EUROPEAN COMMISSION
DIRECTORATE-GENERAL
REGIONAL AND URBAN POLICY
European Territorial Cooperation, Macro-regions, Interreg and Programme Implementation I
The Director
Brussels
regio.d.4(2025)10673762 /EO/ST
Subject: Closure of the Operational programme for cohesion policy funds 2014-2020
(CCI n° 2014EE16M3OP001) – observations to the final implementation
report
Ref.: Final implementation report - 1st version
Dear Mr Merila,
On 5 August 2025, the Commission services received the final implementation report as
approved by the monitoring committee and required by Article 50(1) and 141(1) of Regulation
(EU) No 1303/20131 relating to the operational programme in reference. The purpose of this
letter is to provide observations to the final implementation report in accordance with Article
50(7) of Regulation (EU) No 1303/2013.
Following the assessment of the submitted information, the Commission services conclude that
the final implementation report cannot yet be accepted.
The managing authority is kindly requested to revise the content of the final implementation
report in accordance with the comments provided in Annex I.
In accordance with Article 141(2) of Regulation (EU) No 1303/2013, the final balance will be
paid only after acceptance of both the accounts of the final accounting year and of the final
implementation report.
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Regulation (EU) No 1303/2013 of the European Parliament and of the Council of 17 December 2013 laying down
common provisions on the European Regional Development Fund, the European Social Fund, the Cohesion Fund,
the European Agricultural Fund for Rural Development and the European Maritime and Fisheries Fund and laying
down general provisions on the European Regional Development Fund, the European Social Fund, the Cohesion
Fund and the European Maritime and Fisheries Fund and repealing Council Regulation (EC) No 1083/2006 (OJ
L 347, 20.12.2013, p. 320).
Urmo Merila
Riigi Tugiteenuste
Keskus Lõkke 4,
10122, Tallinn
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111
The managing authority is kindly requested to reply to these comments within two months of the
receipt of this letter. In the absence of a reply, or in the case of an unsatisfactory reply, the closure
of the operational programme will be carried out on the basis of the available information.
Yours faithfully,
Electronically signed
Slawomir TOKARSKI
c.c.: Karin Viikmaa, Anu Altermann,
[email protected]
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ANNEX I
Observations to the final implementation report according to Article 50(7) of Regulation (EU)
No 1303/2013
Section 8 – Financial instruments
Overall, there are multiple discrepancies in the data reported in final implementation report
(FIR) that should be either explained or corrected.
1. The value declared in the FIR as eligible expenditure in line with Article 46 of the CPR is
EUR 118,443,369.00, while the value included in the annual accounts is EUR 110,500,000.00.
2. Total amount of programme contributions committed in the funding agreement for guarantee
specific fund (52,000,000.00) is higher than the amount paid to specific fund (49,500,000.00)
and also the amount blocked (committed) in the guarantee contracts signed (39,046,131.51) is
not fully covered by loans which were disbursed to final recipients (37,706,507.70).
3. Furthermore there is difference between the total amounts of programme contributions
committed and paid to equity fund of funds (FoF) and committed to equity specific funds within
this FoF, e.g., amounts committed to specific funds are larger than ones paid to FoF; the values
do not add up for total amounts of programme contributions paid to equity specific funds and
amounts paid to final recipients through equity specific funds.
4. Please also ensure consistency with Table 7 of FIR (values declared under form of support for
fields 03 and 04).
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Electronically signed on 29/09/2025 12:41 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121