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Grant audit and grant expenditure statements

We review your grant expenditure statement and issue the auditor’s report required by the grant rules, so that you can justify the grant on time and with your documentation in order.

AreaJustify
CoverageThroughout Spain
FrameworkLaw 38/2003 · EHA/1434/2007
FirmROAC no. S1604
In briefA grant audit is the review carried out by an auditor registered as practising with Spain's Official Register of Statutory Auditors (ROAC) of the grant expenditure statement (cuenta justificativa) for a public grant, in accordance with art. 74 of Royal Decree 887/2006 and Order EHA/1434/2007. It is needed when the grant rules or the call for applications choose this method of justification. It is different from an audit of annual accounts, which may also be mandatory if the entity receives more than €600,000 in grants in a financial year (Additional Provision 2 of Royal Decree 2/2021).

Reviewed by Controlaudit's audit team · Firm registered with the ROAC under no. S1604 · Updated 13 October 2026

What it involves

When a grant is justified by means of a grant expenditure statement with an auditor's report (cuenta justificativa con aportación de informe de auditor), the beneficiary submits a report on the activities carried out and an abridged financial report, and a statutory auditor registered as practising with Spain's Official Register of Statutory Auditors (ROAC) reviews that statement with the scope set by the grant rules (art. 74 of Royal Decree 887/2006). In return, the public authority may reduce the information the beneficiary has to provide.

The work is carried out in accordance with Order EHA/1434/2007 of 17 May, which governs the auditor's work in this type of review. It is not an audit of accounts and does not express an opinion: the auditor applies specific procedures (checking expenditure and payments, their link to the activity, the allocation criteria, the three quotations where required, and other income or aid financing the project) and reports the facts observed so that the granting body can assess the justification.

At Controlaudit Auditores Certificados, an audit firm registered with the ROAC under no. S1604, we review grant expenditure statements for national, regional, local and EU-funded grants, for beneficiaries throughout Spain. If your organisation also needs its annual accounts audited, see our audit of annual accounts service.

Who it is for

  • Companies that have received aid from the Spanish central government, any regional government or their innovation agencies whose grant rules require a report from a ROAC auditor.
  • Beneficiaries of EU funds (Recovery Plan, ERDF, PERTE) that must justify the grant with an expenditure statement and an auditor's report.
  • Companies and centres carrying out R&D and innovation projects with several annual instalments, partners or complex staff cost items.
  • Foundations, associations, non-profit organisations and consortia that finance their activity with public grants.
  • Entities that have received more than €600,000 in grants in a financial year and must also have their annual accounts audited.
  • Beneficiaries that have received a request to remedy deficiencies or are subject to a subsequent review and need to put their supporting documentation in order.

The Spanish General Grants Act (Law 38/2003 of 17 November) sets out the beneficiary's obligations: to justify that the purpose of the grant has been fulfilled, to submit to verification and control procedures, to keep supporting documents for as long as they may be subject to control (art. 14.1) and to obtain three quotations when expenditure exceeds the thresholds for minor contracts (art. 31.3). The authority's right to order repayment becomes time-barred after four years (art. 39).

Royal Decree 887/2006 governs the grant expenditure statement with an auditor's report in its art. 74: a practising ROAC auditor, an abridged financial report and a review with the scope set by the grant rules. If the beneficiary is required to have its annual accounts audited, the review is carried out by the same auditor unless the grant rules provide otherwise (art. 74.2); if not, the beneficiary appoints the auditor unless the grant rules give the granting body that power (art. 74.3). The cost of the report is only eligible if the grant rules provide for it and up to the limit they set. Art. 75 allows a simplified expenditure statement for grants of less than €60,000 where the grant rules so provide.

For Recovery Plan funds, Order HFP/1030/2021 requires entities involved in their implementation to have an anti-fraud plan and to manage conflicts of interest (art. 6), as well as obligations to identify the recipient (art. 8). Regional aid is governed by its own rules and calls for applications, which determine the method of justification and any thresholds: they must be read in each case.

SituationRuleWhat it means
The grant rules require an expenditure statement with an auditor's reportArt. 74 Royal Decree 887/2006 and Order EHA/1434/2007Report by a practising ROAC auditor on the grant expenditure statement, with an abridged financial report.
Grant of less than €60,000 with a simplified statement provided for in the grant rulesArt. 75 Royal Decree 887/2006No auditor's report is required; the granting body carries out sample checks.
More than €600,000 in grants or aid in a financial yearAdditional Provision 2 Royal Decree 2/2021 (RLAC)Mandatory audit of the annual accounts for that year and for the years in which the operations or investments are carried out.
Beneficiary required to have its accounts auditedArt. 74.2 Royal Decree 887/2006The grant expenditure statement is reviewed by the same auditor, unless the grant rules provide otherwise.
Recovery Plan fundsOrder HFP/1030/2021, arts. 6 and 8Anti-fraud plan, management of conflicts of interest and identification of the recipient, in addition to the rules of the grant.

What it includes

EU funds

Review of expenditure statements for aid under Spain's Recovery, Transformation and Resilience Plan (NextGenerationEU), the ERDF and PERTE projects, applying the specific instructions published by each managing body and checking the requirements specific to these funds.

R&D and innovation projects

Verification of staff costs (hours charged, timesheets, hourly cost), external collaborations, depreciation and indirect costs, with particular attention to the separation between annual instalments and project partners.

Regional government aid

Reports for aid from any regional government and its agencies and departments, following the manuals and report templates of each call for applications where they exist.

Non-profit organisations and consortia

Review of operating and project grants in foundations, associations and consortia, including the allocation of overheads and the concurrence of other aid or income.

Multi-year grants

Support for projects with several annual instalments or partial justifications, coordinating each report with the previous ones and with the changes approved in the grant award decision.

How we work

  1. 01

    Analysis of the grant rules and award decision

    We read the grant rules, the call for applications, the award decision and any amendments in order to establish the scope of the report and the justification deadline. This is best done at the start of the project, not at the end.

  2. 02

    Proposal and contract

    We send you a proposal adapted to the scope and sign the contract required by Order EHA/1434/2007. If the cost of the report is eligible, we take that into account in the timetable.

  3. 03

    Receipt of the expenditure statement

    You prepare the report on activities and the abridged financial report; we check that they contain all the elements required by art. 74 and the grant rules.

  4. 04

    Review work

    We check invoices, proof of payment, allocation of expenditure, three quotations, other income and the requirements of the grant rules. If the rules allow it, we use sampling. Indicative timeframe: one to three weeks depending on volume.

  5. 05

    Representation letter and report

    The beneficiary signs the representation letter and we issue the report setting out the procedures applied and the facts observed, in time for you to submit it before the justification deadline.

Documentation and deliverables

What we will ask you for

  • Grant rules, call for applications and award decision, with any amendments.
  • Signed report on activities and abridged financial report.
  • List of expenditure and investments, with invoices and documents of equivalent evidential value.
  • Proof of payment (bank statements, transfers).
  • Supplier quotations where expenditure exceeds the thresholds for minor contracts.
  • Payslips, social security contributions and timesheets for the staff charged to the project.
  • Separate accounts or an accounting code identifying the project expenditure.
  • List of other income, aid or grants financing the same activity.
  • Documentation on publicity of the public funding and, for EU funds, the anti-fraud documentation required by the grant rules.

What you will receive

  • Auditor's report on the grant expenditure statement in accordance with Order EHA/1434/2007 and, where applicable, the template in the call for applications.
  • Reviewed abridged financial report as an annex to the report.
  • Communication of issues identified during the work so that you can remedy them before submission.
  • Recommendations for organising documentation for future justifications or annual instalments.

Frequently asked questions

When the grant rules or the call for applications choose the method of justification by means of an expenditure statement with an auditor’s report under art. 74 of Royal Decree 887/2006. There is no single amount for all grants: each funding line sets its own method. Check your grant rules or contact us with your award decision.

If your organisation is required to have its annual accounts audited, the grant expenditure statement is reviewed by the same auditor, unless the grant rules provide otherwise. If it is not, you appoint the auditor, unless the grant rules give that power to the granting body (art. 74.2 and 74.3 of Royal Decree 887/2006). In all cases the auditor must be registered as practising with the ROAC.

Only if the grant rules so provide and up to the limit they set (art. 74.3 of Royal Decree 887/2006). Some regional calls for applications provide for it; check yours before budgeting the project.

No. It is a review using procedures defined in Order EHA/1434/2007, and the report states this expressly: it does not express an opinion on the annual accounts. It is limited to the expenditure statement for a specific grant.

Yes, if in a financial year you receive public grants or aid, or EU funds, totalling more than €600,000. In that case you must have that year audited, as well as the years in which the operations or investments are carried out (Additional Provision 2 of Royal Decree 2/2021), and appoint the auditor before the end of the financial year to be audited (Additional Provision 4).

Expenses paid outside the eligibility period or in cash without sufficient support, missing three quotations where they were required, staff hours without a reliable record, recoverable VAT charged as an expense, and expenses not clearly linked to the subsidised activity. Detecting them before submission avoids partial repayments.

The Spanish General Grants Act (Law 38/2003) requires supporting documents to be kept for as long as they may be subject to verification and control (art. 14.1.g), and the right to order repayment becomes time-barred after four years (art. 39). The grant rules and EU legislation may set additional periods, so they should be checked for each grant.

Yes. We review grant expenditure statements for beneficiaries throughout Spain, whatever the granting body: central government, regional governments, local authorities or EU funds. Much of the work is done with digital documentation. Contact us and we will prepare a proposal for you.

Request a proposal for your grant audit

Tell us about your situation and one of the firm’s auditors will contact you.