Topic:  Elucidation concerning the reporting of “minor task” Subcontracting under Subcontracting in Form C

Dear Mr/Ms/Mrs …!

When it comes to reporting, any kind of Subcontracting has to be reported under Subcontracting in the corresponding activity in Form C.

Subcontracting means having "an agreement with a third party on business conditions".
If under this condition a contract is classified as Subcontracting, it always has to be reported under Subcontracting.

Subcontracting may incur in two different ways:
1) Subcontracting laid down in Annex I of the Grant Agreement and
2) "minor task" Subcontracting (Grant Agreement, Annex II.7.3), which by definition is meant for minor tasks which are not laid down in Annex I. Minor tasks correspond to minor services which are not project tasks identified in Annex I but needed for the implementation of the project (catering for a meeting, printing of leaflets, etc.) and minor in their importance.

Both ways of Subcontracting are based on a contract on business conditions for carrying out a work or service.
Therefore also "minor task" Subcontracting is legally classified as Subcontracting and must not be treated differently. It has to be reported under Subcontracting in Form C, no matter if it has been foreseen in Annex I for Subcontracting or not.

The rules concerning Subcontracting you may find in Article 7 of Annex II Grant Agreement (Annex II.7 GA) ftp://ftp.cordis.europa.eu/pub/fp7/docs/fp7-ga-annex2-v6_en.pdf

Further information on Subcontracting from the Commission’s side can be found on pp. 27-31 in the Guide to Financial Issues (concerning “minor task” Subcontracting please consult p. 30 directly) ftp://ftp.cordis.europa.eu/pub/fp7/docs/financialguide_en.pdf

The legal department (RTD A2) of the Commission was already asked via the Research Enquiry Service on this issue. You may find answers concerning subcontracting/minor tasks in the document “FAQ Research Enquiry Service” from section 1.9.3 on, page 44 ff http://rp7.ffg.at/upload/medialibrary/FAQ_ResearchEnquiryService_Stand12_03_09.pdf 

Kind regards