Many companies, non-profit organisations and town councils in the province of Alicante manage projects financed by the Recovery and Resilience Facility: digitalisation, energy efficiency, housing refurbishment or strategic projects (PERTE). This article separates what the official sources say from what is forecast, and proposes a checklist for arriving well prepared at the justification stage and at inspections. It is part of our series on the auditor’s report on the grant expenditure statement.
Where the Recovery Plan stands
According to the Ministry of Finance, on 30/09/2026 Spain submitted the seventh and final payment request, for €25,861 million (€21,463 million in grants and €4,398 million in loans), covering 148 milestones and targets. With it, the funds allocated reach €101,300 million. Previously, after the sixth disbursement, Spain had received €78,000 million and met 338 milestones and targets.
| Official data | What it means for the beneficiary |
|---|---|
| 31/08/2026: deadline for meeting the Facility’s milestones and targets | This is a deadline for the State vis-à-vis the Commission. Your implementation and justification deadlines are those in your grant award decision and any extensions to it |
| 30/09/2026: deadline for submitting the final payment requests | The managing authorities have had to demonstrate results to Brussels, which may translate into more information requests to beneficiaries |
| 31/12/2026: Commission’s final deadline for disbursements | It is not a justification deadline for you, but it marks the financial closure of the Plan |
| Activation of the España Crece fund as an investment lever after closure | If you receive financing from that fund, it will be governed by its own conditions, which you will need to review separately |
What the closure means for the beneficiary
The Facility calendar concerns the relationship between Spain and the European Union. Each beneficiary’s position is determined by its call for applications, its grant award decision and Spanish grant legislation. In practice, it is advisable to review three things:
- Outstanding justification deadline. Check in your award decision when it falls due and whether there have been extensions. Do not assume that extensions will be maintained.
- Maintenance obligations. Many grants require the investment, employment or activity to be maintained for a period after implementation.
- Specific commitments under the Plan. Order HFP/1030/2021, which sets up the Plan’s management system, requires beneficiaries to accept the transfer of data between administrations and to declare their commitment to the Plan’s cross-cutting principles (annexes IV.B and IV.C). It also requires the entities implementing the Plan to have an anti-fraud plan in place.
Auditor’s report in PERTE projects: ministry instructions
For strategic projects, such as the Agri-food PERTE or the Electric and Connected Vehicle PERTE, the Ministry of Industry and Tourism has published specific instructions for the auditor’s report that accompanies the grant expenditure statement. These instructions develop Order EHA/1434/2007, which governs the review of grant expenditure statements in the central government public sector. If your project belongs to a PERTE, the auditor must follow the version of the instructions applicable to your call.
In agri-food projects in the Vega Baja or SME digitalisation projects in L’Alacantí and the Baix Vinalopó, the key issues tend to be two: the allocation of staff costs and the traceability of payments to suppliers and subcontractors.
Document retention and audit trail
The Spanish General Grants Act (LGS) requires supporting documents, including electronic ones, to be kept for as long as they may be subject to verification and control (art. 14.1.g). It also sets a four-year limitation period for the right to demand repayment, generally running from the end of the justification period, and that period is interrupted by any verification action (art. 39). EU legislation and the rules of your call may set additional periods; check which one applies to you before destroying any document.
A complete audit trail should allow a third party to reconstruct the expenditure without asking you. This checklist will help you review it:
- Grant award decision, amendments, extensions and communications with the managing body.
- Signed declarations required by the Plan (transfer of data, cross-cutting principles and, where applicable, absence of conflicts of interest).
- Procurement files or, at least, the three quotations when the expenditure exceeds the minor contract thresholds (art. 31.3 LGS).
- Invoices, contracts and bank evidence for each payment, linked to the relevant line of the approved budget.
- Time records and staff cost allocation criteria.
- Accounting records that make it possible to identify the project’s expenditure and income.
- Evidence of publicity measures and results (technical reports, photographs, deliverables).
- Grant expenditure statement as submitted, auditor’s report and management representation letter.
How to prepare for a subsequent inspection
That there will be more inspections from 2027 onwards is our forecast, not official data: the closure of the Plan concentrates the justification of many projects, and national and European control bodies may review them afterwards. If you receive a request, it is advisable to:
- Identify which body is sending it, what its scope is and what deadline it gives for replying.
- Gather the audit trail before replying and check that it is consistent with what was justified.
- Review with your auditor any issues already noted in the report on the grant expenditure statement.
- If repayment proceedings are opened, assess with your legal adviser the submissions to be made and, if necessary, the support of an economic expert witness to quantify the amounts in dispute.
Town councils and other local authorities implementing Plan funds also have their own internal control obligations. We review them in financial control in town councils and the involvement of private auditors.
Frequently asked questions
Do I have to justify my NextGenerationEU grant before 31/12/2026?
Not necessarily. Your deadline is the one set in your grant award decision. 31/12/2026 is the deadline for the Commission to make disbursements to Spain, not a general deadline for beneficiaries.
Can a grant under the Plan require me to have my annual accounts audited?
Yes, if in a financial year the total public grants and aid that you must record exceeds €600,000, including EU funds. We explain this in mandatory audit for grants above €600,000.
What happens if I do not keep a supporting document?
Expenditure that cannot be evidenced in an inspection may be treated as not justified and lead to partial repayment, with interest. That is why documentation should be kept for as long as it may be subject to verification.
Does the auditor’s report protect me against a subsequent inspection?
It does not replace the Administration’s control. It does record what was reviewed and with what result, which makes it easier to respond to a request.
Official sources
- Ministry of Finance: final payment request under the Recovery Plan (30/09/2026)
- Ministry of Finance: sixth disbursement under the Recovery Plan (11/08/2026)
- Order HFP/1030/2021, management system of the Recovery Plan (BOE)
- Law 38/2003, Spanish General Grants Act (BOE), arts. 14, 31 and 39
- Ministry of Industry: instructions for the auditor’s report, PERTE AGRO
- Ministry of Industry: instructions for the auditor’s report, PERTE VEC
From Alicante, Controlaudit (ROAC S1604) reviews grant expenditure statements for NextGenerationEU funds and supports companies and public bodies in preparing for inspections. Find out about our grant audit, public sector audit and expert evidence services, or contact us to review the status of your file.
Article prepared by Controlaudit’s technical team. Updated 08/10/2026. This content is for information only and does not replace professional advice on your specific case.