ANNEX II – WHAT’S NEW IN PRAG 2025?

1. PRAG Structure

The structure of Chapter 2 of PRAG has been revised so as to clearly identify which rules are
both common to procurement and grants. In case of procurement, all common provisions to the
three types of procurement (services, supplies and works) have been regrouped in Chapter 2.

2. Common provisions to procurement and grants

a) PIC registration

Due to the deployment of SUMMA, all entities that participate in an award procedure,
regardless of the submission method, in direct management or indirect management by
the partner country (where the Commission makes payments) shall register and obtain
a PIC in order to participate. The validation of the PIC (which includes the legal entity
and bank accounts details) is triggered for the entities to be awarded a procurement
contract or grant. This has also an impact for the treatment of bank account changes and
other information regarding the legal entity.

b) Conditionality Regulation provisions and respect of EU values

The General Conditions have been revised in order to introduce the application of
measures under the Conditionality Regulation. The code of conduct of contractor and
beneficiaries has been reinforced by introducing reference to EU values in line with
new provisions in the Financial Regulation.

3. Procurement

a) Digitalisation

PRAG takes into account the further roll out of e-procurement, both for electronic
submission, signature and electronic management.

b) Validity of tenders

Given that much more verifications need to take place before the award of the contract,
the period of validity of the offers has been modified.

c) New FR provisions

This includes the new provisions on professional conflicting interests, control of foreign
subsidies, elimination of the obligation to publish the shortlist.

d) Participation of SMEs

In order to promote the participation of SMEs, the selection and award criteria have
been revised in order to remove barriers for their participation.

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 e) Services – key experts.

- Key experts:

The provisions on key experts have been revised in the context of the simplification
exercise.

The CV of the key expert has been replaced with a new profile that shall facilitate
the evaluation.

The timing of confirmation of the availability of the key expert has been brought
earlier: the presumed successful tender shall confirm the availability of the key
expert before the award of the contract.

The General Conditions of the service contract have been revised regarding the
change of experts, including provisions on liquidated damages.

4. Grants

a) Financial Regulation provisions

This includes: new definition of NGO; calculation of volunteer costs; simplification for
Simplified Cost Options (verifications); simplification calculation non profit; new
concept of very low value grant.

b) Financing not linked to costs

All relevant documents have been updated in order to allow grants in the form of
reimbursement of costs, or financing not linked to costs, or a combination of both.

c) Simplified Cost Options

In anticipation of e-grants, the new PRAG only allows two types of Simplified Cost
Options: the ones determined by the contracting authority and authorised prior to the
launch of the award procedure, and single lump sum. Result-based SCOs and the related
guidelines, previously embedded in annex K, cease to exist.

d) Indirect Costs

In anticipation of e-grants, indirect costs are not calculated on all direct eligible costs:
project office costs, volunteer costs, and land purchase costs are excluded.

e) Changes in award procedure

The information and declarations that grant applicants must submit and timing for
submission have been rationalised. This has allowed to merge evaluation steps 2 and 3.

The evaluation grid has been revised, and it anticipates the evaluation grid included in
e-grants.

Finally, the award notice has been eliminated since this is not a requirement under the
Financial Regulation.

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 f) Reporting obligations

The reporting obligations of grant beneficiaries have been reviewed, including the
narrative and financial reports, to further facilitate the clearing of pre-financing, and
information on financial support to third parties.

g) Transfer of assets

Obligations on transfer of assets have been clarified and new obligation to ensure
respect of EU values after transfer.

h) Communication and visibility

The grant template guidelines and budget have been updated, to clarify that applications
should not include a communication component (budget, communication staff for the
beneficiary, or communication activities) unless explicitly requested by the European
Commission. This applies to communication strategies, plans, activities or activities of
similar nature. Any request by a grant applicant must be approved by INTPA 02.

If a grant application or draft contract proposes to include communication activities,

budget, or staff, and you have any doubt whether it should be removed, please ensure
02 is consulted before signature.

MATRIX OF CHANGES

What’s new – PRAG 2025

The table below provides an overview of the main changes in the PRAG 2025. The changes in the PRAG
are applicable to all award procedures initiated on or after its publication date, with the following
exceptions:

• with regard to procurement procedures in indirect management with Partner countries, such
procedures will be deemed to have been initiated as from the date of the official transmission of
the whole tender dossier to the relevant EU Delegation;

• in direct management, procedures will be deemed to have been initiated once the contract notice
file is in ARES and beyond the level ‘encode’.

In case of grant award procedures launched with PROSPECT, given the necessary IT adaptations, no
call may be configured until these changes are implemented (expected date end of January).

Cross-
C reference
Title Subject matter Modification
h section/ann
ex
1 Basic Harmonisation of Content that was dispersed across several Chapters 2,
Rules content chapters, but common to services and grants, 3, 4, 5, 6
has been moved to chapter 2, therefore avoiding
duplications and inconsistencies. Duplications

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 between the PRAG and the Users Guides of the
Companion have, where appropriate, been
removed. Duplications between the chapters
and the annexes have, where appropriate, been
removed. Information that was previously only
found in the annexes, has, where appropriate,
been included in the chapters. These changes
respond to the recommendations of the Internal
Audit Service.
Contract More precise and detailed information on the Sections
modifications and different types of modifications. Text 2.11
their limits restructured to align more clearly with the
Financial Regulation: cases when modifications
need to be done through addendum with award
procedure in line with Annex I point 11(4) and
the different cases under Article 175 not
requiring an award procedure. Further
clarifications on technical amendments,
including administrative orders. In addition, the
diagram on the contract execution period has
been simplified. For service contracts, supply
contracts and work contracts, specific guidance
will be provided in each chapter (see below).
Award decision New template for award decision based on the Sections
(Digitalisation) new corporate model. The award decision will 6.5.10
be generated automatically by digital systems. Annexes
The word version will be used in case the award b11b, c7b,
decision needs to be filled in manually such as in d7b, e11a
case of indirect management.
Legal Entity Form Details of the LEF and FIF have been unified in
(LEF) and Financial one identification form. The filled in Modificatio
Identification identification form is submitted to the ns have
Form (FIF) contracting authority in case of indirect been made
management where the partner country makes in all
the payment. In case of direct management, and annexes
indirect management where the European and
Commission makes the payments, the form is chapters
submitted to REA as part of the Participant that make
Identification Code (PIC) validation. Until reference to
translations of the identification forms are made LEF and FIF.
available by DG BUDG, the forms are only
available in English.
Participant Modificatio
The PIC registration has been extended beyond
Identification ns have
the cases of electronic submission. It is
Code (PIC) been made
applicable for direct management and indirect
registration in all
management where the European Commission
annexes
makes the payments.
and
chapters
that have
submission

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 instructions
.
Per diems and Precisions on the delivery mode of the expert’s Sections
travel assignment in relation to per diems. Grouping 2.5.5
together in 2.5.5. information on per diems that Annexes
was previously found in the terms of reference, b8i2, b8e
the footnote of the budget and the per diem
library.
Evaluation report Alignment with the terminology used by central Sections
for negotiated services. Negotiation report now named 2.6.8,
procedures, single evaluation report. Evaluation report is now 3.3.5.1,
tender adapted for negotiated, single tender and direct 4.2.6.1,
procedures, and grants award. Separate template for the 5.2.5.1
direct award of evaluation of single tenders (a10b) has been Annexes
grants deleted, since a10a will include the single tender a10a, a10b,
options. a10a1
EU values Sections
Reinforcement of the compliance to basic EU 2.5.6.
values in procurement documents and grant Annexes
guidelines. Reinforcement of the compliance to b8b, b8d,
basic EU values in the general conditions of the c4b, c4e,
contract. d4b, d4p,
e3a, e3h2,
e3h10
Original Annexes
The general conditions include the possibility to
supporting b8d, c4e,
keep original supporting documents in digital
documents d4p, e3h2
format.
(Digitalisation)
Declaration of ‘Declaration of impartiality and confidentiality’ Sections
absence of conflict replaced by ‘Declaration of absence of conflict of 2.9.3
of interests and of interests and of confidentiality’. With this Annexes a4
confidentiality renaming, the wording in annex a4 has become
equivalent to PPMT wording.
2 Basic Communication Different options for the communication Annexes
Rules clauses between the contracting parties have been b8c2, c4d,
(Procure (Digitalisation) provided, to be chosen depending on the level d4o, b8d,
ment) of activation of the F&T Portal. c4e, d4p
Main conditions Procurement contract models now include main Annexes
(Digitalisation) conditions. The main conditions will be b8c1, b8c2,
generated automatically by digital systems. The b8d, c4c,
creation of the main conditions resulted in c4e, c4d,
changes in the draft contracts, special d4n, d4o,
conditions, and general conditions. The word d4p
version will be used in case the main conditions
need to be filled in manually, such as in case of
indirect management.
Notification letters The award notification letter to successful and Sections
to successful and unsuccessful tenderers has been replaced by the 2.9.5,
unsuccessful new corporate model. The letter to the second- 3.4.12.1
tenderers best tenderer (annex b13b) used in case of Annexes
(Digitalisation) services will cease to exist. The award b13a1,

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 notification letters will be generated b13c1,
automatically by digital systems. The word b13c2,
version will be used in case the notification letterc8a1, c8a2,
needs to be filled in manually, such as in case of c8b1, c8b2,
indirect management. d8a1, d8a2,
d8b1, d8b2
Simplified Templates have been adapted to the onboarding Annexes
procedure of the simplified procedure to eSubmission b8o5, ds4b
(Digitalisation) (direct management only).
Single tenders Possibility to submit single tenders by email. Annexes
(Digitalisation) b8o5, c4b,
ds4b
Change of bank The bank account is part of the main conditions. Sections
account Therefore, a change of bank account requires an 2.11.2.4,
amendment to the contract. 2.11.2.3
Annexes
b8d, c4e,
d4p
Simplified Simplification of contract models through the Annexes
procedure and deletion of separate special conditions for the b8c2, d4o
single tenders simplified procedure and single tender in case of
works and services (b8o2 and ds4n). The
simplified procedure and single tenders are
included as an option in the standard special
conditions.
Pre-financing In case of eProcurement, automatic generation Annexes
(Digitalisation) and payment of the pre-financing without b8c2, b8d,
waiting for the reception of the invoice. c4d, c4e,
d4o, d4p,
d4b, ds4o
Pre-financing Further precisions on when a pre-financing Annexes
guarantee guarantee is required. b8c2, c4b,
d4o
Framework Explanations on the different types of Sections
contracts framework contracts and their use, the number 2.6.5
of framework contractors required and the
duration of a framework contract. Detailed
guidance has been provided on request for
specific contracts, see under ‘4. Services’ below.
Promoting the For the selection criteria, the examples in the Annexes
participation of template have been changed into a5f
SMEs predetermined text with options to avoid
disproportionate criteria. For the same reasons,
for the technical capacity criterion the reference
period has been extended to four years.
Professional Precisions on how to treat professional Sections
conflicting interest conflicting interest. Reference to conflicting 2.5.4.4,
interest in the tender documents for services, 2.6.11.3
supplies and works. Professional conflicting Annexes
interest as a fixed professional capacity selection a5f, b8o3,
b8d, b4, b7,

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 criterion. The possibility under the professional b8b, b8n,
capacity criterion to require information to b8o5, b8o7,
examine professional conflicting interest. The c4b, c7b,
presence of professional conflicting interests d4b, d7b
shall be examined on the basis of the declaration
of professional conflicting interests and, where
relevant, the information provided in response
to contracting authority’s request for additional
information.
Foreign Subsidies Application of the Foreign Subsidies Regulation Sections
Regulation which aims to address concerns about foreign 2.6.10.2
subsidies distorting competition within the EU Annexes
internal market. A description is provided for the b3, b8n,
steps to be followed. b8o7, c4l,
ds4c
Abnormally low The contracting authority has the obligation to Sections
tenders identify tenders that appear to be abnormally 2.6.10.1
low. Guidance provided on how to assess
potentially abnormally low tenders and the
steps to be followed.
Period of validity More elaborate guidance on the period of Sections
of tenders validity of tenders. Extension of the period of 2.9.5,
validity of tenders for service award procedures, Annexes
110 days instead of 90 days. b8b, b8o5
VAT VAT instructions and new method to submit Annexes
invoices for consortia without legal personality b8j6, c4p
for service and supply contracts. New annex VI
‘VAT instructions’ (b8j6) explaining that each
member of a de facto consortium (including the
leader) must issue a separate invoice for its
share/part only and corresponding to the
services/supplies provided, for all types of
purchases.
Offsetting Clearer description on offsetting in tender Annexes
provisions documents and special conditions. Recovery by b8c2, b8b,
offsetting may also be done against outstanding b11a, b8o5,
debts of any consortium member for any b13a, c8a,
payment, including against pre-financing. In case c4d, c4b,
of outstanding debt, the contractor will be c7a, d4o,
informed with the award notification letter that d8a, d4b,
any payment may be offset against outstanding ds4o, ds4b,
debts of any consortium member. d7a
Explanatory note An explanatory note during contract preparation Sections
(contract is only required when there are important 2.10.2
signature) elements to report between the evaluation and Annexes a6
contract signature.
Explanatory note An explanatory note during contract closure is Annexes a6
(contract closure) only required when there are important
elements to report between the final payment,
or the release of the performance guarantee,
and contract closure.

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 Record keeping Reduction of the record keeping period from 7 Sections
years to 5 years. Alignment with article 132 of 2.5.5
the Financial Regulation. Annexes
b8d, c4e,
d4p

3 Services Promoting the In the ‘Organisation and Methodology’ it is now Annexes

participation of stated that the involvement of SMEs will be b8g, b8n,
SMEs considered an added value in the tender a5f, b3
evaluation. Single companies will not receive the
maximum available points for the criterion
“Involvement of all members of the
consortium.” Statement on SME’s included in
the statement in the tender form.

Key Experts profile Replacement of the annex ‘Key Expert Sections

Curriculum Vitae’ with ‘Key Expert’s profile’. This
3.4.3.2,
expert’s profile is meant to only indicate the 3.4.10.3
elements relevant to the requirements listed inAnnexes
the terms of reference and used in the b8a, b8b,
evaluation grid in the form of award criteria. The
b8d, b8e,
structure of the expert’s profile should facilitate
b8h, b8n,
the examination of the award criteria for key b8m1,
experts. This change followed simplification b12a, b8o3,
measure number 26. b8o4, b8o5,
b8o7, b11c
Minimum Clearer description on the minimum Sections
requirements of requirements for key experts. Guidance on the 3.2.2
Key Experts for formal education and work experience. Annexes
fee-based b8e
contracts
Minimum The default option is that no minimum Sections
requirements of requirements for experts are defined. It is up to 3.2.1
Key Experts for the contractor to define the precise inputs of the Annexes
Global Price experts. In duly motivated cases, minimum b8f
requirements can be requested for a team.
Replacement of New provisions in the procurement documents Sections 3.6
experts and and in the general conditions for service Annexes
liquidated contracts to strengthen the conditions required b14, b8d,
damages for replacement of key experts and the b11c
application of liquidated damages. Creation of a
pre-information letter (b14) for the
communication with the contractor about the
replacement of key experts and the application
of liquidated damages. This change followed
simplification measure number 24.
Communication Creation of a new annex called ‘Notice to the Sections
with presumed Presumed Successful Tenderer’ (b11c). This 3.4.10.5,
successful notice includes communication on the Annexes
tenderer Declaration on honour, the verification of b11c, b11a

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 documentary evidence on exclusion and
selection criteria, the confirmation of key
experts' and auditor/practitioner availability.
This annex consolidates parts which were
previously found in the evaluation report and
the letter to the best tenderer. The maximum
time limit for providing the information and
proposing a replacement in case of unavailability
of a proposed key expert is reduced to 7 days.
The evaluation report will report on the
verifications done with the presumed successful
tenderer.

Contract Precisions regarding budget modifications Sections 3.6

modifications and between fees, lump sums and incidental Annexes
their limits expenditure in case of fee-based contracts. b8d
Incidental Clarifications and guidance on the items that can Sections 3.6
expenditure be provided for by the incidental expenditure. A Annexes
clearer structure for the incidental expenditure b8b, b8d,
in the budget has been provided. Expenditure b8e, b8i2
verification is now an item of incidental
expenditure, which however, like in the past,
cannot be reduced.

Lump sum costs Clarifications on lump sum costs that can be Sections
included as a global price activity in a fee-based
3.2.2
contract, and on the fact that lump sums costs Annexes
are included in the financial evaluation. b8b, b8d,
b8e, b8i2
Requests for Generic guidance on the launching of request Sections
specific contracts for specific contracts from sending the request 3.5.1.
up to the award. Clarifications on the
modification of specific contracts, whereby
modifications for the repetition of similar
services which require a negotiated procedure
are not applicable to specific contracts. Unlike
previous versions of the PRAG, no specific
guidance will be provided on the external action
framework contracts (SEA, AUDIT), for which the
guidelines specific to each framework contract
should be consulted.
Timesheets The General Conditions include in article 24.2 Annexes
the mandatory elements for timesheets. The b8d, b8k3
time input for each reporting period shall be
rounded to the nearest whole number of days
worked for that period. Creation of a new
specimen timesheet for experts (b8k3) with the
minimum elements of a timesheet. This change
followed simplification measure number 25.
Sub-contracting Explanation on sub-contracting, particularly the Sections
case of one-person company. 3.4.10.3

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4 Supplies Liability andWhere the contracting authority is the European Annexes
ownership of the Commission acting on behalf and for the c4e
Partner Country account of the Partner Country, the Partner
after delivery Country will, immediately after provisional
acceptance, assume full liability and retain full
ownership with regard to the supplies delivered.
Contract More precise information on administrative Sections
modifications and orders and alignment of the value of successive 4.7,
their limits modifications with art. 175 of the Financial Annexes
Regulation with 10% of the initial contract value c4e
as a ceiling. A description of the modifications
that do not require an amendment: the strict
application of procurement documents, the
quantity of any incidental siting or installation
and the extension of the period of
implementation.

5 Works Contract Description of the modifications that do not Sections 5.7

modifications and require an amendment: by measurement, price
their limits revision clause, and extension of the period of
implementation.
Direct End of work contracts in direct management. Chapter 5
management Removal of direct management options in
chapter 5. This change followed simplification
measure number 20.

6 Grants Financing Not Introduction of financing not linked to costs Sections

Linked to Costs provisions in grant contract templates and 6.3.4
(FNLC) guidelines for calls for proposals. Guidelines on Annexes
FNLC embedded in annex K. Introduction of new e3a, e3a2,
templates: financial report for entirely FNLC and e3b, e3c,
hybrid actions, Terms of Reference for third e3d, e3h1,
party assessment on the validation of the results e3h2, e3h5,
reported. The use of FNLC requires a prior e3h6,
approval and must be preceded by an opinion e3h7b,
from INTPA R4. e3h7c,
e3h8c
Change of bank The bank account is part of the special Annexes
account conditions. Therefore, a change of bank account e3h1, e3h2
requires an amendment to the contract.
Simplified Cost Only two types of Simplified Cost Options are Sections
Options (SCO) possible: the ones determined by the 6.3.3
contracting authority and authorised prior to Annexes
the launch of the award procedure, and single e3a, e3h2,
lump sum. Result-based SCOs and the related e3h8b
guidelines, previously embedded in annex K,
cease to exist.
Evaluation Simplification of the evaluation process by Sections
simplification and merging evaluation steps 2 and 3. Eligibility 6.5.6,
improvement check is performed at the full application 6.5.8.4,
evaluation stage on the basis of the Declaration 6.5.8.5

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 on Honour. Content of evaluation reports and Annexes
letters step 2 and 3 is merged in annexes, e3a, e6b,
respectively, e6b and e9b. e9b
Clarifications on Precisions on and modifications of reporting Annexes
reporting obligations under Article 2 of the general e3h2, e3h4,
obligations conditions. New rules and submission frequency e3h7a,
for detailed breakdown of expenditure, to be e3h7b
submitted with financial report and not
anymore with the payment requests.
Reorganisation of the financial report to include
information on both incurred costs and advance
payments/commitments.
Publication of calls Publication of calls for proposals through F&T Section
for proposals portal. 6.5.1
(Digitalisation) Annexes
e3a
Volunteers’ work Volunteers’ work must not exceed 50 % of all Section
sources of financing (that is the Union grant, in- 6.2.8
kind contributions, and other sources of Annexes
financing) as per new Financial Regulation. e3c, e3h2
NGO definition In the new application form, grant applicants will Annexes
be required to declare their legal status, e3b
including whether they qualify as NGOs, in line
with the new definition of the Financial
Regulation.
Transfer of assets Annex IX includes a new part B, for purchases Annexes
ownership below EUR 5 000, to be signed and kept by the e3h2,
beneficiary for control purposes. Requirement e3h10
that the final beneficiary of the action to whom
the assets are transferred must commit to and
ensure that they will use these assets in
compliance with basic EU values.
Financial Support New case of event to be reported when the Section
to Third Parties threshold of EUR 60 000 per third party is 6.8.2
exceeded.

Sensitive contracts Clauses on handling of sensitive grant contracts Annexes

and sensitive information included in special e3h1,
conditions and expenditure verification report. e3h8a

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