Management of Public Funding: ESIF, RRF, Procurement and State Aid
The funding chain
EU public funding is a chain: policy → legal base → programme → project → payment → audit. Know the three management modes: shared, direct and indirect. Cohesion funds (ERDF, ESF+, Cohesion Fund, JTF) are shared management: Partnership Agreement, programmes, managing/certifying/audit authorities, and co-financing. The Recovery and Resilience Facility is different: performance-based, funded by EU borrowing, and disbursed against milestones and targets in Council-approved national plans - not invoice reimbursement. Procurement: thresholds, the five principles (transparency, equal treatment, non-discrimination, proportionality, mutual recognition), procedures (open, restricted, competitive dialogue, innovation partnership, negotiated), exclusion vs selection vs award criteria (MEAT), standstill and remedies. State aid: Article 107(1) TFEU four cumulative conditions; GBER; de minimis (€300,000 over three years); SGEI; notification and standstill; recovery of unlawful aid.
Traps and rule of thumb
Traps: applying ESIF cost-reimbursement logic to the RRF; assuming procurement rules bind every beneficiary (they bind contracting authorities); treating de minimis and GBER as cumulative; saying the EU pays 100%; ignoring standstill. Rule of thumb: identify the funding mode, then the procurement regime, then the state aid route. Worked example: a municipality gives €150,000 to a local SME. A grant is not a public contract, so procurement rules do not govern the award itself; but the aid must be de minimis (fits under €300,000) or GBER-compatible. If the municipality buys the equipment itself, procurement thresholds apply.