Tool 7 · Cross-Cutting
Risk Cards — Compliance Deck
Nine cards covering the compliance risks that cut across combined-instrument pathways. Flag the cards that apply to your project and export a deck for the audit desk.
Serves
The compliance register held for the audit desk
Filled in by
Compliance or grant manager, reviewed at every gate
How to use this tool
- Work through the deck once at proposal stage, then refresh it at every hand-off in the Pathway Planner and at every reporting milestone.
- Every card follows the same format so a coordinator, a finance officer or an auditor can read any card in under two minutes. Open the detail only on the cards that apply to your project.
- Cards 1–7 cover the rule- and governance-driven risks that cut across all plays; Cards 8 and 9 cover the two Türkiye-specific exposures — the IPA III re-entry trap and currency risk on mixed pathways.
- The deck surfaces risks; it does not mitigate them. A flagged risk must be assessed against the specific project, and in some cases against a legal or financial opinion, before any decision is taken.
Your entries are saved in this browser only — nothing is uploaded.
0 of 9 cards flagged as applicable — export will include all nine cards
Card 1
Double-funding
Description — The same cost — personnel time, equipment depreciation, a subcontract, overheads — is charged, in whole or in part, to two EU or combined EU–national sources. This is the single most serious and most common audit failure in combined-instrument projects, and it is typically inadvertent.
Compliance boundary engaged
No double funding.
Card 2
State aid
Description — Public funding to an undertaking (in the EU state-aid sense — any entity carrying out an economic activity) exceeds the thresholds at which the support must be notified or must be structured under the General Block Exemption Regulation or must comply with the de minimis regulation. The risk is material in any Play that involves SME co-funding, industrial IAs, or public procurement of innovation — Plays 1, 3, 4, 5, 6.
Compliance boundary engaged
No invented programme compatibility.
Card 3
Procurement–grant interface
Description — A pathway uses both grant-funded and procurement-funded mechanisms (typically IPA III alongside Horizon Europe, or a public authority procuring a pilot that has been developed under a grant), and the boundary between the two is not clean. The two regimes have different eligibility rules, different cost rules, different audit trails, and different disqualification grounds for subsequent tenders.
Compliance boundary engaged
No simplification that distorts rules.
Card 4
Eligibility drift
Description — The proposal scope, the partner composition, or the beneficiary profile changes during drafting in ways that silently break eligibility under the call's specific rules. The drift is typically small, accumulates across versions, and is often caught only at the pre-submission legal check — or not at all, and surfaces at audit.
Compliance boundary engaged
No assumed participation rights.
Card 5
Participation-status drift (Türkiye-specific)
Description — Türkiye's participation in a specific instrument — Digital Europe limited to Specific Objectives 1, 2, 4, 5; SMP limited to the COSME strand; association status renewals across Horizon Europe and Erasmus+ cycles — changes, or is mis-assumed, or expires during the project. The consequence is that a Turkish partner becomes ineligible mid-project, or an instrument becomes unavailable at a call that was expected to be open.
Compliance boundary engaged
No assumed participation rights.
Card 6
Consortium governance
Description — Lead-partner disputes, IP collisions, partner exits, and role overlaps across concurrent instruments disrupt the consortium in ways that a well-drafted consortium agreement would have pre-empted. The risk is structural in any multi-partner, multi-instrument project and is underestimated because most consortium agreements are copied from earlier templates without re-examination.
Compliance boundary engaged
No invented programme compatibility.
Card 7
Timing and sequencing breakdown
Description — The pathway logic of a play requires hand-offs between instruments that have been scheduled against unrealistic call cut-offs, against internal lead times that the organisation cannot actually sustain, or against partner confirmation deadlines that the partners have not agreed to. The breakdown typically materialises at a hand-off and is catastrophic when it does.
Compliance boundary engaged
No simplification that distorts rules.
Card 8
IPA III re-entry risk
Description — A grant-shaped project, typically a Seal-bearing proposal or a completed pilot, is 're-routed' toward IPA III as if IPA III were another grant window. It is not. IPA III is delivered primarily through procurement under PRAG rules, with a different application logic (a technical and financial offer against a tender), a different counterpart (CFCU or the EU Delegation as contracting authority), different IP outcomes (typically resting with the contracting authority), and a different role for the applicant (contractor, not beneficiary). A proposal cannot be transferred intact: it must be re-structured to fit a tender or twinning logic, and only content that matches the published programming priorities will find a window at all.
Compliance boundary engaged
No simplification that distorts rules.
Card 9
Currency and inflation exposure
Description — A multi-year pathway combines instruments denominated in Turkish lira (TÜBİTAK, KOSGEB, Development Agencies) with instruments denominated in euros (Horizon Europe, Erasmus+, Interreg, financial instruments). Exchange-rate movement and domestic inflation change the real value of each leg at different speeds: a national budget fixed at submission can lose a substantial share of its purchasing power before the project ends, while the costs a euro grant must cover (salaries, equipment, services) inflate in parallel. A pathway that was financially coherent at design can become unbalanced in implementation; co-financing commitments, matching-fund obligations, and equipment budgets are the usual casualties.
Compliance boundary engaged
No simplification that distorts rules.
Practical tip
The Deck does not itself mitigate risks; it surfaces them. Flag the cards that apply to your project and bring the exported deck to your kick-off meeting with a named owner for each one.