Conclusions and recommendations

AuthorMichie, Rona; Wishlade, Fiona; Mendez, Carlos
Fact-finding study on the GBER transparency re quirement
There are wide differences in approaches to the transparency requirements. However, the data
currently available do not enable an accurate assessment of compliance with the requirements to
be made. As such, it is not possible to conclude that a particular model is more effective than
From the data available it is possible to analyse the timeliness of reporting, but it is not possible to
know the scale of awards that were not reported at all. A more accurate assessment of
compliance might be gleaned from requiring Member States to report the actual number of
awards under SARI, as well as expenditure; the number of awards anticipated might also be
made an obligatory entry under SANI2. Neither of these proposals would provide a complete
solution, but over time would enhance the capacity accurately to identify likely instances of
Although the scale of failure to report is unknown, detailed data on delayed reporting is available.
Analysis of this data shows that the timeliness or otherwise of reporting is essentially driven by
the behaviour of a very small number of awarding bodies in each Member State. A radical
improvement in the timeliness of reporting could be achieved by targeting and training those
few organisations that report belatedly.
It cannot necessarily be concluded that the same organisations responsible for delayed reporting
are also responsible for failures to report since this is not possible to detect. However, it may be
that awarding bodies failing to report at all do so due to low levels of awareness of the obligations
and few instances (particularly in the case of non-GBER aid). Alongside targeted training, the
adoption of a single harmonised t ext on transparency might raise the profile of the obligation
and improve levels of compliance.

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