Special Report No 7 // 2016#The European External Action Service’s management of its buildings around the world #(pursuant to Article 287(4), second subparagraph, TFEU)
Date: 2016-02-16
Institutions: European Court of Auditors
Subjects: European External Action Service, administrative expenditure (EU), management audit, operational expenditure (EU), property leasing, public building, real property

EN 

2016 

NO 07

Special Report  The European External 

Action Service’s 
management of its 
buildings around the world

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EN 

2016 

NO 07

Special Report

The European External 
Action Service’s 
management of its 
buildings around the world

(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 IV — headed by ECA Member Milan Martin Cvikl — which 
specialises in auditing revenue, research and internal policies, financial and economic governance and European Union’s 
institutions and bodies. The audit was led by ECA Member Pietro Russo, supported by the Attaché of his private office, 
François Gautier; Mark Crisp, Director; Paul Stafford, Principal Manager; Mark Marshall, Head of Task; and Pascale Pucheux-
Lallemand, auditor.

From left to right: M. Marshall, P. Russo, F. Gautier, P. Pucheux-Lallemand, P. Stafford.

Contents

03

Paragraph

Glossary

I-VIII 

Executive summary

01-04 

Introduction

05-06  Audit scope and approach

05 

06 

Audit scope

Audit approach

07-66  Observations

07-27 

Section I — Buildings generally meet the needs of delegations but in some cases do not provide 
best value for money because of excess space, unused properties and charges to tenants which 
do not recover full costs

08-19 

Buildings generally meet the needs of delegations

20-22 

Space in most office buildings, and some residences, exceeds the building policy ceilings

23-25 

The EEAS owns buildings which it no longer uses

26-27 

Some charges for co-location in office buildings do not recover full costs

28-47 

Section II — There is a structured procedure for selecting delegation buildings but there are some 
weaknesses at each of the major stages when it is applied in practice

30-31 

The building-file procedure provides a structured basis for selecting delegation buildings

32-35 

Delegations have insufficient expertise to identify suitable buildings and do not receive sufficient support 
from headquarters

36-43 

There are some weaknesses in the way delegations present options to headquarters

44-47 

Some Headquarters Building Committee opinions are not timely or convincing

 
Contents 

04

48-66 

Section III — Information on the suitability of buildings is not reliable and is not used for planning, 
which is too short term and particularly weak for owned properties

49-59 

Central monitoring systems do not provide reliable basic information on the suitability of all delegation 
buildings

60-62 

Planning makes insufficient use of available information and is short term

63-66 

Planning systems for owned properties are particularly weak

67-72 

Conclusions and recommendations

Annex I  —  Co-location with EU Member States in EU delegations

Annex II  —  Details of review of 30 building files

Annex III  —  Reasons why delegation buildings do not provide best value for money

Reply of the EEAS

 
 
 
 
Glossary

05

Building Committee: The Building Committee is chaired by the head of the EEAS Headquarters Infrastructure 
Division and includes at least four other members of this division and one member of the Field Security Division. 
It adopts opinions on the building files it examines.

Building file: Delegations are required to prepare a building file before renting (including when renewing a rental 
agreement), buying, renovating or constructing offices or a residence for the head of delegation. Such building files 
have to be submitted to headquarters (the Building Committee) for approval if their total value is 60 000 euro or 
more. Delegations do not have to submit a building file for renting staff accommodation unless the rent exceeds 
the rental ceiling defined for that country.

Building policy: Guidelines laid down by EEAS headquarters for delegations to ensure that the management of 
buildings is effective and keeps within financial limits. The building policy is also intended to help to standardise 
the resources made available to delegations and ensure transparency.

Co-location: The sharing of delegation office space with EU Member States or other EU institutions or bodies 
(e.g. the European Investment Bank).

Condition of office buildings and residences: EEAS headquarters monitors the condition of office buildings and 
residences of heads of delegation through on-site visits. The assessment of building condition combines three 
criteria rated from ‘0’ (unusable) to ‘5’ (excellent): health and safety, security and general status (functionality/
image/location).

Delegation: Around 140 EU delegations operate worldwide to promote EU interests and values and to deliver trade 
and development cooperation. Most delegations are responsible for EU relations with one country. Others are 
dedicated to maintaining relations with multilateral or international organisations such as the African Union or the 
United Nations. One third of delegation staff work for the EEAS; the others work for the European Commission, in 
directorates-general such as DG International Cooperation and Development, DG Neighbourhood and Enlargement 
Negotiations and DG Trade.

European External Action Service (EEAS): The European External Action Service is the European Union’s 
diplomatic service. Its role is to coordinate the EU’s foreign and security policy. The head of the EEAS is the High 
Representative for Foreign Affairs and Security Policy, who is also Vice-President of the European Commission. 
Formally launched on 1 January 2011, the EEAS was created by the Treaty of Lisbon. It brings together staff 
from relevant departments of the General Secretariat of the Council and of the European Commission as well 
as diplomatic staff from the EU Member States. The EEAS has its headquarters in Brussels and is responsible for 
running around 140 EU delegations worldwide.

Head of administration: The head of administration assists the head of delegation in the day-to-day running of the 
delegation. He/she coordinates the work of the administration section and is responsible for human resources and 
safety management, financial management and implementation of the delegation’s budget, and management of 
logistics, purchasing and premises.

Head of delegation: The heads of delegation assist the High Representative and the Commission in fulfilling their 
mandates in the field of external relations. The head of delegation is responsible for the management of all the 
delegation staff and financial resources.

Executive  
summary

06

I
On its creation in January 2011, the European External Action Service (EEAS) took over responsibility for running 
EU delegations around the world from the European Commission. It provides office space for 5 300 staff in around 
140 delegations. The EEAS is also responsible for the residences of heads of delegation and for providing, or reim-
bursing the costs of, accommodation for 2 400 staff. The effective management of EU delegation buildings contrib-
utes to achieving the EU’s objectives in foreign policy, trade and development cooperation. EEAS expenditure on 
delegation buildings in 2014 amounted to 165 million euro (see paragraphs 1 to 4).

II
The European Court of Auditors examined whether delegation buildings meet the needs of the EEAS and provide 
value for money. It examined whether the EEAS has effective procedures for selecting the right buildings, monitor-
ing the suitability of buildings and planning necessary changes (see paragraphs 5 and 6).

III
The audit found that delegation buildings, whether office buildings, residences of heads of delegation or staff 
accommodation, generally meet the needs of delegations (see paragraphs 8 to 19). However, in some cases, build-
ings do not provide best value for money because:

(a)  space in most office buildings, and some residences, exceeds the ceilings in the building policy (see para-

graphs 20 to 22);

(b)  the EEAS owns buildings which it no longer uses (see paragraphs 23 to 25);

(c)  where delegations share their office premises with EU Member States or EU institutions or bodies, some charges 

to hosted organisations do not recover full costs (see paragraphs 26 and 27).

IV
The suitability of delegation buildings depends firstly on their initial selection and then on the way the EEAS 
ensures they continue to meet needs and provide value for money. The initial selection of buildings for rental or 
purchase is based on the building-file procedure. Before renting (or renewing a rental agreement) or buying, the 
delegation concerned submits a building file to headquarters for examination and approval. In providing a struc-
tured and documented basis for decision-making, the building-file procedure is an example of good practice 
(see paragraphs 30 and 31). However, there is a risk that the EEAS does not select the right buildings because there 
are some weaknesses in the practical application of each of the major stages of the selection procedure:

(a)  When some delegations search the local market, they have insufficient expertise to identify suitable options 

and do not receive sufficient support from headquarters (see paragraphs 32 to 35).

(b)  When delegations present options to headquarters, the proposed solution is sometimes not based on a sound 

technical and financial analysis (see paragraphs 36 to 43).

(c)  When the Headquarters Building Committee makes its final decision, it is sometimes too late to sign a contract 

and it does not always demonstrate that the decision represents best value for money (see paragraphs 44 to 47).

Executive summary 

07

V
Once the EEAS has selected buildings, it regularly assesses whether they continue to meet the needs of delegations 
through site visits, but it does not identify all shortfalls (see paragraphs 49 and 50). The EEAS does not take into 
account all relevant factors when it monitors the space per person in office buildings (see paragraphs 51 and 52); 
nor does it monitor that rents of office buildings and residences remain in line with market rates and that charges 
to co-located organisations recover full costs (see paragraph 53). Furthermore, the EEAS does not reliably record the 
results of its monitoring in its information systems (see paragraphs 54 to 59).

VI
The lack of reliable basic information on delegation buildings is an obstacle to effective planning. Moreover, head-
quarters does not make effective use of the information which is available to draw up plans for taking corrective 
action (see paragraph 60). Planning focuses on addressing short-term needs (see paragraphs 61 and 62).

VII
It is the long-term objective of the EEAS to purchase more delegation office premises. In 2015, under the new provi-
sions in the financial regulation, the EEAS arranged terms for borrowing up to 200 million euro to buy real estate. 
However, the EEAS has limited experience in owning buildings and lacks real-estate management expertise. Conse-
quently, it has not established effective systems to manage owned properties, for example to maintain properties in 
good condition or to sell buildings which it no longer uses (see paragraphs 63 to 66).

VIII
On the basis of the observations in this report, the Court recommends that the EEAS should:

(a)  include environmental factors, access for disabled people and flexibility as objectives in the building policy for 

office buildings;

(b)  ensure charges paid by EU Member States or other EU institutions or bodies hosted in delegation buildings are 

consistent and recover full costs;

(c)  strengthen the application of the building-file procedure for selecting buildings;

(d)  use a central source of information to verify market rates for office buildings and regularly monitor consistency 

of office rents with market rates;

(e)  improve its real-estate management information system, so that it can provide more reliable and relevant infor-

mation to feed into the planning process;

(f)  reinforce expertise in real-estate management at headquarters to develop a more strategic approach, improve 

planning and strengthen support for delegations;

(g)  establish priorities for rentals, purchases, sales, modifications and maintenance in rolling medium-term plans, 
using available information on floor space and building condition in order to comply with the building policy;

(h)  introduce systems to manage owned buildings effectively.

Introduction

08

01 
The European External Action Service (EEAS) coordinates the EU’s foreign and 
security policy. The EEAS has its headquarters in Brussels and is responsible for 
running EU delegations around the world. The EEAS is structurally and financially 
independent from the European Commission, but cooperates with it on many 
issues.

02 
On its creation in January 2011, the EEAS took over responsibility for all EU del-
egations from the European Commission. As a consequence, delegation buildings 
that are currently occupied are largely the result of past European Commission 
decisions. The EEAS provides office space for 5 300 staff in around 140 delega-
tions. The EEAS is also responsible for the residences of heads of delegation and 
for providing or reimbursing the costs of accommodation for 2 400 staff.

03 
The effective management of EU delegation buildings contributes to achiev-
ing the EU’s objectives in foreign policy, trade and development cooperation. 
Delegation offices aim to provide a stable, visible, functional and secure working 
and meeting environment for staff and visitors. Buildings should provide value 
for money, and sharing office premises with Member States or other EU institu-
tions and bodies is actively promoted.

04 
Some 80 % of delegation office buildings and residences of heads of delegation 
are rented, the rest are owned. EEAS expenditure on delegation buildings in 2014 
amounted to 165 million euro (see  Figure 1).

Introduction 

09

1
e
r
u
g
i
F

2014 expenditure on delegation buildings 165 million euro

Security costs 26 million euro — 16 %

Water, gas, electricity, insurance — 3 %
Cleaning and maintenance — 2 %

Major repairs/fitting out — 2 %
Purchase/construction of buildings — 1 %

Source: EEAS.

Rents or 
reimbursements
 of rents
126 million euro — 76 %

Offices
53 million euro

Residences - 11 million euro

Staff accommodation
62 million euro

 
Audit scope  
and approach

10

Audit scope

05 
The overall audit objective was to examine whether the EEAS manages delega-
tion buildings well and the audit addressed the following sub-questions.

(a)  Do delegation buildings meet the needs of the EEAS and provide value for 

money?

(b)  Does the EEAS have effective procedures for selecting the right buildings?

(c)  Does the EEAS have effective systems for monitoring the continued suitabil-

ity of buildings and planning necessary changes?

1 

2 

The survey was sent to all 
delegations except those 
located inside the EU 
(e.g. Delegation of the 
European Union to the OECD 
and Unesco in Paris) and those 
depending on another 
delegation.

The sample of 30 building files 
was selected using monetary 
unit sampling from the 
148 building files submitted 
between January 2013 and 
September 2014.

Audit approach

06 
We based the audit observations on four main sources of audit evidence (see 
Figure 2).

(a)  We sent a survey to heads of administration in 133 delegations1. 112 heads of 
administration completed the survey, representing a response rate of 84 %.

(b)  We reviewed a sample of 30 building files submitted to headquarters in 2013 
and 20142. The decision to rent or buy a particular building, or whether or not 
to renew a lease, is taken on the basis of a building file submitted to head-
quarters by the delegation concerned.

(c)  We carried out visits to four delegations (Nepal, Tanzania, Turkey and United 
States — Washington DC) in order to examine building-management prac-
tices in delegations of different size, continent, space per person, ownership 
(three office buildings were rented), building condition, staff composition 
and experience of co-location. During the visits to these delegations we also 
discussed building-management practices with heads of administration of 
the Member States’ embassies. Over the course of our visits we met with the 
embassies of Belgium, Denmark, Finland, Germany, the Netherlands, Sweden 
and the United Kingdom. We also visited the Ministry of Foreign Affairs in the 
Netherlands to obtain further information on their innovative policies and 
procedures for managing embassy buildings.

(d)  We reviewed documentation relating to policies, procedures and tools, car-
ried out interviews at headquarters and analysed quantitative information 
relating to delegation buildings.

Audit scope and approach  

11

Sources of audit evidence

2
e
r
u
g
i
F

Review of
30 building files

Audit visits to
four delegations:
 Nepal, Tanzania,
Turkey and
United States

Audit
observations

Audit survey

Review of statistics
and procedures

Source: European Court of Auditors.

 
Observations

12

Section I — Buildings generally meet the needs of 
Delegations but in some cases do not provide best 
value for money because of excess space, unused 
properties and charges to tenants which do not 
recover full costs

07 
The audit examined whether buildings meet the needs of delegations and pro-
vide value for money.

Buildings generally meet the needs of delegations

Office buildings

08 
The EEAS building policy has the following objectives for delegation offices: sta-
bility, visibility, functionality, security and best value for money. The audit survey 
of heads of administration in delegations confirmed the relevance of all these 
objectives, shown in bold type in Figure 3.

3
e
r
u
g
i
F

Importance of objectives for delegation offices

Accessibility for disabled — 6 %

Environmental impact — 7 %

Flexibility — 9 %

Value for money — 12 %

Visibility — 12 %

Security — 22 %

Functionality — 18 %

Stability — 14 %

Source: Audit survey of heads of administration in EU delegations.

 
Observations 

09 
Respondents gave the highest weighting to security and functionality, but also 
recognised the importance of other factors which are not currently objectives of 
the building policy.

(a)  Flexibility. The 2014 working document on the EEAS building policy stated 

that renting has the advantage of flexibility if needs change. Building needs 
may change, for example, as a result of an increase or decrease in staff 
numbers. Moreover, staff numbers can be outside the direct control of the 
EEAS, as it provides office space for European Commission staff and for other 
organisations.

(b)  Environmental impact. Although the EEAS is determined to put in place an 
environmentally friendly workplace both at headquarters and in delega-
tions3, its building policy does not reflect this concern. For example, it has 
not yet committed itself to adopting EMAS (the eco-management and audit 
scheme)4. Actively promoting EMAS could provide an opportunity for delega-
tions to lead by example and to demonstrate that it can also be useful for 
small organisations5. Nevertheless, the Washington DC and Tanzania delega-
tions provided examples of good practice (see Box 1).

13

3 

EEAS 2013 discharge — 
answers by the EEAS to the 
written questions.

4  Court of Auditors Special 

Report No 14/2014, ‘How do 
the EU institutions and bodies 
calculate, reduce and offset 
their greenhouse 
gas emissions?’  
(http://eca.europa.eu).

5 

The European Commission 
has published an ‘EMAS toolkit 
for small organisations’ and 
promotes a standardised 
methodology called 
‘EMAS easy’.

1 Improving environmental impact in Washington DC and Tanzania
x
o
B

In 2012, the Washington DC delegation joined other diplomatic missions in Washington DC in a pledge to pur-
sue policies aimed at improving environmental quality. The delegation had already led the way in obtaining 
the Leadership in Energy and Environmental Design (LEED) gold award for its new office premises leased in 
Washington DC, an example that the landlord of the building subsequently followed by obtaining LEED gold 
certification for the remainder of the building in 2013.

In Tanzania, the EEAS owns part of an office building together with Germany, the Netherlands and the United 
Kingdom. The building is managed by a Joint Management Committee, which produces an annual manage-
ment report. The annual management report contains an analysis comparing monthly consumption of elec-
tricity, diesel and water for the previous 3 years in order to identify areas for possible future savings.

(c)  Accessibility for disabled people. Sometimes local requirements have to be 
met. This was the case for office renovations in Turkey and Washington DC. 
Moreover, health and safety inspections by the EEAS (see paragraph 49(b)) 
check the accessibility of premises for disabled people.

 
Observations 

10 
The Headquarters Infrastructure Division monitors the health and safety, security 
and general status of each Delegation office building6. The average condition of 
office buildings in 2014 was satisfactory (rated 3.7 out of 5) but there were defi-
ciencies in some delegations7 (see Figure 4).

14

6 

The assessment of the 
condition of an office building 
combines three criteria rated 
from 0 (unusable) to 5 
(excellent): health and safety 
(including structure, technical 
equipment, etc.), security and 
general status (functionality/
image/location).

7 

The four delegations assessed 
as being in the worst 
condition in 2014 were India, 
Egypt, Senegal and Sri Lanka.

Condition of delegation office buildings (5 = excellent)

Rented

Purchased before 2000

Purchased after 2000

4
e
r
u
g
i
F

s
g
n
d

i

l
i

u
b
e
c
ﬃ
o
f
o
n
o
i
t
i
d
n
o
C

5.0

4.5

4.0

3.5

3.0

2.5

2.0

1.5

1.0

0.5

0

Source: European Court of Auditors based on EEAS data.

Delegation oﬃce buildings

 
 
 
 
Observations 

15

11 
The assessment by headquarters was supported by the findings of our survey. 
Most respondents considered that delegation offices meet their needs in terms 
of location, facilitation of working relationships with partners, working condi-
tions, image, security and space (see Figure 5). Over 90 % considered that the 
location is suitable. However, a quarter of respondents considered that security, 
image and working conditions are not appropriate. A third of respondents con-
sidered that delegation offices do not provide enough space.

5
e
r
u
g
i
F

Suitability of delegation office buildings

s
t
n
e
d
n
o
p
s
e
R

100 %

90 %

80 %

70 %

60 %

50 %

40 %

30 %

20 %

10 %

0 %

Unsatisfactory
Satisfactory

Location

Facilitates
relations

Working
conditions

Image

Security

Enough
space

Source: Audit survey of heads of administration in EU delegations.

 
16

Observations 

Residences

12 
The residence of the head of delegation is provided by the EEAS. It has a double 
function: it is the private home as well as the venue for official receptions. Nor-
mally, the residence should not change when the head of delegation changes. 
The building policy states that it should have a representative image, should 
not be excessively ostentatious and should provide best value for money. The 
location of the residence and the steps taken to ensure its safety should take into 
account the security situation in the host country.

13 
Most respondents to our survey considered that residences of heads of delega-
tion meet needs in terms of security, location, image, facilitation of relationships 
with partners, condition and space (see Figure 6). However, a quarter of respond-
ents considered that the head of delegation’s residence does not provide enough 
space and that the condition of the residence is not satisfactory.

6
e
r
u
g
i
F

Suitability of residences of heads of delegation

s
t
n
e
d
n
o
p
s
e
R

100 %

90 %

80 %

70 %

60 %

50 %

40 %

30 %

20 %

10 %

0 %

Unsatisfactory
Satisfactory

Security

Location

Image

Facilitates
relations

Building
condition

Enough
space

Source: Audit survey of heads of administration in EU delegations.

 
Observations 

17

14 
The surface area of the residence should be a maximum of 600 m2 (see para- 
graph 22). The surface area of the residence and the surrounding land should be 
in the range of the size of residences of ambassadors of Member States in the 
same country8. Over 40 % of respondents to the survey considered that the head 
of delegation’s residence provides less space than most embassy residences. The 
average surface area of EU delegation residences in 2014 was 488 m2 (see Fig-
ure 7). There were some 40 residences (30 %) under 400 m2.

8 

EEAS building policy: 
Residences — policy and 
selection.

7
e
r
u
g
i
F

Surface area (m2) of residences

m²

1 400

1 200

1 000

800

600

400

200

0

Recommended maximum (600 m²)

Average (488 m²)

Source: European Court of Auditors based on EEAS data.

Delegation residences

 
Observations 

15 
The Headquarters Infrastructure Division monitors the condition9 of delegation 
residences (see Figure 8). The average condition of residences in 2014 was 4.6 out 
of 5. This is higher than the average condition of offices, rated 3.7 out of 5 (see 
paragraph 10).

18

9 

The assessment of the 
condition of a head of 
delegation’s residence 
combines three criteria rated 
from 0 (unusable) to 5 
(excellent): health and safety 
(including structure, technical 
equipment, etc.), security and 
general status (functionality/
image/location). The EEAS has 
no data on the condition of 53 
residences (see paragraph 
57(b)).

Condition of residences (5 = excellent)

Rented

Purchased before 2000

Purchased after 2000

8
e
r
u
g
i
F

s
e
c
n
e
d
i
s
e
r

f
o
n
o
i
t
i
d
n
o
C

5.0

4.5

4.0

3.5

3.0

2.5

2.0

1.5

1.0

0.5

0.0

Source: European Court of Auditors based on EEAS data.

Delegation residences

 
 
 
Observations 

19

Staff accommodation

16 
The EEAS manages accommodation for around 2 400 staff in delegations10 
through the following two methods provided for in the Staff Regulations.

(a)  EU delegations provide accommodation free of charge for around 1 400 staff. 
With a few exceptions, this accommodation is rented rather than owned. 
Since January 2014 EU delegations have been able to provide accommoda-
tion on this basis mainly in high-risk countries or in countries where rental 
market conditions make it difficult to find suitable accommodation11.

(b)  EU delegations reimburse the cost of accommodation rented by around 1 000 

staff.

10  All staff in delegations except 

local employees.

11  Decision of the High 

Representative of the Union 
for Foreign Affairs and Security 
Policy of 17.12.2013 regarding 
the rules for the 
implementation of housing 
policy in EU delegations 
(HR DEC(2013) 011).

12  EEAS building policy: 

Accommodation policy for 
officials serving in third 
countries.

17 
In both cases, the rent paid or reimbursed by the delegation is limited by a rental 
ceiling drawn up for each place of employment outside the EU. This ceiling is 
based on the composition of the staff member’s family and takes into account 
the local rental market.

18 
The EEAS building policy states that accommodation of expatriate staff should 
comply with EEAS security standards, for example it should be located in permit-
ted areas only. It should also reflect an appropriate image of the EU12.

19 
Respondents to our survey expressed a high level of satisfaction with staff ac-
commodation. Around 90 % of respondents considered that the security, space, 
location and living conditions of staff accommodation are suitable (see Figure 9).

Observations 

20

9
e
r
u
g
i
F

Suitability of staff accommodation in delegations

s
t
n
e
d
n
o
p
s
e
R

100 %

90 %

80 %

70 %

60 %

50 %

40 %

30 %

20 %

10 %

0 %

Security

Space

Location

Living conditions

Source: Audit survey of heads of administration in EU delegations.

Unsatisfactory
Satisfactory

 
Observations 

Space in most office buildings, and some residences, exceeds 
the building policy ceilings

Average space per person in delegation offices exceeds the 
building policy ceiling

20 
The EEAS building policy recommends that delegation offices should have 
a maximum size of 35 m2 per person (the maximum in the building policy before 
2013 was 42 m2)13. The calculation is based on all areas (not only offices but also 
common areas) divided by all permanent posts, except for posts which do not 
need an office (e.g. drivers). The building policy provides for the exclusion of 
certain areas from the calculation such as an additional conference room to meet 
the needs of the presidency function under the Lisbon Treaty. New delegation 
offices should consist of a mixture of individual offices, shared offices for 2-4 
people and open-space areas. Individual offices should be reserved for a small 
number of staff whose function requires one.

21 
In 2014, some 85 delegations exceeded the maximum space of 35 m2 per person14. 
The average space per person was 41 m2 (see Figure 10)15. Reducing the average 
space per person would lead to savings on rent16 and running costs.

Some residences exceed the ceiling in the building policy

22 
The EEAS building policy states that the maximum total surface area of all rooms 
of the residence of the head of delegation should be 600 m2. Although the aver-
age surface area of EU delegation residences in 2014 was under this ceiling (see 
paragraph 14), 34 residences (24 %) exceeded the ceiling (see Figure 7)17.

21

13  Newly purchased buildings 
should be large enough to 
accommodate a 10 % increase 
in staff.

14  The delegations with the 
highest office space per 
person were the delegation to 
the United Nations in New 
York (90 m2 per person) and 
the delegation to the United 
Nations in Geneva (104 m2 per 
person).

15  This analysis deducts office 
space rented to other 
organisations. It excludes 
delegations with fewer than 
10 staff, all of which have more 
than 35 m2 per person. The 
analysis is based on 
permanent posts. The 
inclusion of around 200 
temporary trainees and 
national experts would reduce 
the average space per person 
to 40 m2.

16  The total annual rent of 

delegation offices in 2014 was 
53 million euro (see Figure 1), 
which means that each m2 of 
the average space per person 
cost 1.3 million euro.

17  The residence in Indonesia, at 
1 200 m2, was one of the 
largest residences. A contract 
has been signed to rent a new 
residence of 580 m2 from 
September 2015.

Observations 

22

0
1
e
r
u
g
i
F

Office space per person in delegations

m² per person
120

100

80

60

40

20

0

Maximum recommended (35 m²)

Average (41 m²)

Note: Excludes delegations with fewer than 10 staff members.

Source: European Court of Auditors based on EEAS data.

Delegation oﬃce buildings

 
Observations 

23

The EEAS owns buildings which it no longer uses

23 
EU delegation office buildings purchased before 2000 and still used by the EEAS 
are among the office buildings in the worst condition (see Figure 4). Delegation 
staff in Gabon have relocated to small temporary offices, as the office building 
purchased in 1996 now has serious structural problems.

24 
Owned residences are smaller and easier to maintain. The average condition of 
owned residences purchased before 2000 and still used by the EEAS is 4.6 out 
of 5 (see Figure 8). This is considerably better than the average condition of 3.4 of 
owned delegation offices purchased before 2000.

25 
Although the EEAS no longer uses 20 % of the delegation buildings it owns (7 
out of 33 office buildings and 6 out of 30 residences), it has retained them. The 
unused office buildings in Chad, the Central African Republic and Rwanda are 
rented to other organisations, such as DG Humanitarian Aid and Civil Protection 
or a Member State’s embassy. Other buildings, however, are retained unoccupied. 
For example:

(a)  Owned office buildings in Botswana and The Gambia have been unoccupied 

since 2004.

(b)  The residences in South Africa and Cape Verde have been unoccupied since 

2012.

(c) 

In Tanzania, the ex-residence of the head of delegation (see Figure 11) and 
a staff house have been unoccupied since 2009 at a cost of 25 000 euro per 
year for security, utilities and gardening. They are located outside the area 
recommended by the regional security officer. Another house owned by the 
delegation, which is located within the recommended security area, has been 
unoccupied since April 2014.

Observations 

24

Former residence in Tanzania empty since 2009, but retained by the EEAS

1
1
e
r
u
g
i
F

Source: European Court of Auditors.

Some charges for co-location in office buildings do not 
recover full costs

26 
The EEAS encourages solutions which involve sharing office premises with 
Member States or other EU institutions and bodies, including DG Humanitarian 
Aid and Civil Protection. Co-location aims to ensure better visibility of the EU, 
facilitate cooperation with Member States and also save costs18. There were 45 
delegations sharing their office premises with either EU Member States or EU 
institutions and bodies in 2015. The number of delegations hosting or hosted by 
Member States’ embassies increased from 14 to 17 between May 2014 and May 
201519. Annex I shows the 17 delegations where there was co-location with one or 
more Member States in 2015.

18  EEAS building policy: 
Delegation offices — 
policy and selection. 
EEAS building policy: Sharing 
delegation offices or 
co-location with third parties.

19  2014 and 2015 working 
documents on the EEAS 
building policy.

 
25

20  European Parliament Decision 

of 3 April 2014 on the 
discharge for 2012.

21  EUCAP Nestor is an EU civilian 
mission, with some military 
expertise. It supports the 
development of maritime 
security systems in Horn of 
Africa and Western Indian 
Ocean states, to enable them 
to fight piracy and other 
maritime crime more 
effectively.

Observations 

27 
Member States and EU institutions and bodies should pay their fair share of the 
costs involved in co-location20. In practice, there are different methods for cal-
culating charges to co-locating organisations, some of which do not recover full 
costs. For example:

(a)  In Washington DC, the delegation has co-location agreements with five dif-
ferent organisations. However, only the two most recent agreements (with 
Europol and the European Investment Bank) include a contribution to admin-
istrative overheads.

(b)  In Nepal, DG Humanitarian Aid and Civil Protection contributes to cleaning, 

maintenance, utilities and security guards. However, it makes no contribution 
to office rent, which would amount to a further 8 000 euro per year. Similarly, 
in Tanzania, where the delegation owns the building, the delegation charges 
EUCAP Nestor21 only for running costs (maintenance, utilities, security and 
cleaning).

(c)  The 2013 guidance to delegations on calculating the rent charged to other 
organisations required all new agreements, and existing agreements when 
renewed, to charge for common areas. Charges set before 2013 only take 
into account the net office area of the tenant. As a result, the tenant uses the 
common areas for free and pays less than its fair share of rent and operating 
costs.

Section II — There is a structured procedure for 
selecting delegation buildings but there are some 
weaknesses at each of the major stages when it is 
applied in practice

28 
Section I examined the suitability of delegation buildings: whether they meet 
the needs of delegations and provide value for money. Whether or not delega-
tion buildings are suitable depends first of all on the way they were selected. The 
audit therefore examined whether the EEAS has effective procedures for select-
ing the right buildings.

Observations 

26

29 
The building-file procedure provides a structured basis for selecting delegation 
buildings. However, there are some weaknesses when the building-file procedure 
is applied in practice. As a consequence, there is a risk that the EEAS may not 
select the right building. The weaknesses occur at each of the major stages of the 
building-file procedure:

(a)  when the delegation searches for suitable buildings;

(b)  when the delegation compares options and presents them to the Headquar-

ters Building Committee;

(c)  when the Building Committee makes and explains its decision.

The building-file procedure provides a structured basis for 
selecting delegation buildings

30 
The selection of buildings for rental or purchase is based on the EEAS building-
file procedure.

(a)  For offices and residences, delegations have to prepare a building file before 
renting, buying or constructing a new building, or when renewing a rental 
agreement. Delegations are required to submit such building files to the 
Headquarters Building Committee for examination and approval if they have 
a total value of 60 000 euro or more.

(b)  Delegations also have to submit a building file to the Building Committee 

before any acquisition of land.

(c)  When renting staff accommodation, delegations have to submit a building 

file if the rent exceeds the ceiling set by the EEAS for the country concerned 
and for the countries where no ceilings have been set.

31 
In providing a structured and documented foundation for decision-making based 
on guidance from headquarters, the building-file procedure is an example of 
good practice. Building files use the objectives set out in the EEAS building policy 
as a basis for the selection criteria. The building file should contain a shortlist of 
suitable options resulting from the delegation’s research of the local property 
market, a discussion of whether to rent or buy, the delegation’s assessment of 
suitable options and its proposal to the Building Committee. The building-file 
procedure helps ensure that the selected buildings meet the needs of delega-
tions whilst providing value for money.

Observations 

27

Delegations have insufficient expertise to identify suitable 
buildings and do not receive sufficient support from 
headquarters

32 
Our audit review of 30 building files (see Annex II) found that in most of them 
(26 out of 30), the delegation had explored the local market. However, only 
15 of the 30 building files included a shortlist of suitable, realistic options 
(see Figure 12).

2
1
e
r
u
g
i
F

Summary results of audit review of 30 building files

4

26

s
e
l
ﬁ
g
n
d

i

l
i

u
b
f
o
r
e
b
m
u
N

15

15

25

5

8

22

7

23

No
Yes

1. Exploration of
the local market

2. Discussion of
whether to rent
or buy

3. Shortlist of more
than one suitable,
realistic option

4. Delegation's
proposed solution
based on sound
technical and
ﬁnancial analysis

5. Convincing reason
for HQ Building
Committee's
decision

Source: European Court of Auditors based on review of 30 building files.

 
 
 
 
Observations 

28

33 
In the audit survey, almost half of heads of administration considered that their 
delegation does not have sufficient staff and expertise to manage its buildings. 
Heads of administration are not building-management specialists and do not re-
ceive specific training in this area. In order to manage building projects (e.g. mov-
ing to a new office building or carrying out works), they may therefore require 
approval to bring in the necessary expertise (e.g. to analyse the market, carry out 
a rent-versus-buy analysis, negotiate with landlords or design and monitor build-
ing works). For example, in Washington DC the delegation hires a broker locally 
to research the market and to negotiate with landlords on its behalf. In countries 
where such expertise cannot be bought in, delegations require more involve-
ment and support from headquarters.

34 
The audit survey showed that 85 % of heads of administration were satisfied with 
the support they receive from headquarters when renewing office rentals. The 
level of satisfaction was lower for the support received when choosing new of-
fices (76 %) (see Figure 13).

3
1
e
r
u
g
i
F

Support to delegations for building-management activities

s
t
n
e
d
n
o
p
s
e
R

100 %

90 %

80 %

70 %

60 %

50 %

40 %

30 %

20 %

10 %

0 %

Renewing
oﬃce rental

Choosing
new oﬃces

Maintenance
and renovation

Source: Audit survey of heads of administration in EU delegations.

Inadequate HQ support
Adequate HQ support

 
Observations 

29

35 
A number of responses to the audit survey highlighted the need for more in-
tensive support from headquarters, particularly where there is a lack of suitable 
buildings on the local market22. Some delegations visited, for example Nepal (see 
Box 2), also highlighted the need for on-site visits, particularly when searching 
for new premises. In 2014 the Headquarters Infrastructure Division visited 36 
delegations to provide on-site support. As an example of good practice, when 
German embassies are seeking new premises, once the head of administration 
has identified possible locations, staff from headquarters arrive on site to check 
their suitability and to help with negotiations.

22  This was identified by 

respondents to the survey as 
one of the main obstacles 
when it comes to finding 
better premises.

2 Need for headquarters support to find an office building in Nepal
x
o
B

In Nepal, because of a lack of space in the main building, since 2007 a third of staff have been working in con-
verted garages. Since 2009, another third have been working in second-hand prefabricated cabins installed 
in the garden, presenting a poor image of the delegation (see Figure 14). The June 2011 evaluation of the 
delegation to Nepal recommended that a move to more appropriate and modern offices should be planned 
by the time the lease came to an end in 2014.

The delegation did not have the time and expertise necessary to produce a high-quality building file. It 
considered that a visit from a team of property-management experts from headquarters (e.g. a negotiator, an 
architect and a security officer) could help to search for new premises, negotiate the best arrangements and 
identify and compare suitable solutions. However, headquarters was unable to carry out such a visit, despite 
written requests from the delegation in 2011 and 2012. Headquarters did write to the delegation to encourage 
it to develop its proposal to purchase land from the French embassy and to construct offices and a residence, 
but then rejected the proposal due to lack of funds. The delegation was unable to identify a suitable alterna-
tive and so submitted a building file to renew the existing lease until 2024 which was approved by headquar-
ters in November 2013.

 
Observations 

30

Pre-fabricated cabins used as offices in Nepal

4
1
e
r
u
g
i
F

Source: European Court of Auditors.

There are some weaknesses in the way delegations present 
options to headquarters

36 
The building policy requires delegations to present to headquarters, through 
building files, the results of their research into the local property market. This 
should include a discussion of whether to rent or buy, their assessment of suit-
able options and their proposal to the Building Committee. However:

(a)  delegations do not produce building files for all new contracts;

(b)  building files are unnecessarily detailed when delegations have no intention 

of moving;

(c)  building files rarely discuss the possibility of buying and do not compare it 

with the cost of renting;

(d)  in some building files, delegations do not present options in a comparable 

way;

(e)  guidance on preparing building files does not take into account space rented 

to other organisations and income generated by co-location.

 
Observations 

31

Delegations do not produce building files for all new contracts

37 
Delegations sometimes sign a building contract without producing and submit-
ting a building file to the Building Committee, as required. For example, there 
was no building file for the 230 000 euro contract for Venezuela offices signed in 
2013 or the 240 000 euro contract for the residence in Nepal signed in 2011.

23  For German embassies, for 
example, there is an 
assumption that embassies 
will remain where they are, 
unless there is a particularly 
compelling reason to move.

Building files are unnecessarily detailed when delegations have no 
intention of moving

38 
Stability is an objective of the building policy, so there is good reason for prefer-
ring to continue with the lease for an existing building if it meets the delegation’s 
needs and provides value for money. This also avoids the cost and disruption of 
moving23. In any case, the standard lease agreement has a clause enabling the 
delegation to terminate the contract with 3 months’ notice at any time.

39 
However, there is currently no difference between the guidance for preparing 
building files which aim to continue an existing lease and the guidance for pre-
paring building files which aim to select — when a move is needed — the best 
building among a number of options. In the first case, a comparison with alterna-
tive options is artificial and less meaningful than demonstrating that the building 
still meets the delegation’s needs in accordance with the building policy and in 
line with market rates (see Box 3). In the second case, delegations may require 
more support from headquarters to carry out a more comprehensive assessment, 
including a comparison of suitable and realistic shortlisted options.

3 When delegations intend to stay put, examining alternatives can be artificial and of 
x
o
B

limited value

The objective of the 2013 building file for Rwanda offices (see Annex II) was to justify continuing the exist-
ing rental agreement. This was clear from a mission report from headquarters annexed to the building file 
instructing the delegation to negotiate an extension to the lease agreement for the office buildings quickly 
after exploring the market as required for the purposes of a report to the Building Committee. Therefore, 
although the building file included an analysis of a shortlist of suitable, realistic options, this had limited value 
because there was no intention of moving.

 
Observations 

32

Building files rarely discuss the possibility of buying and do not 
compare it with the cost of renting

40 
Of the 30 building files examined, only five discussed the possibility of buying 
(see Figure 12), and in all cases buying was rejected. None of the building files 
examined presented a comparison of renting with buying that included a com-
parison of the estimated future costs. In March 2015, headquarters informed 
heads of delegation that, in future, the Headquarters Infrastructure Division 
will carry out the calculations to compare buying with renting24. However, the 
method used is not disclosed in the EEAS building policy. The previous building 
policy explained how to calculate the financial return on an investment as a basis 
for comparing purchasing with renting over a suggested period of 20 years25. In 
practice, rent-or-buy discussions do not demonstrate that the proposed solution 
represents better value for money (see Box 4).

24  Note from managing director 
administration and finance to 
heads of delegation of 
30 March 2015.

25  The residual value of 

purchased property is an 
important factor in this 
calculation and one which is 
difficult to estimate accurately. 
For example, the value of the 
residence in Washington DC 
purchased in 1971 for the 
equivalent of 2.4 million euro 
has trebled whilst the value of 
the office building in 
Argentina, purchased in 1992 
for the equivalent of 
1.5 million euro is estimated at 
1.6 million euro.

4 Delegations do not show that purchasing is better value for money than renting
x
o
B

In 2010-2011, when the delegation in Nepal was proposing to purchase a plot of land from the French embassy 
and to construct offices and a residence, it was not required by headquarters to demonstrate that purchasing 
and construction represented better value for money than renting.

The same occurred in Washington DC, when the delegation had the opportunity to purchase the office build-
ing in 2010. Purchasing was excluded without exploring financing options and tax advantages, even though 
ownership of the building could have improved the delegation’s presence and the additional space could 
have been used for co-location with another embassy.

In some building files, delegations do not present options in 
a comparable way

41 
A good practice found in some building files was the comparison of shortlisted 
options against the selection criteria in the form of a table. By way of illustration, 
Figure 15 is a composite table based on those found in the building files for the 
Rwanda, Guatemala and Laos offices. The allocation of points and the comments 
are for illustrative purposes only. A table such as this makes it easy to compare 
the different options in order to arrive at a balanced overall assessment. The 
table could also be extended, for example, to include the one-off costs associ-
ated with moving buildings (e.g. fitting-out and security works), running costs or 
revenue from co-location.

 
Observations 

33

5
1
e
r
u
g
i
F

Illustrative good practice example of a table comparing options

Quality criteria

Price criteria

Size criteria

Building

Option 1

Option 2

Safety and 
security 
(max 50)

Functionality 
(max 30)

Some concerns 
20

Modern building 
24

Location  
and image 
(max 20)

Good image 
16

Excellent 
38

New building 
28

In diplomatic area 
18

Option 3

Can be adapted 
25

Some concerns 
14

Outside diplomatic 
area 
10

Total quality 
points 
(max 100)

Total  
annual rental 
euro

Price per 
m2 euro

m2 total

m2  
per person  
(for offices)

60

84

49

25 000

16.67

1 500

22 000

15.71

1 400

20 000

12.5

1 600

38

35

40

Source: European Court of Auditors based on building files for offices in Rwanda, Guatemala and Laos.

42 
This approach contrasted with other building files which examined the options 
in a less readily comparable way, for example, by randomly presenting particular 
advantages and disadvantages. Delegations sometimes omit key information 
from building files such as cost per m2, or space per person for office buildings, or 
non-compliance with the space ceiling. In 8 of the 30 building files examined, the 
solution proposed to the Building Committee was not based on a sound analysis 
by the delegation (see Figure 12). Moreover, although building files often show 
the cost of the proposed solution after negotiations, they compare this with the 
cost of alternative buildings before negotiations.

 
34

26  Report on co-location, 2014, 11 

July 2014, EEAS.

27  For any building project likely 

to have significant 
implications for the budget of 
the EU (for example, 
acquisition of land and 
acquisition of buildings 
exceeding 3 million euro or 
any new building related 
contract with an annual 
charge over 750 000 euro) the 
approval of the budgetary 
authority (the European 
Parliament and the Council) is 
also required (financial 
regulation, Article 203(7)). 
A building acquisition project 
financed through a loan is also 
subject to prior approval by 
the budgetary authority 
(financial regulation, 
Article 203(8)).

Observations 

Guidance on preparing building files does not take into account 
space rented to other organisations and income generated by 
co-location

43 
The 2014 report on co-location26 explains that the EEAS does not have the 
necessary manpower to develop common standards and produce reference 
documents for co-location. Consequently, guidance on preparing building files 
(see paragraph 31) does not explain how office space rented to Member States’ 
embassies and other EU institutions and bodies should be taken into account in 
the calculation of space per person. Guidance also omits to explain how the as-
sociated income should be taken into account in calculating the cost per m2.

Some Headquarters Building Committee opinions are not 
timely or convincing

44 
In the final stage of the building-file procedure, the Headquarters Building Com-
mittee examines the delegation’s proposal and issues its opinion. The Building 
Committee’s approval is necessary before a contract can be signed27. However:

(a)  lengthy procedures prevent the signature of some contracts;

(b)  some decisions do not convincingly demonstrate that the selected solution is 

in line with market rates;

(c)  some decisions do not sufficiently take floor space into consideration.

Lengthy procedures prevent the signing of some contracts

45 
The Building Committee adopts opinions on the building files it examines. 
Some comments in building files explain that, rather than wait for lengthy EEAS 
proced ures, landlords would rent out buildings to other tenants. This point of 
view was echoed by comments in the audit survey. One respondent wrote: ‘The 
time from having identified a building until the approval from headquarters is far 
too long and landlords rent to other organisations in the meantime.’ As a conse-
quence, the approval of a building file does not necessarily lead to the signing 
of a contract. For example, although the building files for the residences in Israel 
and Sri Lanka were approved, contracts were not subsequently signed (see An-
nex II).

35

28 

It also excluded an additional 
conference room from the 
calculation, which was 
provided for in the building 
policy (see paragraph 20).

Observations 

Some decisions do not convincingly demonstrate that the selected 
solution is in line with market rates

46 
Of the 30 building files examined, seven did not contain a convincing reason for 
the Building Committee’s decision (see Figure 12). In four of these cases, this was 
because they did not demonstrate that the selected solution was in line with 
market rates. The Building Committee did not compare the cost per m2 of the 
solution proposed by the delegation with an independent source of market rates 
in any of the 30 building files examined during the audit. This meant that in those 
cases where the delegation had not demonstrated that its proposed solution was 
in line with market rates, the Building Committee did not address this weakness. 
This was the case for the offices in Togo, the residences in Mauritania and Sri 
Lanka and accommodation in Kenya (see Annex II).

Some decisions do not sufficiently take floor space into 
consideration

47 
In three of the seven building files which did not contain a convincing reason for 
the Building Committee’s decision, this was because they did not give sufficient 
consideration to the amount of office space per person and the recommended 
ceilings in the building policy (see Annex II).

(a)  In 2013, the Building Committee approved the proposed solution in the 

building file of the Jordan delegation for renting offices of 43 m2 per person 
(23 % higher than the recommended ceiling). An alternative solution was 
rejected because it was considered too small, even though it was 35 m2 per 
person, exactly in line with the ceiling, and was over 20 % cheaper (a differ-
ence of 110 000 euro per annum) than the proposed solution.

(b)  In 2014, the Building Committee approved the proposed solution in the 

building file of the Washington DC delegation for expanding office space. 
Headquarters calculated the space per person as 40 m2 (14 % higher than 
the ceiling). However, it arrived at this figure by adding 20 staff, for which 
there was no clear basis. This increase had not occurred at the time of the 
audit visit in May 2015. It also excluded the ground-floor press room from 
the calculation, although there was no reason for this in the building policy28. 
The space per person was in fact 56 m2, i.e. 60 % higher than the ceiling. The 
Washington DC delegation considered that the building policy does not give 
sufficient recognition to the increased coordination role of the EEAS in cer-
tain countries, such as the United States. However, neither the delegation nor 
the Building Committee mentioned that an exemption from the ceiling was 
necessary.

Observations 

36

(c)  The selection criteria in the 2014 building file for a new residence in Sri Lanka 
specified a building with a minimum size of 600 m2. This was inconsistent 
with the building policy in which 600 m2 is the maximum, not the minimum, 
size. The solution proposed by the delegation, and approved by the Building 
Committee, was a building of 930 m2. Headquarters did not mention that this 
exceeded the ceiling of 600 m2 by 55 % and that an exemption was necessary.

Section III — Information on the suitability of 
buildings is not reliable and is not used for planning, 
which is too short term and particularly weak for 
owned properties

48 
The suitability of delegation buildings depends not only on their initial selection, 
but also on the way the EEAS ensures they continue to meet needs and provide 
value for money. The audit therefore examined whether the EEAS monitors 
the suitability of buildings once they have been selected, and plans necessary 
changes and maintenance to ensure they continue to meet needs and provide 
value for money.

Central monitoring systems do not provide reliable basic 
information on the suitability of all delegation buildings

Site visits assess whether buildings meet the needs of delegations, 
but do not identify all shortfalls

49 
Headquarters assesses delegation buildings through the following mechanisms 
to ensure they continue to meet the needs of delegations.

(a)  The Delegation Support and Evaluation Service carries out evaluations of 

delegations on average every 4 years, which include an assessment of offices 
and residences.

(b)  On behalf of the EEAS, an external contractor carried out health and safety 
inspections of nearly all offices and residences of delegations between 2010 
and 2015.

(c)  The regional security officer carries out security assessments of the delega-

tion’s buildings at least once a year.

Observations 

37

50 
These assessments of buildings recommend corrective action (for example, set-
ting up security systems, carrying out works or moving premises) to remedy the 
shortfalls identified. However, these assessments do not identify all shortfalls. For 
example, the November 2013 report of the regional security officer in Nepal did 
not address the fundamental issue of how to provide the same level of security 
for garages and prefabricated cabins as for the main building (see Box 2).

The monitoring of space per person in office buildings does not 
take account of all relevant factors

51 
The EEAS building policy recommends that delegation offices should have 
a maximum size of 35 m2 per person (see paragraph 20). The building policy pro-
vides for certain areas to be excluded from the calculation. However, headquar-
ters cannot accurately identify all office buildings for which there is too much 
or too little space, because it does not separately identify the following surface 
areas when monitoring the space per person:

(a)  office space rented to another organisation;

(b)  an additional conference room when necessary to meet the needs of the 

presidency function under the Lisbon Treaty;

(c)  space used by temporary trainees and seconded national experts, when 

a delegation employs such staff regularly.

52 
The monitoring system does not keep track of the buildings for which exemp-
tions concerning the surface area ceilings have been granted. It does not there-
fore monitor whether such exemptions are still justified.

Observations 

38

The EEAS does not monitor whether rents of office buildings and 
residences remain in line with market rates

53 
Headquarters has the necessary information to calculate the cost per m2 for each 
office building and residence. However, it does not regularly compare these costs 
per m2 with market rates to identify significant differences. Such an exercise 
was carried out for staff accommodation in 2014: it found significant differences 
between some rental ceilings and market prices. Similarly, headquarters does not 
monitor charges to co-located organisations to ensure they recover full costs.

The EEAS does not reliably record the results of its monitoring in 
its information systems

54 
Before the creation of the EEAS, the European Commission had developed an in-
formation system for managing delegation real estate: ImmoGest. This buildings 
information system, in use since 2008, has the potential to provide information to 
feed into the planning process in line with best practice. However, more than half 
of the respondents to the audit survey considered that ImmoGest is not useful for 
managing buildings (see Figure 16).

6
1
e
r
u
g
i
F

Opinions on ImmoGest

s
t
n
e
d
n
o
p
s
e
R

100 %

90 %

80 %

70 %

60 %

50 %

40 %

30 %

20 %

10 %

0 %

Useful for managing
 buildings

Easy to use

Complete

Reliable

Source: Audit survey of heads of administration in EU delegations.

Disagree
Agree

 
Observations 

39

55 
Each delegation is responsible for entering information on its office buildings, 
residence and staff accommodation in ImmoGest. However, around 35 % of office 
buildings and residences were not recorded in ImmoGest in 2014. More than half 
of the respondents to the audit survey considered that the system is not easy to 
use and more than 30 % of respondents considered that the data are not com-
plete or reliable (see Figure 16).

56 
The following findings from the audit visits to delegations reinforced the results 
of the survey.

(a)  The ImmoGest system is not user friendly. It has bugs which have not been 
fixed and in Nepal, for example, the system functions slowly and is some-
times inaccessible.

(b)  The information is not linked to business processes and the ImmoGest system 
does not, for example, provide practical reminders when rental payments are 
due or when lease end dates are approaching.

(c)  Headquarters does not make effective use of the information entered by del-
egations. For example, although ImmoGest contains information on building 
rents, headquarters does not use this information to compile the budget.

(d)  Most of the information describing staff accommodation where costs are 

reimbursed serves no purpose.

(e)  Because the system is not used to perform practical functions, delegations 

do not regularly update data in the system. Moreover, there are a number of 
mistakes in the data. For example, some buildings are recorded in ImmoGest 
as owned when they are rented.

Observations 

40

57 
Instead of using ImmoGest, the EEAS Infrastructure Division maintains a central 
Excel spreadsheet containing information on all delegation offices and resi-
dences, including information obtained through site visits. However, some of the 
information in the spreadsheet is also incomplete or inaccurate. For example:

(a)  The condition of unoccupied buildings is not recorded.

(b)  There are no data on the condition of 53 residences (38 %).

(c)  The office space of some office buildings is inaccurate. For example, office 
space in the office building in Nepal was recorded in the spreadsheet as 
1 225 m2, but the delegation confirmed it was 947 m2.

(d)  The condition of some office buildings and residences is not consistent with 

the assessment. For example, the health and safety report assessed the office 
building in Nepal as 4 out of 5, but the spreadsheet recorded 3 out of 5. The 
condition of the residence in Washington DC was assessed as 5 out of 5, even 
though major maintenance work is needed.

58 
The EEAS Infrastructure Division maintains a separate inventory of owned prop-
erties. Some of the information in this inventory is also inaccurate or incomplete. 
For example, in 2014, the residence owned in Zimbabwe was recorded as offices, 
the former residence in Tanzania was not included and the inventory did not 
indicate which buildings were still in use.

59 
EEAS headquarters does not, therefore, have reliable basic information on all 
office buildings and residences, although such information is essential to feed 
into the planning process by identifying where changes are necessary. At the end 
of 2015, the EEAS was taking steps to make ImmoGest more relevant and user 
friendly.

41

29  For example, headquarters did 
not prioritise or estimate the 
cost of recommendations 
following the health and 
safety inspection to Nepal of 
November 2012. Headquarters 
did not follow up in any way 
the recommendations 
regarding the residence 
(which the delegation did not 
implement).

30  For example, the 2012 

evaluation of the delegation in 
Tanzania found that the office 
premises were too small and 
had reached their capacity. 
The delegation subsequently 
rented part of the fourth floor 
from the Netherlands embassy 
from April 2013.

Observations 

Planning makes insufficient use of available information and 
is short term

Available relevant information is not used to create plans

60 
The lack of reliable basic information on delegation buildings and the weak-
nesses in central monitoring systems (see paragraphs 50 to 59) are obstacles to 
effective planning by headquarters. Moreover, headquarters does not make ef-
fective use of available information to draw up plans for maintaining or changing 
buildings. For example:

(a)  Headquarters does not prioritise, budget for or integrate into maintenance 

plans the recommendations from on-site assessments which delegations do 
not have the resources to implement29. Delegations implement some recom-
mendations from assessments regarding their buildings to address short-
falls30, but not others. Respondents to the audit survey explained that delega-
tions do not implement many recommendations from assessments because 
of the lack of human and financial resources, and local constraints. Health 
and safety recommendations, for example, are based on EU legislation, 
regardless of local conditions. One respondent summed up the difficulties as 
follows: ‘Lack of human resources, lack of budget and general local condi-
tions and procurement issues substantially undermine scheduled implemen-
tation.’ The delegation in Nepal did not have the resources to rectify certain 
issues repeatedly highlighted in reports by the regional security officer.

(b)  Although headquarters has information on buildings in poor condition 
or with too much or too little space, it does not fully use it to prioritise 
where changes are the most needed, and to plan the related maintenance 
works, co-location or moves. This results, for example, in the deterioration 
of the condition of office buildings, especially those acquired before 2000 
(see Figure 4 and paragraph 23). The audit survey showed that 42 % of 
respondents realised that their office space per person exceeded the recom-
mended maximum. However, 47 % of these were taking no action to reduce 
office space and align it with the ceiling. In Turkey, even though office space 
per person exceeded the recommended maximum, there was insufficient 
space due to the unpractical floor layout (see Box 5).

Observations 

42

(c)  Headquarters does not plan how to dispose of owned buildings no longer 
occupied by delegations. There are no plans for most of the 20 % of owned 
buildings which are not used by delegations (see paragraph 25). As an exam-
ple of good practice, when German embassies move to a new building, they 
are required to plan how to dispose of the former building, if owned, before 
buying or renting something else.

(d)  Headquarters does not plan the review of contributions paid by co-locating 
organisations. In 2013 the EEAS required delegations to charge for common 
areas (see paragraph 27(c)). The EEAS has also recognised that hosted organ-
isations should contribute to the administrative burden. However, the EEAS 
has not planned which existing agreements to review as a priority.

5 Managing office space in the delegation in Turkey
x
o
B

The surface area of the delegation offices in Turkey was 5 500 m² for 150 staff, which is equivalent to 37 m2 per 
person. Although this exceeds the ceiling of 35 m2 per person, the October 2008 evaluation report found that 
the unpractical floor layout of the building resulted in insufficient office space for staff.

In 2015, the project to rearrange office space within the current building and to increase office sharing has 
released some space and reduced the space per person to 34 m2.

Planning focuses on addressing short-term needs

61 
The EEAS Infrastructure Division produces planning documents which incorpo-
rate elements of sound practice. However, these planning documents focus on 
short-term needs (around 2 years) and building projects currently being prepared 
or explored. For example:

(a)  The 2014 and 2015 annual working documents on the EEAS building policy, 

which describe projects under preparation and exploration, show no planned 
changes in office space after 2015. They state that changes in surface areas 
and locations will follow political decisions and the availability of resources.

 
Observations 

(b)  A 2014 note to heads of delegation on the development of the building poli-
cy for 2015 and 2016 identified building projects planned for the next 2 years 
and asked heads of delegation to keep an eye on opportunities to purchase 
in case the EEAS ends the year with a budgetary surplus which needs to be 
committed quickly.

(c)  There is a medium-term plan which identifies purchases, works and rent 

renewals for the 2014 to 2020 period. However, it only shows planned build-
ing purchases and construction projects which address pressing needs. The 
EEAS does not sufficiently establish priorities for changing premises, closing 
delegations, merging delegations, opening new delegations or changing the 
size of delegations until 202031. This is partly because the EEAS does not make 
sufficient use of available information (see paragraph 60), but also because 
the European Commission only provided the EEAS with its delegation staff-
ing proposals32 for the next 2 years.33

62 
Because the EEAS planning process is reactive and focuses on projects that ad-
dress current needs, there is a risk that major projects are not built into plans 
 until they become urgent. A medium-term plan (around 7 years) for delegation 
buildings would reflect best practice in other Member States and would enable 
the EEAS Infrastructure Division to play a more strategic role. Unforeseen political 
developments may result in a change in the level of the EU presence in certain 
countries and necessitate a reactive approach to planning certain building pro-
jects. Nevertheless, the existence of a medium-term plan would enable the EEAS 
Infrastructure Division clearly to show strategic policymakers the impact of these 
unforeseen changes in terms of adjustments to the plan.

43

31  The EEAS 2014 report on 

co-location recognises that 
medium-term plans should 
include this information.

32  Since the creation of the EEAS, 
EU delegations have consisted 
of two types of staff: 1 900 
EEAS staff and 3 400 European 
Commission staff. In order to 
take account of the European 
Commission’s plans regarding 
the number of its staff working 
in delegations, the EEAS 
consults with the Commission 
on decisions regarding 
resource allocations in 
delegations through the 
‘EUDEL mechanism’.

33  A ‘regionalisation approach’, 

currently under consideration 
at DG International 
Cooperation and 
Development, may result in 
the medium term in the need 
to obtain additional space in 
delegations playing a role as 
regional centres, and to 
reduce staffing levels in other 
delegations.

44

34  2014 working document on 
the EEAS building policy.

35  The 2012 revisions to the 
financial regulation 
(Article 203(8)) enable the 
institutions to borrow money 
to purchase buildings.

Observations 

Planning systems for owned properties are particularly weak

The EEAS has a long-term objective of purchasing more delegation 
office premises and arranged terms for borrowing up to 
200 million euro …

63 
Currently less than 20 % of delegation office buildings and residences are owned. 
However, the 2014 and 2015 working documents on the EEAS building policy 
stated that it would often be more economical to purchase rather than to rent 
buildings. Over 80 % of respondents to the audit survey considered that purchas-
ing delegation buildings is better value for money than renting.

64 
It is the long-term objective of the EEAS to purchase more delegation office 
premises. An obstacle to this goal was the limited budget available to the EEAS 
for the purchase or construction of new delegation buildings (in the order of 
5 million euro per year 34). The audit survey found that in half of the cases where 
the delegation wanted to purchase offices or the residence, this had been 
prevented by a lack of funds. However, in 2015, under the new provisions in the 
financial regulation35, the EEAS arranged terms for borrowing up to 200 mil-
lion euro over 4 years to buy real estate.

… but it has not set up systems to manage owned properties 
effectively

65 
The 2015 guidelines and procedures for buying real estate in third countries 
state that priority should be given to the purchase of office buildings rather than 
residences. However, ownership offers less flexibility than renting (see paragraph 
9(a)). The reduced flexibility of ownership is less of an issue for residences than 
for offices, because they do not have to respond to changes in staff numbers. 
Moreover, because of their smaller size, they are easier to buy, maintain (see para-
graphs 15 and 24) and sell than offices.

45

36  Note from EEAS headquarters 
to heads of delegation, 
20 January 2015: Budget 
2015 — Impact of the falling 
value of the euro for 
expenditure in delegations.

Observations 

66 
When renting buildings, the EEAS benefits from external expertise in property 
management. Whilst lack of funds is no longer a constraint to its long-term 
objective of increased ownership, the EEAS has limited experience in owning 
buildings, lacks property-management expertise and has not established effect-
ive systems for buying, maintaining and selling buildings. For example:

(a)  The system for deciding whether it would be better to buy or rent should be 

improved (see paragraph 40).

(b)  There is no property maintenance strategy or effective system to maintain 

owned property. This results in the deterioration of the condition of buildings 
(see paragraph 23). Over one third of respondents to the audit survey consid-
ered that headquarters support for building maintenance is inadequate (see 
Figure 13). Embassies of Member States (for example, Denmark, Germany, the 
Netherlands, Sweden and the United Kingdom) emphasised the importance 
of planning for, and investing in, the maintenance of owned buildings. The 
delegation office building in Tanzania, for example, which is owned together 
with Germany, the Netherlands and the United Kingdom, is maintained in 
good condition.

(c)  The lack of a mechanism for managing fluctuations in exchange rates may 

prevent delegations from carrying out planned works projects36. The embas-
sy of the Netherlands explained, in contrast, how their exchange rate for the 
year is fixed centrally in order to protect operations such as planned mainten-
ance work from exchange-rate fluctuations. Any exchange-rate gain or loss is 
borne by their headquarters.

(d)  There are disincentives and obstacles to the disposal of surplus property, 
resulting in the retention of buildings which are no longer used (see para-
graphs 25 and 60(c)). For example, the funds received from the sale of owned 
properties are not available to the EEAS Infrastructure Division to purchase 
a replacement building. Furthermore, the EEAS does not own certain prem-
ises but was merely given the right of usage by national authorities.

(e)  The EEAS guidance on charging tenants for co-location does not cover 
owned properties. Consequently, some charges do not recover full 
costs because they do not reflect the rental value of the building (see 
paragraph 27(b)).

Conclusions and 
recommendations

46

67 
To contribute effectively to achieving the EU’s objectives in foreign policy, trade 
and development cooperation, the buildings provided by the EEAS have to meet 
the needs of delegations. They should also provide good value for money. The 
following paragraphs set out the main conclusions of the Court’s audit, followed 
by relevant recommendations. The implementation of the recommendations 
should begin immediately and should be completed by the end of 2017.

68 
Delegation buildings, whether they are office buildings, residences of heads of 
delegation or staff accommodation, generally meet the needs of delegations, 
although the building policy omits some objectives for office buildings (see para-
graphs 8 to 19). However, buildings do not provide best value for money because:

(a)  space in most office buildings, and some residences, exceeds the ceilings in 

the building policy (see paragraphs 20 to 22);

(b)  the EEAS keeps owned buildings which it no longer uses (see paragraphs 23 

to 25);

(c)  where delegations share their office premises with EU Member States or EU 
institutions or bodies, some charges to hosted organisations do not recover 
full costs (see paragraphs 26 and 27).

Recommendation 1 — Complete objectives for office 
buildings

The EEAS should include environmental factors, access for disabled people and 
flexibility as objectives in the building policy for office buildings.

Recommendation 2 — Ensure charges to co-located 
organisations recover full costs

The EEAS should ensure charges paid by EU Member States or other EU institu-
tions or bodies hosted in delegation office buildings are consistent and recover 
full costs. For example, it should charge all tenants for use of common areas 
and for administrative support. Where the offices are owned, it should include 
a charge to reflect the rental value of the building.

The method for calculating these charges should also be applied to buildings 
owned by the EEAS, but no longer occupied by a delegation and rented to other 
organisations.

Conclusions and recommendations 

47

69 
The suitability of delegation buildings depends on the way they were selected. It 
also depends on the systems used by the EEAS to ensure that buildings continue 
to meet needs and to take corrective action where necessary. Annex III sum-
marises the weaknesses in the systems for selecting buildings, monitoring their 
suitability and planning future changes.

70 
Before renting (or renewing a rental agreement) or buying, the delegation con-
cerned submits a building file to headquarters for examination and approval. 
This is an example of good practice (see paragraphs 30 and 31). However, there 
is a risk that the EEAS may not select the right buildings because there are some 
weaknesses when the building-file procedure is applied in practice.

(a)  Delegations have insufficient expertise to identify suitable solutions (see 

paragraphs 32 to 35).

(b)  There are weaknesses in the technical and financial analysis carried out by 

delegations to compare options (see paragraphs 36 to 43).

(c)  Final decisions made by the Headquarters Building Committee are some-

times not timely or convincing (see paragraphs 44 to 47).

Recommendation 3 — Strengthen the application of the 
procedure for selecting buildings

The EEAS should strengthen the application of the building-file procedure for 
selecting buildings.

 ο

Produce a building file for all new contracts.

 ο

Introduce a streamlined building file for rent renewals. Such building files 
could be limited to demonstrating that the proposed solution continues to 
meet needs in accordance with the building policy and remains in line with 
market rates.

 ο Compare options in the form of a table to arrive at a sound and balanced 

overall technical and financial assessment which demonstrates that the se-
lected solution is in line with market rates and gives sufficient consideration 
to floor space.

 ο

 ο

Produce guidance on how to take into account space rented to other organ-
isations and income generated by co-location.

Take decisions promptly to minimise the risk that buildings may no longer be 
available.

Conclusions and recommendations 

48

71 
Once the EEAS has selected buildings, it regularly assesses whether they continue 
to meet the needs of delegations through site visits, but does not identify all 
shortfalls (see paragraphs 49 and 50). The EEAS does not monitor the space per 
person in office buildings against the criteria of the building policy (see para-
graphs 51 and 52); nor does it monitor that rents of office buildings and residen-
ces remain in line with market rates or that charges to co-located organisations 
recover full costs (see paragraph 53). Furthermore, the EEAS does not reliably 
record the results of its monitoring in its information systems (see paragraphs 54 
to 59).

Recommendation 4 — Verify market rates

EEAS headquarters should use an independent source of information to verify 
market rates for office buildings and residences, and regularly monitor the con-
sistency of rents with market rates. This monitoring could trigger the renegotia-
tion of a lease or the search for a new building for rent or purchase.

Recommendation 5 — Improve the real-estate management 
information system

The EEAS should improve its real-estate management information system, so that 
it has more reliable and relevant information to feed into the planning process. 
This information should focus on office buildings, residences, staff accommoda-
tion provided by the delegation and owned buildings no longer occupied by 
dele gations. Information on office space per person should be refined by separ-
ately identifying office space rented to other organisations, conference rooms 
necessary to meet the needs of the presidency function and space used by train-
ees and seconded national experts.

72 
The lack of reliable basic information on delegation buildings is an obstacle to 
effective planning of necessary changes by headquarters. Moreover:

(a)  headquarters does not make effective use of the information which is avail-
able to draw up plans for taking corrective action (see paragraph 60);

(b)  planning focuses on addressing short-term needs (see paragraphs 61 

and 62);

(c)  Although the EEAS has a long-term objective of purchasing more delegation 

office premises and arranged terms for borrowing up to 200 million euro it 
has not set up systems to manage its owned properties effectively (see para-
graphs 63 to 66).

Conclusions and recommendations 

49

Recommendation 6 — Reinforce real-estate management 
expertise

The EEAS should reinforce expertise in real-estate management at headquar-
ters (e.g. through training or recruiting staff with appropriate skills) in order to 
develop a more strategic approach, improve planning, strengthen support for 
delegations and realise significant savings from improved management of space.

Recommendation 7 — Establish medium-term plans

The EEAS should establish rolling medium-term plans for its delegation buildings, 
covering around 7 years. These plans should include priorities for rentals, pur-
chases, sales, modifications and maintenance. They should use available informa-
tion on floor space and building condition in order to plan, for the medium term, 
how to comply with the criteria in the building policy. For example, they should 
plan to align office space more closely with the number of staff, and use surplus 
space for co-location where appropriate.

Recommendation 8 — Identify where purchasing offers 
better value for money and manage owned buildings 
effectively

The EEAS should enhance systems to identify where purchasing offers better 
value for money and to manage owned buildings effectively.

 ο Apply a tool (e.g. for use in rent-or-buy assessments in building files) and only 
purchase buildings where this offers better value for money than renting. 
The EEAS should estimate costs and revenue for the whole life cycle of the 
building, including financing and maintenance costs. In this renting versus 
buying comparison, the EEAS should also take into account the residual value 
of the building, the discount rate and risk factors such as the political or eco-
nomic instability of the country and the instability of staffing levels for office 
buildings.

 ο

Plan major purchases, giving priority to buildings (whether offices or resi-
dences) where purchasing offers best value for money.

 ο Develop a strategy to maintain owned property, linked with recommenda-

tions of health and safety inspections.

 ο

Protect the buildings-maintenance budget from exchange-rate fluctuations

 ο

Plan how to dispose of surplus owned properties before buying or renting 
something else.

Conclusions and recommendations 

50

This Report was adopted by Chamber IV, headed by Mr Milan Martin CVIKL, Member 
of the Court of Auditors, in Luxembourg at its meeting of 16 February 2016.

For the Court of Auditors

Vítor Manuel da SILVA CALDEIRA
President

 
 
 
Annexes

51

I
x
e
n
n
A

Co-location with EU Member States in EU delegations

Delegation

EU Member States

Afghanistan

Azerbaijan

Belarus

Colombia

East Timor

Ethiopia

Georgia

Honduras

Iraq

Mauritania

Myanmar

Nigeria

South Sudan

Tanzania

Lithuania

Spain, Croatia

Austria

Finland, Czech Republic

France

Luxembourg

Slovakia

France

United Kingdom

United Kingdom

Spain

Italy, Netherlands, Greece, France, Germany, Austria, Slovakia

Denmark, France, Germany, Italy, Netherlands, Spain, United Kingdom

Finland, Germany, Netherlands, United Kingdom (co-ownership)

Turkey (Gaziantep)

France, Denmark, Germany

Vietnam

Yemen

Finland

Spain

Source: 2015 working document on the EEAS building policy.

 
Annex II 

52

I
I
x
e
n
n
A

Details of review of 30 building files

File ref

Delegation

Building

Proposed 
solution 
involves a 
change of 
building

1. Exploration 
of market

2. Discussion 
whether to 
rent or buy

3. Shortlist 
of more than 
one suitable, 
realistic 
option

4. Delegation’s 
proposed solution 
based on sound 
technical and 
financial analysis

5. Convincing 
reason for 
HQ Building 
Committee’s 
decision

2013.01

2013.11

2013.18

2013.19

2013.20

2013.27

2013.36

2013.42

2013.46

2013.48

2013.52

2013.56

2013.70

2013.73

2013.75

2013.90

2013.93

2014.01

2014.07

2014.10

2014.15

2014.16

2014.26

2014.27

2014.31

2014.45

2014.48

2014.55

2014.61

Pakistan

Residence

Angola

India

Uganda

Rwanda

Jordan

Hong Kong 

Guatemala

Offices

Residence

Offices

Offices

Offices

Offices

Offices

Mauritania

Residence

Libya

Kenya

Kenya

Offices 

Offices

Accomm.

Myanmar

Offices

Peru

Angola

China

Gabon

Pakistan

Laos

Residence

Residence

Offices

Offices

Offices

Offices

Côte d’Ivoire

Accomm.

Colombia

Fiji

India

Israel

Vietnam

Togo

Sri Lanka

Sri Lanka

Offices

Offices

Offices

Residence

Offices

Offices

Offices

Offices

Residence

Timor-Leste

Accomm.

2014.35

United States

No

Yes

Yes

No

No

No

No

No

No

Yes

No

Yes

Yes

Yes

Yes

No

Yes

No

Yes

Yes

No

Yes

Yes

Yes

Yes

No

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

Yes

Yes

Yes

Yes

No

Yes

Yes

Yes

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

Yes

No

Yes

Yes

No

Yes

Yes

No

No

No

No

No

No

No

No

No

No

Yes

Yes

Yes

Yes

Yes

Yes

No

Yes

No

Yes

Yes

No

Yes

No

No

No

Yes

Yes

No

No

No

Yes

Yes

No

No

Yes

No

No

Yes

Yes

No

Yes

Yes

No

Yes

Yes

No

Yes

Yes

No

Yes

Yes

Yes

Yes

Yes

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

Yes

No

Yes

Yes

Yes

Yes

Yes

Yes

No

Yes

Yes

No

Yes

Yes

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

Yes

No

No

Source: European Court of Auditors based on review of 30 building files.

 
Annex III 

I
I
I
x
e
n
n
A

Reasons why delegation buildings do not provide best value for money

Causes

Selection procedure

53

Eﬀect

Lack of suitable buildings on the local market

Lack of suitable options when searching for new buildings

Lack of expertise in delegations

Until 2013, higher ceiling for oﬃce space

Building ﬁles and decisions do not suﬃciently 
take into consideration ﬂoor space

Exemptions from ceilings are granted 
without being explicitly justiﬁed

Some surface areas not excluded
from calculation as provided for

Inaccurate identiﬁcation of oﬃce buildings
where too much or too little space

No checks on exemptions from ceilings
(Are they still justified?)

 Information on ﬂoor space incomplete and unreliable

All available information  on excessive ﬂoor space not 
used to plan corrective actions (co-location, moves…)

No medium-term staﬃng plans for delegations

Monitoring suitability

Planning necessary changes

Floor space often exceeds
the ceiling.

The system for deciding where it is better to buy or rent is weak

Selection procedure

Condition of unoccupied
buildings not monitored

Lack of monitoring of
condition of residences

Inventory of owned properties  incomplete and unreliable

No property maintenance strategy

Lack of medium-term maintenance plans

Fluctuations in exchange rates prevent planned works projects

No incentive/requirement to sell unsuitable buildings

No disposal plans for most of the owned buildings no longer used

Some buildings are acquired under special conditions
which make their disposal difficult

Monitoring suitability

Planning necessary changes

Selection procedure

No guidance on how to take into account space rented to 
other organisations and income generated by co-location

Lack of monitoring of agreements
with co-located organisations

No guidance on how to calculate ﬁnancial
contribution if delegation owns the building

No plans on which existing agreements
have to be revised as a priority

No guidance on how to calculate
contribution to administrative costs

Monitoring suitability

Planning necessary changes

Source: European Court of Auditors.

20% of owned buildings
not used by EEAS

Some organisations hosted in
Delegation buildings do not pay
their fair share of the costs

 
 
 
 
 
Reply of  
the EEAS

Executive summary

54

I
The EEAS agrees that there are some shortcomings in its management of infrastructure in EU delegations, and work 
is in hand in a number of areas to address these. Yet the complexity and political sensitivity of managing 180 office 
buildings and 140 official residences in 138 countries throughout the world, each with its own specific legal system 
and property market, has to be underlined.

Given the acute, well-known budget constraints and the commitment on staff cuts, this huge portfolio is managed 
by a HQ team of only 13 staff backed by local administrative support at the level of delegations. Unfortunately, it has 
not been possible to accompany the significant expansion of the delegation network over recent years with a com-
mensurate increase in the number of staff devoted to this task, which has been a management challenge.

We also agree that the existing tool for real-estate inventory management is in need of replacement. A new sys-
tem will be fully implemented at the end of 2016. This will allow the EEAS to develop a more effective system for 
advance planning and programming of expenditure.

III
Regarding the space in delegations’ buildings, it should be noted that in 2013 the guidelines for maximum office 
space per person were reduced from 42 m² to 35 m² as a general rule, with the possibility of additional space for 
specific needs such as meeting rooms for meetings with Member States. These new guidelines apply for all new 
acquisitions, but it will take some time for the average to come down towards the new target. In cases where del-
egations have spare capacity, we actively seek possibilities for co-location with Member State embassies or other EU 
bodies.

It is also true that some residences for EU heads of delegation exceed our normal ceiling of 600 m², even if the 
overall average size is 461 m² of useable space. In five of these cases, the residences are owned by the EU, but in the 
others we will ask the delegations to explore alternatives when the present lease contracts expire.

Regarding the owned buildings, there are indeed a number of properties that are owned by the EEAS that are no 
longer used, either because of the security environment or other local conditions. The relevant delegations have 
been asked to sell these properties, but this can be a lengthy and politically sensitive process for several reasons 
explained in the reply of the EEAS.

Reply of the EEAS 

Observations

55

09 (b) Environmental impact
The EEAS encourages and supports eco-friendly projects primarily for owner-occupied premises. In case of rented 
premises the necessary investment must be amortised within the expected, normally short, duration of the lease 
contract.

For example, in 2014 the EEAS approved the installation of solar panels on the newly owned office building in Cape 
Verde. Likewise, the 2016 renovation project of our offices in Mexico will include eco-friendly features.

In view of the workload it entails the EMAS system has not yet been adopted. However, efforts will be made to 
enhance awareness of the environmental impact of the buildings of delegations.

09 (c) Accessibility for disabled people
The EEAS recognises that only a small number of EU delegations are fully accessible to disabled people. According 
to a health and safety survey in September 2014, only seven delegations were fully compliant, and a further 16 del-
egations could be made accessible to people with reduced mobility with relatively minor adaptations.

In addition, where technically and financially possible and where required by local legislation, adaptations of offices 
to improve the accessibility for disabled people are systematically considered. Finally, access for those with disabil-
ities will be systematically assessed for new buildings.

10
The India and Egypt delegations moved in 2014/2015 and the Sri Lanka delegation moved in January 2016. Possible 
alternatives have already been analysed for Senegal but it has not yet been possible to identify an appropriate one.

11
The survey provides interesting qualitative insights into the views of respondents on the working environment in 
delegation offices. However, the results may reflect the differing circumstances of each respondent.

14
As general remarks:

—  the delegation’s guide states that ‘local building’ tradition may mean that this 600 m² limit cannot always be 

respected;

—  the EEAS allows some flexibility on the calculation method for surface areas of buildings, taking account of local 

practice;

—  having less space than most embassy residences is a positive point, moreover this difference can be explained 

for historical reasons.

The average usable floor area of residences is now 461 m².

Reply of the EEAS 

56

20
(1)  The EEAS has allowed some flexibility on how to calculate the surface area of the buildings rented or owned by 
the EEAS in the light of local practice. This can therefore lead to difficulties in interpreting aggregate figures.

(2)  Delegations have been instructed to give due consideration to the amount of office space per staff member. Any 
deviation from the buildings policy has to be justified. It will take some time for the average to come down towards 
the new capacity.

In case of excess space, co-location with Member State embassies or other EU bodies is actively pursued. However, 
co-location cannot always be implemented from one day to the next.

(3)  In case of reduction in staff, it is not always possible or cost-effective to move immediately to a smaller building. 
The cost of the move and the cost of the securing of the new buildings may be higher than the saving expected 
from the reduction of space.

(4)  In some case, it is not possible to rent part of a floor only.

(5)  It is not cost-effective to terminate an existing lease contract of an office with excess space while the rent at cur-

rent market prices for smaller offices would be the same or higher.

(6)  In some cases, the number or the size of meeting rooms/conference rooms required for the fulfilment of the role 
and responsibilities of EU delegations under the Lisbon Treaty are increasing significantly the ratio of space per 
person. This is for example the case for:

  —  United States (Washington) — 5 458m² of usable floor space, 89 staff, 55 m²/staff member (co-location 

deducted);

  —  United States (New York) — 4 217m² of usable floor space, 57 staff, 74m²/staff member;

  —  Switzerland (Geneva — delegation to UN) — 2 500m² of usable floor space, 25 staff, 100 m²/staff member.

21
Although mathematically correct, the figure of price for excess square metres in footnote 16 may vary depending on 
where the reductions in space occur, as these prices differ significantly between countries.

In addition, investments (security and infrastructure works) made in office buildings need to be offset against the 
potential aforementioned savings.

22
It is true that some residences exceed our ceiling of 600 m². At the beginning of 2016, 26 residences (18 %) exceeded 
the ceiling of 600m². In five of these cases, the residences are owned by the EU. The other delegations will be asked 
to explore alternatives when the present lease contract expires.

 
Reply of the EEAS 

57

25
There are indeed a number of properties that are owned by the EEAS that are no longer used, either because of the 
security environment or other local conditions. The relevant delegations have been asked to sell these properties, 
but this can be a lengthy and politically sensitive process.

More specifically on:

—  The Gambia: The EU had to leave the offices end of 2003 after 18 years of occupation, due to the presence of 

asbestos. These offices were under a long-term lease contract of 99 years with the government of The Gambia 
with a provision stipulating that offices must be handed over refurbished. Under such circumstances it was 
financially more advantageous to keep the offices. In May 2014 it was decided to reopen negotiations with local 
authorities for the disposal of the offices in the present conditions before the end of the long lease. This nego-
tiation will resume with the arrival of a new head of delegation.

—  Botswana: Offices were acquired in 1987. In 2003, these offices became too small and the delegation had to 

relocate. However, at that time it was decided to keep the premises since the land is located in a prime location, 
and to investigate the feasibility of projects such as the construction of new offices or accommodations on this 
plot. None of the projects have materialised so far, mainly for budgetary reasons. Recently, the delegation was 
invited again to launch a feasibility study for the construction of new offices on the plot of land.

—  South Africa: The residence was auctioned but the price proposed was far too low. The delegation has been 

instructed to reconsider the sale.

—  Tanzania: The Delegation does not have any title of ownership for the houses, among which the former resi-

dence, are located outside the areas recommended by the regional security officer. Following instructions 
from EEAS HQ of 2013, the delegation is investigating options with local authorities to return these houses. The 
 houses have been valued at ~ 1.8 million euro by the Tanzania Building Agency. The Ministry of Foreign Affairs 
confirmed the principle of compensation.

27
A revision of the co-location agreements with DG Humanitarian Aid and Civil Protection (ECHO) and the EIB is under 
discussion. The intention is to harmonise the way it is calculated for all the ECHO and EIB co-locations. New frame-
work memoranda of understanding should be signed in 2016.

Old memoranda of understanding should also be completely revised and adapted to the full cost recovery policy.

32
Discussion of whether to rent or buy was not useful at the time, as it was difficult to buy as there were limited 
budget ary appropriations until 2015.

The ability to draw up a shortlist depends on the local market. It is not always possible to have more than one realis-
tic option.

Reply of the EEAS 

58

33
The EEAS recognises that not all delegations have sufficient expertise to manage building projects.

The EEAS also agrees that ideally there should be more capacity in the relevant division in HQ to support delega-
tions on infrastructure projects including additional site visits.

Given the acute, well-known budget constraints and the inevitability of further staff cuts, this huge portfolio is man-
aged by an HQ team of only 13 staff backed by local administrative support at the level of delegations. Unfortun-
ately, it has not been possible to accompany the significant expansion of the delegation network over recent years 
with a commensurate increase in the number of staff devoted to this task.

The regionalisation of the administration of the delegation will also constitute an answer to this problem as special-
ised staff in the regionalised centre will be able to deal with several delegations buildings at the same time.

35
Nepal has since been visited three times: in April 2014, in May 2015 and in November 2015. The EEAS unfortunately 
cannot match all Member States in term of the resources available in HQ to support delegations with buildings 
projects.

36
See detailed comments 39 and 40.

37
These cases are quite exceptional and are mainly due to a misinterpretation of the rules to be applied by the head 
of administration or the head of delegation. The new delegation’s guide now provides clearer/more user-friendly 
guidelines.

39
To demonstrate that the building still meets the delegation’s needs in accordance with the building policy and in 
line with market rates can only be done with a market survey.

With the result of the market survey, the delegations may also have good arguments to negotiate a better deal with 
the landlord of the building which is occupied by the delegation.

Procedures for building contracts are regulated by the financial regulation applicable to the general budget of the 
Union.

Any real-estate transaction, which includes the renewal of existing lease, should be decided after a real-estate mar-
ket prospection.

The EEAS is ready to explore scope for a streamlined building file for rent renewals, subject to the constraints of the 
financial regulation.

Reply of the EEAS 

59

40
Until very recently, the use of the limited resources for delegation infrastructure has been a significant obstacle to 
the purchase of premises. Now, the EEAS agrees that with the 200 million euro facility the purchase of buildings has 
become a realistic option to renting. The relative costs/benefits of purchase and renting will now be a standard ele-
ment in building files. Guidelines have been circulated to the delegations to this effect.

Headquarters will calculate the financial benefit of buying compared to renting according to standard theories of 
financial management or corporate finance (e.g. NPV methodology). This is not included in the delegation’s guide as 
this calculation will be done by the HQ.

Appropriate financial justifications have also to be provided to the budgetary authority in case of a purchase 
financed with a loan.

For Nepal, there was no budget available at that time.

For Washington, the building to be bought was too big for the needs of the delegation. Furthermore it was occu-
pied by other tenants. Should the EEAS have bought this building, it would have meant that the delegation would 
have had to manage lease contracts with other occupants of the building. The timing to purchase the building was 
also too short to consult the budgetary authority. Finally, co-location was not necessarily an option as all the Mem-
ber States present in Washington already had their own premises.

42
The delegation guide was updated in 2015, and includes instructions on how to present options in a comparable 
way on the basis of an example of good practice.

43
The EEAS recognises the need to improve these guidelines to include more detailed information on, inter alia, how 
office space rented to Member States’ embassies and other EU institutions and bodies should be taken into account 
in the calculation of space per person and in calculating the cost per m².

44
See the EEAS reply to paragraphs 45 and 47.

For decisions regarding building files which depend on the approval of the budgetary authority, this can take 
between 6 and 8 weeks.

Reply of the EEAS 

60

45
Procedures for building contracts are regulated by the financial regulation applicable to the general budget of the 
Union. The EEAS agrees that accelerated procedures should be used whenever it is possible. Unfortunately, the 
scope is quite limited. 

The EEAS cannot force landlords to wait until the compulsory, legal and administrative procedures are terminated.

Lengthy procedures are sometimes due to the complexity of the project.

The Sri Lanka contract was not signed not because of a lengthy procedure but because the landlord changed his 
mind.

46
Comparison with an independent source is however more difficult than for accommodations as the value of a build-
ing depends on its quality and location, as well as the general conditions of the real-estate market at a particular 
point in time.

For Mauritania, there was no other solution than the one proposed.

For Togo, there were no offers competing with the present offices, where an investment of 200 000 euro had just 
been made.

47
In 2015, delegations were instructed to give due consideration to the amount of office space per staff, and that from 
now on any deviation from the buildings policy will have to be justified, approved and recorded.

In addition, this element is also discussed during each Building Committee.

In general, the exemption to the ceiling in terms of m² is automatically given if the Building Committee gives 
a favourable opinion (see also reasons for exemption listed at paragraph 20).

Jordan. The proposed solution was to renew the existing lease contract with a reduced rent. Given the investments 
already made in the building, the good location, the security standards and the reduced rent, the Building Commit-
tee issued a favourable opinion despite the excess of office space. However, the Building Committee also indi-
cated that if the number of staff were to decrease further, the delegation would be requested to investigate other 
alternatives.

The EEAS recognises that the residence in Sri Lanka is too large. However, finding a residence of less than 600 m² in 
Sri Lanka is very difficult.

Washington. The main reason for expanding space was the need to create a secure meeting facility for meetings 
with Member States and for transatlantic negotiations in the context of the Snowden leaks. The present meeting 
room located on the ground floor with windows that face the street is impossible to secure.

Reply of the EEAS 

61

In addition, office space for an additional 20 staff was required on the basis of an anticipated increase of the delega-
tion’s staff, and derogations provided for in the delegation’s guide for temporary staff (e.g. ENDs, trainees, etc.).

Early in 2016, the total number of staff of the EU delegation was increased by three permanent staff and, according 
to the most recent information, could further increase over 2016 and 2017 by another six or seven permanent staff.

Importantly, there was no other choice but to rent an entire floor, bigger than the actual requirement, to create the 
extra space required for these needs.

49
The evaluation team does not have the technical capacity to assess the buildings. However, they do include any 
specific issues arising from building quality in their reports.

51
The new ImmoGest will refine the calculation of the different types of surface (co-location, specific meeting rooms, 
etc.) to enable the EEAS to calculate more accurately the average space per staff member in the delegation and to 
facilitate its monitoring.

52
Delegations have been instructed to give due consideration to the amount of office space per staff member, and 
that from now on any deviation from the buildings policy will have to be justified, approved and recorded.

53
The EEAS is ready to consider the establishment of a methodology to monitor market rates for offices and resi-
dences. However, until now, with the well-known resource limitations and the commitment on staff cuts, the devel-
opment and the implementation of such a methodology is not possible.

Comparison with an independent source is indeed more difficult than for accommodations, as the value of a build-
ing depends a lot on its quality and its location, as well as the fluidity of the real-estate market in each country.

The exercise which was carried out in 2014 compared data gathered by a private company using more or less the 
same system used by the delegations to calculate the housing norms. The data gathered by this private company 
can differ from the housing norms mainly because it is using data from locations which are not authorised by the 
regional security officer.

Reply of the EEAS 

62

54
The observations of the Court regarding ImmoGest are well known and integrated into the work programme of the 
EEAS.

The EEAS agrees that the existing IT tool for real-estate inventory management (ImmoGest) is outdated and in need 
of replacement.

This, together with limited resources for delegation infrastructure development, has been a significant obstacle to 
effective planning beyond a 2-3-year time frame.

A new system is being developed and will be fully implemented by the end of 2016. In the first place the new 
ImmoGest will be more user friendly. It will also support reporting, analysis, budgeting and, in a wider sense, project 
planning. The new ImmoGest will allow better monitoring/tracking of the suitability of delegation buildings.

59
EEAS headquarters considers that it has sufficient reliable basic information on all office buildings and residences to 
draw up planning documents focusing on a 2-3-year time frame, which it considers as appropriate.

60
See also the EEAS reply to paragraphs 59 and 61.

Headquarters develops the following, on a yearly basis.

—  Since 2015, a 5-year plan with the ambition to identify major potential projects for offices and residences such 

as purchases, construction, relocations and rent renewals.

—  A programme of work for offices and residences for the next 2 years. This programme is sent to all delegations, 
and is developed on the basis of the information available in central monitoring systems. It presents for each 
delegation the main actions to be taken in accordance with priorities set by HQ, derived also from various re-
ports (e.g. mission reports, evaluation reports), and budget availability.

In addition, headquarters reports on sensitive and/or high-priority files to the EEAS hierarchy on a 3-monthly basis.

Regarding more specifically the implementation of recommendations from on-site assessments, it is important to 
distinguish recommendations such as, for example, relocations to new premises and co-location plans from recom-
mendations related to minor security works, minor renovation and maintenance, which are to be dealt with locally 
under the responsibility of the delegation, and which are not necessarily reflected in the 2-year programme of work. 

The EEAS agrees that, subject to the availability of resources, the follow-up of the aforementioned recommenda-
tions as well as planning in general can be further improved.

HQ took the necessary actions to correct the situation in Chad, Egypt, Sri Lanka and India. No solution has yet been 
found for Senegal.

Reply of the EEAS 

63

61
Similarly to the experience of Member States’ ministries of foreign affairs, it is extremely difficult to develop mean-
ingful long-/medium-term plans for delegation buildings.

There are a number of reasons for this. Firstly, political considerations play often a decisive role. The opening of 
delegations in Libya, Myanmar/Burma, Iran and South Sudan are recent examples where the need/opportunity 
for a new delegation responds to political development and hence could not have been foreseen many years in 
advance.

Secondly, severe budgetary constraints have also been an impediment towards longer-term planning, as priority 
often had to be given to short-term, more pressing, needs. The creation of an investment facility (as from 2015) will 
introduce an element of stability in the funding of medium-term building projects. Yet it is important to underline 
the unpredictable and dynamic political and security context.

Nevertheless, the EEAS is exploring options to improve the forward planning of building management and pro-
gramming of expenditure. In view of the political and practical uncertainties, a 2-3-year planning horizon is more 
realistic than a longer-term 6-7-year plan, except in the case of construction.

The EEAS therefore believes that it makes sufficient use of available information. This situation will improve when 
ImmoGest is fully operational.

The best example is Member States’ practices. During co-location meetings, Member States were asked to exchange 
their 5-year planning, but this information was not available.

The EEAS Infrastructure Division meets every year in September in order to discuss the work programmes for the 
next 2 years. During this discussion more long-term planning is also discussed, but is not included in the work pro-
gramme which is transmitted to the delegation.

62
The EEAS agrees that there is room for improvement with medium-term planning. This will be the case when 
ImmoGest and the management system of the owned properties are fully operational, as more information will be 
available.

See also the EEAS reply to paragraph 61.

63
The EEAS believes that, in the long term and in principle, owning is generally better than renting. In the past, this 
has not been an option because of budget constraints. Now that the EEAS has a loan facility discussions on buying/
renting will be easier, as the possibility to buy has become a reality. Ownership may however not always be the best 
option (mainly for financial reasons) or may not always be possible for legal reasons.

Reply of the EEAS 

64

65
The purchase of residences is only considered when there is a good financial opportunity, and importantly if its size 
is sufficient to cover the needs of most possible cases.

66 (a) 
The relative costs/benefits of purchase and renting will now be a standard element in building files. Guidelines have 
been circulated to the delegations to this effect.

The March 2015 note to heads of delegation on the 200 million euro credit line facility states that MDRA4 will carry 
out the calculations to compare buying with renting.

66 (b) 
The EEAS agrees on the need for an improved property maintenance strategy. To take this work forward, the follow-
ing steps are being taken in 2015 and 2016.

(1)  A questionnaire was sent to all delegations where we have real-estate property. This includes questions on the 
quality of infrastructure, technical installations, historical works, maintenance, feedback and comments on the 
general operational state of the building.

(2)  A maintenance plan will set out a schedule of major planned renovations. This will be a multiannual plan subject 

to annual updating. The plan will be the basis for budgetary planning.

(3)  In parallel with the definition of a maintenance plan, guidelines will be issued providing clear maintenance stand-

ards for property-owned buildings.

The new framework contract for health and sanitation inspections will allow the use of external expertise in the 
implementation of this property maintenance strategy.

66 (c) 
The EEAS agrees that exchange-rate fluctuations are a major obstacle to the programming of infrastructure pro-
jects. As far as possible it is tried to have the contracts in euro, but this is not always possible. The EEAS is open to 
discussing solutions in this area (not just for infrastructure spending) with the budgetary authority.

Reply of the EEAS 

65

Recommendation 1 — Complete objectives for office buildings
The EEAS accepts the recommendation.

The EEAS will give further prominence to the importance of flexibility, environmental factors and the issue of access 
for disabled people in the building policy. This is, however, not always possible due to local constraints.

Recommendation 2 — Ensure charges to co-located organisations recover full costs
The EEAS accepts the recommendation.

Recommendation 3 — Strengthen the application of the procedure for selecting 
buildings
The EEAS accepts the recommendation subject to the limits of the financial regulation.

The EEAS has taken work forward on all these issues and a number of steps have already been taken to strengthen 
the procedure for building files.

Recommendation 4 — Verify market rates
The EEAS accepts the recommendation.

The EEAS is ready to analyse the efficiency and the feasibility of an improved methodology to verify and monitor 
market rates for offices and residences if resources allow.

Until now, with the well-known resources limitations and the commitment on staff cuts, the development and the 
implementation of such a methodology has not been possible.

Recommendation 5 — Improve the real-estate management information system
The EEAS accepts the recommendation.

The EEAS agrees that the existing IT tool for real-estate inventory management (ImmoGest) is outdated and in need 
of replacement. A new system should be fully implemented by the end of 2016.

Recommendation 6 — Reinforce real-estate management expertise
The EEAS accepts the recommendation.

The Human Resources policy of the EEAS promotes the mobility of staff except for positions requiring specific 
expertise. Consideration will be given to establishing more flexible mobility criteria for some expert posts. The 
regionalisation of delegation management will also enable expertise to be built and maintained.

Reply of the EEAS 

66

Recommendation 7 — Establish medium-term plans
The EEAS partially accepts the recommendation.

The EEAS considers that a planning horizon of more than 2-3 years can only be indicative, as the information 
required for the development of such plans is subject to political and practical uncertainties (e.g. evolution of staff, 
security context, Member States’ plans) which are difficult to predict beyond such a time frame. Moreover, regard-
ing modifications and maintenance in particular, such forward-looking planning can only be relevant for major 
projects.

Recommendation 8 — Identify where purchasing offers better value for money and 
manage owned buildings effectively
The EEAS accepts the recommendation subject to the availability of resources.

The new IT tool for real-estate inventory management under development will also support analysis, budgeting 
and, in a wider sense, project planning.

However, with a team of only 13 staff, there are limitations as to the possibilities for the EEAS to manage effectively 
such a huge portfolio.

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The European External Action Service (EEAS) provides 
office buildings for EU staff and residences for heads of 
delegation in around 140 EU delegations around the 
world. In this report the Court of Auditors examines 
whether buildings meet the needs of the EEAS and 
provide value for money. It concludes that buildings 
generally meet the needs of the EEAS but in some cases do 
not provide best value for money: most offices have too 
much space, the EEAS owns buildings which it no longer 
uses and the charges to some organisations renting space 
in delegations do not recover full costs. The audit 
examines the reasons for these shortfalls and makes 
recommendations to strengthen systems, particularly in 
view of EEAS plans to invest in purchasing, rather than 
renting, buildings.

EUROPEAN
COURT
OF AUDITORS