the responsi-
bility of the Member States, however. 
It should have started at Commis-
sion level with proper coordination 
between the Directorates-General 
responsible for the different funds. The 
Commission should have assessed the 
appropriateness of the demarcation 
lines and approved them as part of 
the national strategy plans for rural 
development, issued guidance and 
checked measure-implementation in 
the Member States.

Observations

33

61 
For the 2007-2013 programming 
period the Commission did not issue 
any guidance on demarcation or 
avoiding the risk of double-funding 
and approved the Member States’ 
RDPs without requiring more detail 
on the mechanisms applied to avoid 
double-funding. The Court identified 
several cases where similar activities 
had been funded by different funds 
and where the demarcation between 
the funds had been vague. The ob-
vious disadvantage of this situation 
is that management structures may 
be duplicated. The greater the lack of 
clarity of demarcation when combined 
with management procedures that do 
not work well, the greater the risk of 
double-financing.

62 
Nonetheless, the Court found that 
some Member States employed good 
practices to mitigate the risk of dou-
ble-financing, such as the stamping 
of invoices (Spain (Galicia), Austria, 
Poland), declarations by beneficiaries 
(Spain (Galicia)) and consultations 
between competent authorities and 
mandatory checks at the application 
stage (Sweden).

63 
As regards demarcation between the 
different EU Funds, the Court checked 
the Member States’ national strat-
egy plans and RDPs for the 2007-2013 
programming period and found the 
following weaknesses.

 ο

 ο

 ο

 ο

In Spain (Galicia) training actions 
outside ‘normal education’ in 
rural areas could be supported by 
either the EAFRD, ESF or ERDF. No 
relevant demarcation criteria had 
been defined, however. Examples 
were found of both information 
technology (IT) courses in rural 
areas and courses on cooperative 
entrepreneurship in rural areas 
that had been financed by either 
the EAFRD (measure 111), the ERDF 
or the ESF.

In the United Kingdom (England), 
ESF-funded courses on leadership 
and management, IT and office 
skills were open to all businesses, 
including rural enterprises, even 
though the demarcation criteria 
seemed to exclude them.

In Poland similar training activ-
ities had been financed under the 
ESF Human Capital Operational 
Programme and measure 111.

In Belgium (Wallonia) similar 
activities could be financed under 
measure 331 and the ESF. This 
measure was started with rural- 
development funding but was 
then discontinued. The Belgian 
authorities explained that training 
providers preferred ESF financing, 
because the ESF cost-reimburse-
ment rules are, in their opinion, 
less stringent that the EAFRD rules.

34

30  Monitoring is the regular 

examination of expenditure, 
outputs and results, which 
provides up-to-date 
information on whether 
programmes are progressing 
as intended. Evaluation is 
a periodic collection and 
analysis of evidence 
— including the information 
produced for monitoring 
—  to form conclusions on the 
effectiveness and efficiency of 
a programme or policy.

31  Kirkpatrick, Donald L., 
Kirkpatrick, James D., 
Evaluating training programs: 
The four levels, 3rd edition, 
2006, p. 21.

Observations

64 
In Spain (Galicia), the audit revealed 
that the system had run the risk of 
double-funding by measure 115 and 
the ESF in that staff costs for newly 
recruited staff were covered by both 
Funds. A case was detected where 
a service provider had been a bene-
ficiary of both the ESF (122 400 euro) 
in connection with job creation and 
measure 115 (124 700 euro).

65 
In the new 2014-2020 programming 
period, the relevant regulations high-
light the importance of greater coher-
ence between the EU Funds. The new 
approach focuses less on demarcation 
and more on complementarity. There 
was a lack of operational guidance 
from the Commission, however. The 
Court has analysed the partnership 
agreements and it is not clear in the 
case of several Member States how the 
coordination weaknesses that oc-
curred in the 2007-2013 programming 
period will be overcome in the new 
period.

Part III — procedures to 
monitor and evaluate the 
results of the 
knowledge-transfer and 
advisory activities

66 
A key element in ensuring that the 
EU budget is well spent is monitor-
ing and evaluation30. As illustrated in 
Figure 4 and paragraph 1, monitoring 
and evaluation can provide input for 
short-term analyses and the speci-
fications of the programme within 
the 7-year programming period and 
when designing longer term pro-
grammes for the future.

67 
In the absence of a model used by 
the Commission for the purpose, the 
Court makes reference to a recognised 
model, the ‘Kirkpatrick four levels’ 
model, for the evaluation of training 
programmes. The principles of this 
model are applicable to any training 
programme (see Annex II). Kirkpat-
rick’s four levels are designed as a se-
quence of ways to evaluate training 
programmes. When moving from one 
level to the next, the process becomes 
more difficult and time-consuming, 
but each subsequent level also pro-
vides more valuable information31.

Observations

35

70 
In most of the Member States audited, 
training participants fill in feedback 
forms (also called ‘happiness sheets’ or 
‘satisfaction sheets’) immediately after 
having finished training. This is mostly 
done on the initiative of the service 
provider but some Member State au-
thorities have developed guidelines or 
standardised feedback forms (see also 
Box 9).

71 
In many cases however, the Member 
State authorities do not fully use the 
information collected. In Poland, 
consolidated results of only one 
qualitative question are forwarded to 
the authorities in the final report at 
payment stage. In Austria, neither the 
feedback forms nor their analyses are 
forwarded to the authorities. In Spain 
(Galicia), in the case of training actions 
managed through direct intervention, 
the central services of the authorities 
do not receive the completed forms 
from the project coordinators.

68 
The information obtained through 
levels 1 and 2 (reaction and learning) 
is primarily useful to identify issues 
linked to the quality of the service 
provided, the scope of the activity, 
etc. This information can serve as an 
input to refine the specifications of 
subsequent actions, or to improve the 
selection of providers in subsequent 
calls for tender or calls for proposals. 
Levels 3 and 4 (behaviour and results) 
can be used to assess the impacts 
and outcomes of the actions and 
serve more strategic purposes such 
as  re-assessing the needs, identifying 
new needs, etc.

Direct feedback from 
training participants is 
often collected by training 
providers but seldom used 
by Member State authorities 
to improve subsequent 
actions

69 
The Court found that, in the case of 
EAFRD knowledge-transfer measures, 
most of the Member States collect 
immediate feedback from training 
participants but they do not use it to 
the extent possible for assessing the 
quality of the training or for modifying 
courses. Few Member States monitor 
information about actual learning 
(level 2).

Observations

36

9
x
o
B

Examples of good practice in collecting information for project evaluation

The Polish authorities provide standardised feedback forms to the service providers containing 11 qualitative 
questions.

The authorities in the United Kingdom (England) allow providers to use their own evaluation forms but they 
ensure, through guidelines, that the forms correspond to the minimum requirements. Three or more options 
(e.g. very satisfied, satisfied or dissatisfied) are given to the trainees with regard to six different elements; pace 
and content of the course, materials, venue and facilities, level of support by the tutor, overall quality and 
skills relevance. The participants are also required to confirm the relevance of the skills and the likelihood that 
they will be put into practice. Some space is available for comments and suggestions for improvement.

Still in the United Kingdom (England), the authorities conduct a telephone survey of randomly selected 
trainees. The primary aim of the telephone survey is to check attendance, but it is also a useful mechanism to 
obtain feedback.

In Austria, the Court saw a good example, where evaluation was integrated in the concept of an innovative 
management course for women who are active in rural development. The course included an assessment of 
qualitative elements per module, such as the learning atmosphere, course content and practical relevance, 
and the quality of the trainers and the learning documents. The trainers were required to do a self-assess-
ment, which was compared with the participants’ evaluation, and finally the provider had a feedback discus-
sion with the Austrian authorities. The participants were also required to present an examination document, 
on which they worked continuously during the course, and the provider envisages conducting a survey after 
1-2 years to enquire whether the participants are still using the knowledge and skills obtained. Participant 
interviews, which confirm the positive results of the evaluation, are also provided on the internet.

72 
Most of the Member State authorities 
visited during the audit do not moni-
tor to what extent participants actually 
acquire the intended knowledge, skills, 
and attitudes based on their partici-
pation in the learning event (equiva-
lent to Kirkpatrick level 2 (learning)). 
For  example, in Spain the authorities 
did not follow up how many of the 
training participants actually took the 
exam for which the preparatory course 
was offered. In the United Kingdom 
(England), the authorities do not 

monitor the pass rates for certificate 
courses and the Court found examples 
where even the main contractor did 
not know the pass rates of courses 
given by its subcontractor. In Poland, 
there are no tests or interviews before 
and after the training event to evalu-
ate what the trainee has learned. The 
certificate participants receive at the 
end of the training event is merely 
a confirmation of their participation 
and not a confirmation that they have 
successfully passed a test.

 
Observations

37

73 
In Austria, on the contrary, in the case 
of certificate courses, participants are 
required to pass an examination. The 
providers have to monitor and evalu-
ate the courses in accordance with 
certain criteria and submit a summary 
of the results to the national chamber 
of agriculture. According to the data 
provided, more than 850 certificates 
are issued per year, which represents 
a success rate of approximately 95 %.

75 
In Sweden, regular country-wide 
postal surveys carried out by the 
Swedish statistical service provide 
feedback on all four evaluation levels. 
The latest survey was carried out in 
spring 2010 on 8000 individuals who 
had participated in rural-development 
knowledge-transfer or advisory activ-
ities. Similar studies were carried out 
in 1999 and 2006 and a new survey is 
planned for 2015.32

32  Jordbruksverket: 

Kompetensutveckling inom 
landsbygdsprogrammet 
— Rapport från en statistisk 
undersökning genomförd. 
Rapport 2010:30. 
Jordbruksverket: Analys av 
kompetensutvecklingen inom 
landsbygdsprogrammet 
— Fördjupning av rapport 
2010:30. Rapport 2011:39.

33  Mandl, C. and Kuttner, T., 
‘Bildungsevaluierung 
Ländliche Entwicklung LE 
07-13 — Endbericht’, Vienna, 
2013.

Some examples of good 
practice exist, with Member 
States making efforts to 
collect useful information 
regarding the impact of 
knowledge-transfer and 
advisory activities

74 
As set out in the previous section, 
Member States do not fully exploit 
the possibilities of project evaluation. 
Some Member States commissioned 
surveys or evaluation studies at the 
level of training programmes with the 
objective of obtaining information 
on behavioural changes (Kirkpatrick 
level 3) and impact (Kirkpatrick level 4). 
These studies must start by collect-
ing basic evaluation data, sometimes 
a long time after the courses have 
ended, which makes it even more 
difficult and time-consuming to draw 
meaningful conclusions.

76 
In Austria, the authorities commis-
sioned a specific evaluation of meas-
ures 111 and 331. The authors of the 
study use the following four methods: 
analysis of national and international 
studies, reports and other documents; 
online survey of rural operators (both 
participants and non-participants in 
training measures), training providers 
and officials; ‘dialogue interviews’ of 
1-2 hours, and ‘evaluation cafés’. The 
authors provide a lot of detailed infor-
mation, e.g. on the estimated benefits 
of the training measures in general 
and of different types of actions, or 
the obstacles to participation. On the 
 other hand, they also point to weak-
nesses in the Austrian system and 
suggest the introduction of competi-
tive project selection by using specific 
success indicators per project33.

77 
Data collected through external stud-
ies in the United Kingdom (England) 
and Sweden also allow conclusions to 
be drawn on the benefits of training 
and advice (see Box 10).

Observations

38

0
1
x
o
B

Examples of studies on the impact of RD-financed knowledge-transfer and advice

United Kingdom (England)

In 2013, the Countryside and Community Research Institute (University of Gloucestershire) com-
pleted a report34 in which it attempted to assess the social return on investment (SROI) of axes 1 

and 3 of the RDP for England by using four case study areas.

The report concluded, inter alia, that to a large extent the benefits observed (e.g. improved on-farm sustain-
ability, engagement of the livestock industry in relation to animal health and skills, improvements to soil 
and land management practices, development of local capacity in value added in Axis 1) reflect the levels of 
investment in training and advice.

Sweden

A pesticide monitoring study in a small agricultural catchment in Southern Sweden (Vemmenhög 
river), started in 1990, shows that the occurrence of pesticide residues in watercourses decreased 
by 90 %, despite almost no changes being made to the amounts of crop protection chemicals used. Analysis 
shows that this is largely the result of increased awareness amongst the farmers of safe handling of pesticides 
following the start of advisory services in that domain in 1994.

34  An assessment of the social return on investment of axes 1 and 3 of the rural development programme for England, Final report, by the 
Countryside and Community Research Institute on behalf of the Department for Environment Food and Rural Affairs, 1 November 2013.

78 
In Sweden, since 2001, an initiative 
called Greppa Näringen (Focus on 
Nutrients)35 has been providing free 
environmental advice to farms of more 
than 50 hectares and/or more than 
25 animal units. Funding is obtained 
through the EAFRD and re-invested 
environmental taxes. The initiative 
offers, inter alia, courses for farmers 

and for advisors and provides tools for 
calculating nutrient balances. Evalu-
ation of the farm advice is integrated 
through follow-up visits and quarterly 
surveys. The farmers’ satisfaction with 
the advisory visits is quite high and, 
an even more important indication of 
success; the nitrogen and phosphorus 
surpluses and ammonia emissions per 
farm have been reduced.

35  http://www.greppa.nu

 
39

36  Article 80 of Regulation (EC) 

No 1698/2005.

37  Regulation (EC) No 1974/2006. 
The complete list of common 
indicators is given in 
Annex VIII.

38  Special Report No 12/2013 

‘Can the Commission and the 
Member States show that the 
EU budget allocated to rural 
development is well spent?’ 
(http://www.eca.europa.eu).

39  According to the CMEF 
guidelines the indicator 
‘Number of training days 
received’ is to be calculated as 
the sum of number of hours of 
training received by all 
applicants, divided by eight 
[hours]. The Polish authorities, 
however, simply indicated in 
their 2013 CMEF statistics the 
number of training days that 
took place.

Observations

The data collected to show 
the aggregated results of 
knowledge-transfer and 
advisory services at EU level 
are not reliable

79 
The previous sections refer to moni-
toring and evaluation mainly as a tool 
to improve the specifications and 
implementation of knowledge-trans-
fer and advisory services at Member 
State  level. At EU level, the rural-de-
velopment regulation established 
a Common Monitoring and Evaluation 
Framework (CMEF) for the 2007–2013 
period36. This was a new system, intro-
duced in 2007, with common indica-
tors intended to capture the progress 
towards rural- development objectives 
in a way that allows each of the RDPs 
to be compared and the data to be 
aggregated. A Commission regula-
tion37 sets more specific requirements 
and lists common baseline, output, 
result and impact indicators. As com-
mon indicators cannot fully capture 
all the effects of individual RDPs, 
Member States could also set a limit-
ed number of additional indicators. 
However, none of the Member States 
audited defined additional indicators 
for knowledge-transfer and advisory 
measures.

80 
The Court’s audit confirmed the ser-
ious weaknesses in the availability and 
quality of the monitoring and evalu-
ation information relating to spendin g 
on rural development, as highlighted 
in Special Report No 12/201338.

81 
In the course of this audit, the Court 
found the following weaknesses.

 ο

 ο

In Poland, the calculation method 
used was not in line with the CMEF 
guidelines, which resulted in huge 
differences for the number of 
actual training days39.

The United Kingdom (England) and 
Spain (Galicia) could not provide 
the requested data in full and 
Austria allocated projects to the 
wrong CMEF types (resulting in an 
unreliable number of participants 
and training days for different 
types of activities).

82 
On a positive note, in Sweden, pro-
viders and authorities are required 
to register the participants of each 
individual training or advisory activity 
online in a common database. Finan-
cial data and information on admin-
istrative project checks are recorded 
in another database. For the purpose 
of reporting monitoring data to the 
Commission, both databases must be 
linked through the project number. 
However, the separation into two 
databases means no financial informa-
tion at the level of individual training 
or advisory activities can be provided, 
e.g. costs per participant and/or train-
ing day. Moreover, the links between 
the databases are problematic and the 
Court observed problems concerning 
data reliability.

Observations

40

85 
However, the Commission is not always 
aware of the anomalies and data col-
lection problems in the Member States 
and has published aggregated data 
without ensuring their consistency. In 
the absence of reliable data, the Com-
mission is, therefore, not in a position 
to assess whether the EAFRD funds 
for knowledge-transfer and advisory 
actions are well spent or achieving the 
targets set for the actions.

83 
In addition, the analysis of aggregated 
data available from the Commission is 
evidently misleading for several Mem-
ber States (see Box 11).

84 
The Commission coordinates the CMEF, 
as Commission staff review the Annual 
Progress Reports and aggregate the 
monitoring data. They may participate 
as observers in the Member States’ 
monitoring committees and hold an 
annual meeting with the managing 
authorities to examine the main results 
of the previous year for each RDP. 
The Commission is also required to 
produce a number of reports on the 
implementation and achievements of 
the rural-development policy.

Examples of inaccurate CMEF indicator data

1
1
x
o
B

Measure 111

  The Court found that the CMEF indicated unrealistically high figures for Denmark. Output data indicated, 
for example, 7 770 euro in EAFRD expenditure per training participant and 123 708 euro per training day in 
the 2007-2011 period. The data for the period 2007-2012 still shows comparable values.

  Similarly, output data for France (Martinique, Guadeloupe and Reunion) for the 2007-2012 period resulted 
in unrealistically high values for EAFRD expenditure per training day or per participant (e.g. 382 333 euro/
training day in Martinique or 31 498 euro/participant in Guadeloupe) due to the fact that the monetary 
amounts were encoded for the complete measure whereas the training days or participants were encoded 
by sub-measure.

Measure 115

  Output data indicated that 373 new advisory services were supported through measure 115 in Spain (i.e. 
more than 50 % of all new advisory services supported in the EU). However, it appeared that all the annual 
payments to the same providers were counted as ‘new services’ and therefore the figure does not correspond 
to the actual number of new advisory services set up with the support of the measure, which is much lower.

 
Observations

41

88 
Evidently, the Court could not assess 
at the time of the audit to what extent 
the new CMES will remedy the weak-
nesses highlighted above. However, 
assessing the success of the measures 
only on the basis of the number of 
participants or the number of training 
days given or on the basis of a broad 
evaluation question will not provide 
detailed feedback on the success or 
otherwise of the funds allocated to the 
measures.

40  Articles 14 to 16 of 

Commission Implementing 
Regulation (EU) No 808/2014 
of 17 July 2014 laying down 
rules for the application of 
Regulation (EU) No 1305/2013 
of the European Parliament 
and of the Council on support 
for rural development by the 
European Agricultural Fund 
for Rural Development 
(EAFRD) (OJ L 227, 31.7.2014, 
p. 18).

41  Output indicators 11-14; see 
Annex IV of Commission 
Implementing Regulation (EU) 
No 808/2014.

42  Annex V of Commission 

Implementing Regulation (EU) 
No 808/2014.

86 
The legislation provides for a new 
common monitoring and evaluation 
system (CMES) concerning rural de-
velopment in the 2014-2020 period40. 
It incorporates a number of changes 
with respect to the previous one, such 
as the collection of less data and inter-
mediate evaluation according to the 
needs of the Member States. The new 
output indicators are:

 ο measure 01: number of operations 
supported, number of training 
days given, number of participants 
in training.

 ο measure 02: number of operations 

supported, number of beneficiar-
ies advised, number of advisors 
trained41.

87 
For measure 01, reporting will be made 
per type of operation, which should 
avoid the problem that activities 
with a small number of participants 
are reported under the same indica-
tor as events with a large number of 
participants. With regard to know-
ledge-transfer and advisory measures, 
the common evaluation question 
reads as follows: ‘To what extent have 
RDP interventions supported lifelong 
learning and vocational training in the 
agriculture and forestry sectors?’42

Conclusions and 
recommendations

42

92 
Overall, the management and control 
of the knowledge-transfer and advis-
ory activities was not sufficient relative 
to the measures’ importance and the 
expected outcome for such activities. 
Too often any type of training was 
seen as ‘good’ and eligible to receive 
public support; only infrequently was 
a proper analysis made and training 
activities targeted at areas where they 
could make a real impact. The weak-
nesses set out in this report mainly 
concern the Member States‘ man-
agement of the measures. However, 
the Commission’s role in guiding and 
supervising the Member States should 
not be underestimated.

89 
Knowledge-transfer and advisory 
activities have been upgraded to a 
high-level priority for rural develop-
ment. The importance of vocational 
education and training, skills develop-
ment, lifelong learning and knowledge 
transfer has been underlined by the 
European Parliament and EU agricul-
ture Commissioners, and is reflected in 
the EU’s legal framework.

90 
The Court’s audit posed the following 
question:

Are there management and control 
systems in place to deliver rural- 
development knowledge-transfer 
and advisory measures effectively?

91 
In order to be effective and to have 
the desired impact the funds allocated 
to training and knowledge-transfer 
measures must be spent in response to 
identified knowledge and skills needs, 
which may change during the course 
of a programming period. The activ-
ities selected to address these needs 
must be provided by appropriately 
qualified and experienced providers, in 
a cost-effective manner and the results 
should be measurable and assessed 
to provide information on what has 
actually been achieved. However, the 
Court’s audit revealed that, because 
of weaknesses in the Member States’ 
management and control systems and 
the Commission’s supervision of the 
measures, this was not the case.

Conclusions and recommendations

43

93 
The Court found that the Member 
States’ procedures for the identifica-
tion and selection of relevant service 
providers were flawed. Although they 
implemented procedures to identify 
the knowledge and skills needs of 
rural operators, the identified needs 
were defined in terms which were too 
broad. They did not go further to iden-
tify the most relevant activities (i.e. 
concrete training courses) within these 
areas and relied mainly on the pro-
viders’ proposals. In the Court’s view, 
provider and stakeholder involvement 
can potentially lead to better measure 
delivery, but the ultimate responsi-
bility remains with the Member State 
authorities (paragraphs 23 to 27).

94 
With specific regard to EAFRD sup-
port for the setting-up of advisory 
services (former measure 115), support 
had sometimes been used to finance 
long-standing advisory bodies for the 
setting-up of services that were in fact 
not new (paragraph 28 and Box 3).

Recommendation 1 
Analysis of needs

(a)  The Member States should have 
procedures in place to analyse 
the knowledge and skills needs 
of rural operators that go beyond 
the setting of broad themes, not-
ably for the calls for proposals or 
tender periods. The Member States 
should ensure, as part of recur-
rent procedures (see paragraph 
24 and Figure 4), that relevant 
knowledge-transfer and advisory 
services are specified and selected 
on the basis of such an analysis 
and avoid the risk of the process 
becoming provider-driven.

(b)  The Commission should provide 

additional guidance on how Mem-
ber States should carry out such 
recurrent analyses and encourage 
Member States to formulate these 
analyses in specific rather than 
general terms.

(c)  With specific regard to the 

setting-up of advisory services 
(former measure 115), the Member 
States should ensure that for the 
2014-2020 programming period 
EAFRD support should only be 
granted where there is a demon-
strated deficit in relevant services 
in the area concerned and where 
the need for financing new staff, 
facilities and/or equipment exists.

(d)  The Commission should provide, 
without delay, further specific 
guidance to the Member States 
concerning the setting-up of 
advisory services, and monitor 
the Member States’ subsequent 
compliance.

Conclusions and recommendations

44

43  Article 15(2) of Regulation (EC) 

No 1974/2006.

44  Article 14(3) of Regulation (EU) 

No 1305/2013.

95 
In the 2007-2013 programming period 
Member States were legally required 
to ensure that only high-quality 
providers of advisory services were 
selected43. Such a provision did not 
exist for training providers and, with 
regard to this, the audit revealed sev-
eral weaknesses in the Member States’ 
management. The introduction of 
legal requirements in the new pro-
gramming period concerning appro-
priate capacities of training providers 
may help to remedy these problems44 
(paragraphs 30 to 34).

96 
The Court found, however, that the 
Member States did not always en-
sure fair and transparent competition 
when selecting the knowledge-trans-
fer activities and service providers. 
Merely referring to public procure-
ment does not ensure competitive 
selection, as there is, in particular, no 
clear guidance provided with regard 
to in-house delivery, subcontracting 
and the assessment of service delivery 
by consortiums, despite these prac-
tices being widely used. Most of the 
Member States audited did not ensure 
fair or transparent competition when 
selecting the service providers (para-
graphs 35 to 46).

Recommendation 2 
Selection of providers

(a)  For the new 2014-2020 program-
ming period, Member States 
should select knowledge-transfer 
activities and service providers 
to receive public funds through 
fair and transparent competition, 
regardless of whether they use 
calls for proposals or formal public 
procurement. In particular, Mem-
ber States should improve their 
assessment of the qualifications 
and experience of training provid-
ers in accordance with the new 
legislation and ensure that their 
selection or award criteria do not 
favour certain providers or types of 
providers.

(b)  The Commission should pro-

vide, without delay, additional 
specific guidance on in-house 
delivery, subcontracting and the 
assessment of service delivery by 
consortiums. Furthermore, the 
Commission should ensure that 
the Member States’ procedures are 
adequately monitored and that the 
selection of knowledge-transfer 
and advisory activities is competi-
tive, fair and transparent.

Conclusions and recommendations

45

45  See Special Report No 22/2014 
‘Achieving economy: keeping 
the costs of EU-financed rural 
development project grants 
under control’ (http://eca.
europa.eu).

97 
The Court also found that Mem-
ber States did not ensure the cost- 
effectiveness of the activities funded 
or that these were appropriately 
coordinated with other EU funds. 
Cost-effective delivery of know-
ledge-transfer and advisory services is 
essential to protect the public purse in 
respect of both EU and national bud-
gets. The Court found weaknesses in 
the checks Member States must carry 
out, both at application stage and at 
payment stage. There are indications 
that Member States paid too much for 
certain services and that related costs 
were insufficiently justified (para-
graphs 52 to 55).

98 
The audit further revealed that a con-
siderable number of similar services 
are financed by different EU funds 
(e.g. from the ESF as well as through 
the EAFRD). This implies the risk of 
double-financing and requires the 
duplication of costly management 
structures, which the Court considers 
to be uneconomic. For the 2014-2020 
programming period complementarity 
between EU funds is stressed above 
the previous policy of demarcation, 
this implies a greater need for coord-
ination to avoid the risks outlined 
above (paragraphs 58 to 64).

Recommendation 3 
Cost-effectiveness

(a)  With regard to effective checks of 
cost-reasonableness, the Commis-
sion and Member States should 
implement the recommendations 
in the Court’s Special Report on 
this subject45. More concretely, the 
Member States should assess the 
need to support activities which 
are readily available on the market 
at a reasonable price. When this 
need is justified, Member States 
should ensure that the costs of the 
supported activities do not exceed 
the costs of similar activities of-
fered by the market.

(b)  The Commission should build on 

the first steps taken to ensure com-
plementarity between EU funds, 
for example through specific 
inter-service working groups, to 
carry out a thorough assessment 
of the complementarity between 
different EU funds proposed 
by the Member States for the 
2014-2020 programming period. 
This assessment should result in 
a coordinated approach to sup-
port know ledge-transfer activities, 
in order to mitigate the risk of 
double-funding and duplication 
of administration in the Member 
States.

Conclusions and recommendations

46

46  See also Special Report 
No 12/2013 ‘Can the 
Commission and the Member 
States show that the EU 
budget allocated to rural 
development is well spent?’ 
(http://www.eca.europa.eu).

99 
As regards monitoring and evaluation 
of the results of knowledge-transfer 
and advisory activities, the Court con-
cludes that the Commission and the 
Member States do not have effective 
and efficient procedures in place. The 
Court found no examples of systems in 
place where results from previous calls 
for proposals or tenders feed back into 
the knowledge and skills analyses and 
from there to the design of upcoming 
selection procedures (paragraphs 66 
to 78).

100 
Furthermore, the Court found addi-
tional confirmation that the CMEF data 
are not reliable46. The counting of ben-
eficiaries only provides, in the Court’s 
view, information on the popularity of 
certain services but not on their quali-
ty and effectiveness. The result is that 
despite many millions of euro being 
spent and several million training days 
being organised the Commission and 
Member States are not aware of the 
impact of the measures provided nor 
which activities contribute best to the 
objectives set (paragraphs 79 to 83 
and 86 to 88).

Recommendation 4 
Monitoring, evaluation and 
feedback

(a)  The Member States should im-

plement feedback systems that 
use monitoring and evaluation 
information to improve upcom-
ing calls for proposals or tender-
ing procedures (see paragraph 24 
and Figure 4). Providers should 
be required to provide informa-
tion not only on the participants’ 
satisfaction with the services, but 
also to test whether they have 
learned what they were supposed 
to. Such results may also be used 
by evaluators to allow them to 
concentrate their evaluation work 
on the analyses of the activities at 
result and impact level.

(b)  The Commission should provide 
guidance on how Member States 
may execute such recurrent 
feedback procedures and monitor 
that Member States have them in 
place. In addition, the Commission 
should ensure that Member States 
provide relevant and reliable infor-
mation on the quality and effec-
tiveness of their knowledge-trans-
fer and advisory services.

Conclusions and recommendations

47

Recommendation 5 
Commission supervision

The Commission should increase, 
without delay, the risk profile of know-
ledge-transfer and advisory measures 
and enhance its supervision and 
management accordingly, to provide 
greater assurance that the Member 
States deliver the respective services 
effectively.

101 
The Commission‘s management of the 
measures does not match up to the 
ambitions set for the activities or the 
expected contribution to EU prior-
ities. The Court is of the opinion that 
the Commission did not sufficiently 
fulfil its responsibilities within the 
shared management arrangements, in 
particular as regards the monitoring of 
the management and control systems 
established in the Member States 
(paragraphs 47 to 51; paragraphs 56 to 
57; paragraph 65; paragraphs 84 to 88).

102 
The scale of spending on knowl-
edge-transfer and advisory meas-
ures, in comparison to other rural- 
development measures, is not high in 
relative terms. However, the potential 
multiplier effect of knowledge-trans-
fer and advisory activities means that 
they merit better management and 
monitoring.

This Report was adopted by Chamber I, headed by Mr Augustyn KUBIK, Member 
of the Court of Auditors, in Luxembourg at its meeting of 22 July 2015.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

 
 
 
Annexes

48

audited

I Implementation of knowledge-transfer and advisory measures in the Member States 
x
e
n
n
A

Measure 115

Measure 331

Member State

Measure 114

Measure 111

Austria

Spain (Galicia)

United Kingdom (England)

Poland

Sweden1

implemented

implemented

implemented

implemented

implemented

not implemented

not implemented

implemented

implemented

implemented

implemented

implemented

implemented

not implemented

not implemented

implemented

not implemented

implemented

not implemented

implemented

1  In Sweden, advisory services were generally financed under measures 111 and 331.  
Only advice on cross compliance and occupational safety was financed under measure 114.

 
Annexes

49

I The ‘Kirkpatrick four levels’1
I
x
e
n
n
A

In the absence of a model used by the Commission or the Member States to analyse knowledge and skills needs 
and to evaluate knowledge-transfer and advisory services, the Court sought expert support. This led to the 
application of the ‘Kirkpatrick four levels’ model, a highly influential evaluation methodology for training pro-
grammes in the business world. The model can also be applied in reverse order for providing useful guidance 
for analysing the knowledge and skills needs of the trainees (‘The end is the beginning.’)

(a) Evaluation

Level 1 — Reaction: to what degree do participants react favourably to the learning event? This level is usually 
evaluated through feedback forms, verbal reaction, post-training surveys or questionnaires.

Level 2 — Learning: to what degree do participants acquire the intended knowledge, skills, and attitudes 
based on their participation in the learning event? This level is typically assessed through tests before and after 
the training event. Interviews or observation can also be used.

Level 3 — Behaviour: to what degree do participants apply what they learned during training when they are 
back on the job? For evaluating this level, observation and interviews over time are required to assess change, 
and the relevance and sustainability of change.

Level 4 — Results: to what degree do targeted outcomes occur, as a result of the learning event(s) and subse-
quent reinforcement? For evaluating this level, measures are usually already in place via normal management 
systems and reporting - the challenge is to relate those changes to the trainee.

(b) Analysis of needs and design of actions

Question 1: What are the specific problems and challenges of the Member States’ or regions’ rural areas and do 
knowledge-transfer and advisory activities contribute to their solution, i.e. are they relevant?

Question 2: In which way should rural operators perform (‘behave’) to contribute to the solution of the identi-
fied problems and challenges?

Question 3: What are the concrete learning, knowledge and skills required to enable rural operators to perform 
in the desired way, as identified in question 2?

Question 4: What are the preferences of rural operators as regards learning environment, conditions, methods 
and tools?

 
Annexes

50

I
I
x
e
n
n
A

The principles of the Kirkpatrick model are worth considering when analysing knowledge and skills needs 
of  rural operators and evaluating knowledge-transfer and advisory services. However, the Court wishes to 
 underline that it does not explicitly favour or recommend its exclusive use. Other models for evaluating training 
programmes exist, such as the Phillips ROI methodologyTM2 or the Framework for designing and analyzing agricul-
tural advisory services, published by the International Food Policy Research Institute (IFPRI)3.

See http://www.roiinstitute.net/

1  Kirkpatrick, J. and Kirkpatrick, W. Kayser, The Kirkpatrick four levels: A fresh look after 50 years (1959 – 2009), April 2009.
2 
3  Regina Birner, Kristin Davis, John Pender, Ephraim Nkonya, Ponniah Anandajayasekeram, Javier Ekboir, Adiel Mbabu, David J. Spielman, Daniela 
Horna, Samuel Benin, and Marc Cohen (2006): From ‘Best practice’ to ‘best fit’: A framework for analyzing pluralistic agricultural advisory services 
worldwide. Washington DC (see http://www.ifpri.org/publication/best-practice-best-fit-0).

 
Reply of the  
Commission

51

VII
The issue of demarcation was raised in the RDPs. 
For the 2014-2020 period, the ‘Commission services’ 
position papers’ drawn up for each Member State 
provided guidance on the coordinated interven-
tions of the ESIF. Member States had to ensure 
the complementarity, consistency and conformity 
with other EU instruments in order to avoid double 
funding1.

The regulatory framework for the 2014-2020 pro-
gramming period aims to ensure greater comple-
mentarity and better coordination between the 
funds with a view to avoiding overlapping activities 
through the partnership agreements, where the 
Member States have to describe the use of ESIF in 
order to ensure complementarity and synergies of 
activities.

In addition, in the area of rural development, the 
issue of complementarity has been addressed 
in chapter 14 of the RDPs Information on 
complementarity.

Moreover, the monitoring committees in the Mem-
ber States are in charge of ensuring the correct 
implementation of the programmes and comple-
mentarity between all EU funds.

Finally, Commission services work together to 
ensure a coordinated approach towards ESIF com-
plementarity during the phase of approval of the 
respective programmes.

1  Art. 5 Regulation 1698/2005.

Executive summary

III
The Member States and regions select the meas-
ures and operations to be implemented through 
the RDPs according to the needs identified in the 
programming area. These needs should be further 
detailed to the level of concrete training actions to 
be implemented. The Commission ensures that the 
RDPs are consistent with the policy objectives and 
legal requirements. The actual implementation falls 
under the responsibility of the Member States. The 
Commission is informed in the framework of moni-
toring committee meetings and the implementing 
reports provided by the Member States.

IV
Training and other knowledge-transfer activities are 
needed to improve technical and soft skills. In this 
way they contribute to enhancing the performance 
of the rural operators. Service providers respond to 
calls for tenders or proposals, which are prepared 
on the basis of the needs identified following 
the Member States’ SWOT analysis. However, the 
Commission is of the opinion that there is room for 
improvement in the ex ante analysis carried out by 
the Member States.

V
The Commission recognises that in order to choose 
the best service providers the selection should be 
based on an open and fair competition, measured 
as a ratio price/quality. Ensuring that these proced-
ures are in place falls within the responsibility of 
Member States.

VI
Member States have to ensure that the costs related 
to the implementation of the measures under the 
RDPs are reasonable. Where shortcomings are 
detected during conformity audits, financial correc-
tions apply.

Reply of the Commission 

52

VIII
The evaluation of RDPs is the responsibility of the 
Member States. Assessing the effectiveness of 
measures against the programmes’ objectives is 
a complex task, which has to be proportionate to 
the use of the evaluation. This task is carried out 
by independent professional evaluators. The latter 
draw their conclusions on a number of factors and 
methodological approaches, including a thorough 
assessment of the intervention logic of the pro-
grammes, case studies and analysis on the ground, 
analysis of interactions and spill-over effects 
between different measures etc. The CMEF set of 
indicators are just one tool to address the evalu-
ation questions. The latter aim at structuring the 
evaluation reports in a uniform way, while address-
ing in a comprehensive way strategic priorities at 
the level of the Union. The Commission encourages 
the exchange of good practices in evaluation which 
can be done through the European Network for 
Rural Development (ENRD).

IX
The Commission has always assumed its obligations 
as regards the monitoring of management and con-
trol systems established in the Member States. The 
Commission supervises the implementation of the 
measures through the process of approval of the 
RDPs, within the monitoring committees involving 
the stakeholders and bilateral annual review meet-
ings with the management authorities.

XI — First indent
This recommendation is addressed to the Member 
States.

XI — Second indent
The Commission accepts this recommendation.

The Commission agrees that recurrent analyses of 
needs for training activities by the Member States 
should be encouraged as a matter of good practice 
and will update the measure fiche on knowledge 
transfer and carry out information activities in 
this respect. The Commission will also promote 
exchange of good practices on methodological 
approaches in the context of networking activities.

XI — Third indent
This recommendation is addressed to the Member 
States.

XI — Fourth indent
This recommendation is addressed to the Member 
States.

XI — Fifth indent
The Commission accepts this recommendation and 
has started to implement it.

Guidance on in-house delivery, subcontracting and 
service delivery has already been provided in the 
form of a measure fiche on advisory services, farm 
management and farm relief services. This has been 
presented and discussed on several occasions with 
Member States in the Rural development commit-
tee. Moreover, the Commission and the European 
Network for Rural Development held specific 
training for national and regional authorities on 
‘Reasonableness of costs and public procurement’ 
in Brussels in March 2015.

Regarding the monitoring of the Member States’ 
procedures, the Commission will take due account 
of the risk profile of knowledge-transfer and advi-
sory measures in establishing its audit planning.

XI — Sixth indent
The Commission accepts this recommendation.

The Commission is implementing the recommenda-
tions made in Special Report No 22/20142 by deliv-
ering specific training for the managing authorities 
and paying agencies, enhanced assessment of the 
verifiability and controllability of the measures, and 
promotion of the use of simplified cost options. 
Furthermore, the systems in place for ensuring 
that the costs of the projects are reasonable will 
be assessed in the framework of conformity audits. 
Financial corrections will be applied in cases of 
non-compliance.

2  Special Report No 22/2014 ‘Achieving economy: keeping the 
costs of EU-financed rural development project grants under 
control’ (http://eca.europa.eu).

Reply of the Commission 

53

XI — Seventh indent
The Commission accepts this recommendation and 
has started to implement it.

The Commission already established working pro-
cedures and relevant inter-service groups to assess 
the issues of complementarity and double funding 
between different EU funds (e.g. the ESIF interpret-
ation network, other networks on specific elem-
ents of the regulation such as the simplified cost 
working group, thematic networks, or the Financial 
instruments compass platform).

The Commission will further reflect whether 
another structure (e.g. a specific inter-service 
group) is needed.

XI — Eighth indent
This recommendation is addressed to the Member 
States.

XI — Ninth indent
The Commission partially accepts this 
recommendation.

The Commission will continue to provide guidance 
on the implementation of the CMES established in 
the relevant regulations.

There are standard methodologies to ensure the 
use of feedback procedures, monitoring and evalua-
tions of results as well as impact of training activi-
ties. The Commission will encourage the exchange 
of good practices in the framework of the European 
Network for Rural Development.

However, according to the legal framework, the 
Commission is not responsible for monitoring that 
such feedback procedures are in place.

XI — Tenth indent
The Commission accepts the recommendation.

The Commission will take due account of the risk 
profile of knowledge-transfer and advisory meas-
ures in establishing its audit planning.

Observations

25
Training and advice actions financed by EAFRD 
respond to the needs identified in the program-
ming area. These needs are assessed and described 
in the RDP and then concrete, specific training and 
advice activities should be planned in the frame-
work of measure implementation arrangements.

Taking into account that training needs evolve, the 
managing authorities and service providers should 
adapt their offers to the changing demands of the 
rural operators.

26
According to the partnership principle, close con-
sultation shall take place with economic and social 
partners and other stakeholders, notably rural 
operators, on the elaboration and implementation 
of the RDP. Through monitoring committees as well 
as through informal mechanisms of participation 
and consultation, rural operators have the oppor-
tunity to manifest their needs, which should be 
taken into account by the managing authorities, 
which are finally responsible for defining the pro-
gramme’s strategy and implementation, including 
the selection of relevant activities that meet the 
programme’s strategic objectives.

28
The setting up of an advisory service must respond 
to a specific need identified in the programming 
area.

A new service can be understood as body/entity 
created ex novo to provide service on certain 
themes/areas of expertise needed in the region. 
However, the setting up of a new body/department 
in a pre-existing advisory service which allows it 
to enlarge the scope of services provided before 
can also be considered a new service. The premise 
is that the new service should be able to provide 
advice in areas where it would not be competent 
without the creation of the new service.

Reply of the Commission 

54

Common reply to paragraphs 35 
and 36
Member States have to ensure an open, fair and 
transparent selection of service providers accord-
ing to the EU and national legal frameworks. The 
requirement of greater transparency has been 
reinforced in the 2014-2020 programming period. 
In particular, article 15 of Regulation 1305/2013 
imposes the requirement of having calls for tender 
for the selection of beneficiaries. The selection of 
beneficiaries has to be done in accordance with 
the defined criteria. The bodies providing know-
ledge-transfer and information services shall have 
the appropriate capacities in the form of staff 
qualifications and must carry out regular training 
activities.

See also reply to paragraph 40.

38
This issue has also been identified as a weakness 
by the Commission. The guidelines on eligibility 
and selection explicitly recommend avoiding the 
submission of proposals at any time throughout the 
programming period.

40
Member States have the option to deliver in-house 
services as long as they fulfil the eligibility con-
dition set for the measure. Situations where the 
administration would be the unique beneficiary of 
a measure should be duly justified.

Following the assessment of the 2014-2020 RDP, the 
Commission sent an observation letter to Galicia 
requesting information about actions which would 
be implemented directly by the administration and 
how the best value for money would be ensured.

Common reply to paragraphs 47 and 48
In accordance with the legislation applicable to the 
2007–2013 programming period, the RDPs approved 
by the Commission included information regarding 
the identification of needs and the procedures for 
the selection of beneficiaries.

The requirement for carrying out a SWOT analysis 
of the situation and an identification of the needs 
that have to be addressed in the geographical area 
covered by the programme is embedded in the 
RD legislation of both programming periods. This 
analysis is complemented by the programme’s ex 
ante evaluation and includes knowledge and skill 
needs of rural operators. The programme SWOT 
analysis, identification of needs and strategic orien-
tation of the programme towards those needs are 
thoroughly checked by the Commission during the 
phase of approval of the programmes.

The Commission issued basic guidance for the 2007-
2013 programming period to help Member States to 
prepare their RDPs.

As regards the 2014-2020 programming period, the 
Commission has prepared more extensive and re -
inforced guidelines and measure fiches3 which were 
discussed several times with the Member States in 
the Rural development committee. The Commission 
has also provided answers to questions submitted 
by Member States as regards the preparation of the 
programmes.

49
The Commission is aware that public procurement 
is one of the main root causes of error rates. In this 
context, and in accordance with the principle of 
subsidiarity, the Commission has taken measures to 
identify and prevent or correct the corresponding 
risks. For instance, information regarding the risks 
related to the implementation of the measure and 
mitigating actions have to be included in the RDP. 
For the 2014-2020 programming period both the 
legal provisions and the guidance by the Commis-
sion on public procurement have been strength-
ened, in comparison with the previous program-
ming period.

3  Guidance documents on: 1)SWOT Analysis, 2)Public 
procurement in rural development 2014-2020, 3) Eligibility 
conditions and selection criteria 2014-2020,4) Elements for 
strategic programme, 5) Verifiability and controllability (Art 62), 6) 
Measure fiche Art 14 Knowledge transfer, 7) Measure fiche_Art.15 
advisory services.

Reply of the Commission 

55

The Commission monitors the implementation by 
enforcing the reporting obligations, through the 
annual review meetings and monitoring commit-
tees. Where conformity audits are carried out, the 
selection of providers is assessed.

See also replies to paragraphs 38, 40 and 43. 

51
For the 2014-2020 programming period the specific 
measure fiche on knowledge-transfer is much more 
detailed than the one developed in the previous 
programming period and includes information 
regarding the procedures for the selection of ben-
eficiaries. It is complemented by a set of compre-
hensive relevant guidance documents of a hor-
izontal nature (e.g. on programming and public 
procurement).

Furthermore, the Commission has extensively 
discussed this issue with the Member States in the 
context of the Rural development committee and 
bilaterally and has provided replies to the questions 
asked. Moreover, the Commission and the European 
Network for Rural Development held a specific 
training for national and regional authorities on 
‘Reasonableness of costs and public procurement’ 
in Brussels in March 2015.

Moreover, even in cases where the Member States 
do not apply ublic procurement procedures, they 
must make sure that the selection of beneficiaries is 
done in an open, fair and transparent way.

The in-house provision of the service is a possibil-
ity foreseen in the public procurement legislation 
in cases where the contracting authority has the 
appropriate resources to implement the operation 
internally.

See also replies to paragraphs 47-48, 49 and 50.

55
See reply to paragraph 40.

55 — Fifth indent
The Board of agriculture does not report expendi-
tures on the activity level. All expenses should how-
ever be linked to the implementation of the project 
in order to be considered eligible for support. If 
the expenditure of the administrative control is not 
considered to be part of the implementation of the 
project, costs are deducted.

55 — Sixth indent
With regard to the enhanced scrutiny of EU support 
for rural development in Sweden in 2013, the Board 
of agriculture reported improvements of the con-
trols. Further developments are foreseen as regards 
the new programming period.

Common reply to paragraphs 56 
and 57
In accordance with the requirements of Article 59 
(2) of the financial regulation, the Commission mon-
itors the management and controls systems estab-
lished in the Member States respecting the princi-
ple of proportionality and taking into account the 
level of assessed risk. The audit work programme 
is determined on the basis of a risk assessment, the 
most important element of which is the level of 
expenditure. Since the amount of funding involved 
is relatively low, only a limited number of specific 
conformity audits have been carried out of the 
knowledge-transfer or advisory services.

58
Knowledge-transfer and advice activities can be 
supported by different sources depending on the 
target group and the themes covered. For instance, 
EAFRD supports training and advice for people 
active in the agricultural and forest sectors and 
since 2014 it also targets SMEs in rural areas, while 
support under ESF focusses on the unemployed.

The Member States and regions have to ensure the 
complementarity of the instruments, prevent over-
lapping and double funding.

Reply of the Commission 

56

Common reply to paragraphs 60 and 61
As knowledge-transfer-related activities are eligi-
ble under different streams, the responsibility for 
managing such activities should stay within the 
relevant authority. Similar operations can be sup-
ported by more than one fund, in a complementary 
way. The objective of demarcation is to ensure that 
the implementation of various policies generates 
synergies, overlaps are avoided and double funding 
is prevented. During the approval process, pro-
gramme modifications and regular bilateral meet-
ings, the Commission has requested more informa-
tion on demarcation, where relevant.

The Commission has assessed the appropriateness 
of the demarcation line with other funds during 
the approval process and the assessment of subse-
quent programme modifications. All RDPs were also 
assessed in inter-service consultations, where the 
DGs responsible for the different funds aim at pre-
venting possible inconsistences or overlaps. More-
over, the monitoring Committee, which includes 
members representing other EU funds, plays an 
important role in ensuring demarcation.

See also reply to paragraph 58.

64
The Commission’s observation letter sent to Galicia 
following the assessment of the 2014-2020 RDP 
highlighted the need for avoiding double funding. 
Where relevant, the risk of double funding should 
be identified in the RDP and mitigating actions 
proposed.

65
The legislation for the 2014-2020 programming 
period sets up a series of rules to ensure the coord-
ination of interventions supported by EU funds and 
national resources.

Complementarity is firstly addressed in the part-
nership agreements (PA) where the Member States 
define the mechanisms to coordinate support 
received under ESIFs. This is subsequently specified 
in the RDPs, where a specific section on comple-
mentarity has been included (chapter 14 of the 
RDP).

Extensive guidance documents for the program-
ming at both levels (PA and programmes) have been 
developed by the Commission. In this respect, a set 
of common legal provisions (the Common provision 
regulation) and a Common Strategic Framework 
for all the ESI Funds have also been established 
to reinforce coordination, complementarities and 
synergies between the funds.

See also replies to paragraphs 60 and 61.

67
The Evaluation of the RDPs is performed by external 
evaluators under the responsibility of the Member 
States. It is the professional responsibility of the 
evaluator to propose the best methodology for the 
evaluation task.

80
The 2007-2013 CMEF was the first integrated 
monitoring and evaluation framework. In terms of 
monitoring, it showed some limitations. The 2014-
2020 CMES has been improved by introducing for 
instance a clear separation between training and 
communication events.

Box 11 — First indent
As regards Denmark, measure 111 includes 
a sub-measure which integrates measures 111 
and 123 (demonstration projects). Consequently, 
a simple division of the total support by the number 
of persons trained cannot be used to calculate the 
cost of training per person or per training day.

85
The Commission, which remains primarily depend-
ent on the data collected, aggregated and sub-
mitted by the Member States, was aware of limita-
tions stemming from the quality of such data. As 
a consequence, the Commission has improved the 
2014-2020 CMES by introducing a clear separation 
between training and communication events which 
caused the data collection issues.

Monitoring data is one of the elements that is used 
for evaluation. The assessment of whether EAFRD 
support has been well spent will be done in the 
framework of the ex post evaluation of the RDPs.

Reply of the Commission 

57

88
The evaluation of RDPs is the responsibility of 
the Member States. Assessing the effectiveness 
of measures against the programme objectives is 
a complex task, which has to be proportionate to 
the use of the evaluation. This task is carried out 
by independent professional evaluators. The latter 
draw their conclusions on a number of factors and 
methodological approaches, including a thorough 
assessment of the intervention logic of the pro-
grammes, case studies and analysis on the ground, 
analysis of interactions and spill-over effects 
between different measures etc. The CMEF set of 
indicators is just one tool to address the evaluation 
questions. The latter aim at structuring the evalu-
ation reports in a uniform way, while addressing in 
a comprehensive way strategic priorities at the level 
of the Union.

Conclusions and recommendations

91
The Member States and regions select the mea-
sures and operations to be implemented through 
the RDPs according to the needs identified in the 
programming area. These needs should be further 
detailed to the level of concrete training actions to 
be implemented. The Commission ensures that the 
RDPs are consistent with the policy objectives and 
legal requirements. The actual implementation falls 
under the responsibility of the Member States. The 
Commission is informed in the framework of moni-
toring committee meetings and the implementing 
reports provided by the Member States.

92
Training and other knowledge-transfer activities are 
needed to improve technical and soft skills. In this 
way they contribute to enhancing the performance 
of the rural operators. Service providers respond to 
calls for tenders or proposals, which are prepared 
on the basis of the needs identified following 
the Member States’ SWOT analysis. However, the 
Commission is of the opinion that there is room for 
improvement in the ex ante analysis carried out by 
the Member States.

93
The Commission recognises that in order to choose 
the best service providers the selection should be 
based on an open and fair competition measured as 
a ratio price/quality. Ensuring that these procedures 
are in place falls within the responsibility of Mem-
ber States.

See also reply to paragraph 92.

94
The setting up of an advisory service must respond 
to a specific need identified in the programming 
area.

A new service can be understood as body/entity 
created ex novo to provide service on certain 
themes/areas of expertise needed in the region. 
However, the setting up of a new body/department 
in a pre-existing advisory service, which allows it 
to enlarge the scope of services it provided before, 
can also be considered a new service. The premise 
is that the new service should be able to provide 
advice in areas where it would not be competent 
without the creation of the new service.

Recommendation 1 (a) 
This recommendation is addressed to the Member 
States.

Recommendation 1 (b)
The Commission accepts this recommendation.

The Commission agrees that recurrent analyses of 
needs for training activities by the Member States 
should be encouraged as a matter of good prac-
tice and will update the measure fiche on know-
ledge-transfer and carry out information activities 
in this respect. The Commission will also promote 
exchange of good practices on methodological 
approaches in the context of networking activities.

Recommendation 1 (c)
This recommendation is addressed to the Member 
States.

Reply of the Commission 

58

Recommendation 1 (d)
The Commission accepts this recommendation and 
has started to implement it.

The Commission has issued guidance on Article 15 
of Regulation (EU) No1305/2013 to help the Member 
States or regions to implement the measures. How-
ever, guidance is not legally binding and its appli-
cation depends on the Member States. The Com-
mission has also replied to the numerous questions 
raised by the Member States.

The implementation of RDPs, including the set-
ting-up of advisory services, is discussed within the 
monitoring committees, the annual review meet-
ings and conformity audits.

Where necessary, the Commission will continue to 
update and extend the current guidance.

96
Guidance on public procurement in the context 
of rural development has been provided by the 
Commission. In particular, guidance on Article 15 of 
Regulation 1305/2013 explains the requirements for 
the in-house provision of the service.

Recommendation 2 (a)
This recommendation is addressed to the Member 
States.

Recommendation 2 (b)
The Commission accepts this recommendation and 
has started to implement it.

Guidance on in-house delivery, subcontracting and 
service delivery has already been provided in the 
form of a measure fiche on advisory services, farm 
management and farm relief services. This has been 
presented and discussed on several occasions with 
Member States in the Rural development commit-
tee. Moreover, the Commission and the European 
Network for Rural Development held a specific 
training for national and regional authorities on 
‘Reasonableness of costs and public procurement’ 
in Brussels in March 2015.

Regarding the monitoring of the Member States’ 
procedures, the Commission will take due account 
of the risk profile of knowledge-transfer and advis-
ory measures in establishing its audit planning.

97
The Member States have to ensure that the costs 
related to the implementation of the measures 
under the RDPs are reasonable. Where shortcom-
ings are detected during conformity audits, finan-
cial corrections apply.

98
The issue of demarcation was raised in the RDPs.

For the 2014-2020 period, the ‘Commission services’ 
position papers’ drawn up for each Member State 
provided guidance on the coordinated interven-
tions of the ESIF. The Member States had to ensure 
the complementarity, consistency and conformity 
with other EU instruments in order to avoid double 
funding4.

The regulatory framework for the 2014-2020 pro-
gramming period aims to ensure greater comple-
mentarity and better coordination between the 
funds with a view to avoiding overlapping activities 
through the partnership agreements where the 
Member States have to describe the use of ESIF in 
order to ensure complementarity and synergies of 
activities.

In addition, in the area of rural development, the 
issue of complementarity has been addressed 
in chapter 14 of the RDPs ‘Information on 
complementarity’.

Moreover, the monitoring committees in the Mem-
ber States are in charge of ensuring the correct 
implementation of the programmes and comple-
mentarity between all EU funds.

4  Art. 5 Regulation 1698/2005

Reply of the Commission 

59

Finally, Commission services work together to 
ensure a coordinated approach towards ESIF com-
plementarity during the phase of approval of the 
respective programmes.

Recommendation 3 (a)
The Commission accepts this recommendation.

The Commission is implementing the recommenda-
tions made in Special Report No 22/20145 by deliv-
ering specific trainings for the managing authorities 
and paying agencies, enhanced assessment of the 
verifiability and controllability of the measures, and 
promotion of the use of simplified cost options. 
Furthermore, the systems in place for ensuring 
that the costs of the projects are reasonable will 
be assessed in the framework of conformity audits. 
Financial corrections will be applied in cases of 
non-compliance.

Recommendation 3 (b)
The Commission accepts this recommendation and 
has started to implement it.

The Commission already established working pro-
cedures and relevant inter-service groups to assess 
the issues of complementarity and double funding 
between different EU funds (e.g. the ESIF interpreta-
tion network, other networks on specific elements 
of the regulation such as simplified cost working 
group, thematic networks, or Financial instruments 
compass platform).

The Commission will further reflect whether 
another structure (e.g. a specific inter-service 
group) is needed.

5  See Special Report No 22/2014 ‘Achieving economy: keeping 
the costs of EU-financed rural development project grants under 
control’ (http://eca.europa.eu).

Common reply to paragraphs 99 
and 100
The evaluation of RDPs is the responsibility of the 
Member States. Assessing the effectiveness of 
measures against the programmes’ objectives is 
a complex task, which has to be proportionate to 
the use of the evaluation. This task is carried out 
by independent professional evaluators. The latter 
draw their conclusions on a number of factors and 
methodological approaches, including a thorough 
assessment of the intervention logic of the pro-
grammes, case studies and analysis on the ground, 
analysis of interactions and spill-over effects 
between different measures etc. The CMEF set of 
indicators are just one tool to address the evalu-
ation questions. The latter aim at structuring the 
evaluation reports in a uniform way, while address-
ing in a comprehensive way strategic priorities at 
the level of the Union. The Commission encourages 
the exchange of good practices in evaluation which 
can be done through the ENRD.

Recommendation 4 (a)
This recommendation is addressed to the Member 
States.

Recommendation 4 (b)
The Commission partially accepts this 
recommendation.

The Commission will continue to provide guidance 
on the implementation of the CMES established in 
the relevant regulations.

There are standard methodologies to ensure the 
use of feedback procedures, monitoring and evalu-
ations of results as well as impact of training activ-
ities. The Commission will encourage the exchange 
of good practices in the framework of the European 
Network for Rural Development.

However, according to the legal framework, the 
Commission is not responsible for monitoring that 
such feedback procedures are in place.

Reply of the Commission 

60

101
The Commission has always assumed its obligations 
as regards the monitoring of management and con-
trol systems established in the Member States. The 
Commission supervises the implementation of the 
measures through the process of approval of the 
RDPs, within the monitoring committees involving 
the stakeholders and bilateral annual review meet-
ings with the management authorities.

The audit work programme is determined on the 
basis of a risk analysis, the most important elem-
ent of which is the level of expenditure. Since the 
amount of funding involved is relatively low, only 
a limited number of specific compliance audits have 
been carried out on the expenditure of the know-
ledge-transfer or advisory services.

Recommendation 5
The Commission accepts the recommendation.

The Commission will take due account of the risk 
profile of knowledge-transfer and advisory meas-
ures in establishing its audit planning.

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The Court examined whether the high priority of lifelong 
learning and knowledge transfer within the EU’s 
rural-development policy was matched by the Commission’s 
and Member States’ efforts to deliver high-quality 
knowledge-transfer and advisory activities. The audit found 
that this was not the case. Too often Member States relied on 
the proposals coming from the training providers and any 
type of training was seen as ‘good’ and eligible to receive 
public support. Only infrequently was there proper analysis 
made of whether such activities could make a real impact. 
Member States did not always ensure fair and transparent 
competition when selecting the training activities and paid 
too much for certain services. In terms of follow-up, the audit 
found a lack of detailed evaluation of what was actually 
achieved with the public funds. In its recommendations, the 
Court particularly encourages the Member States to adapt 
the knowledge-transfer and advisory activities they choose 
to the evolving needs of the rural operators through 
recurrent procedures of analysis and evaluation.

EUROPEAN
COURT
OF AUDITORS