Record-keeping after the grant ends

The project is over, the report accepted, the money received, yet the obligations do not end there. The granting authority can check the costs you declared years later, and only documents can prove them. That makes record-keeping part of implementing the grant, not a matter for the archive.

How long to keep records

The period is set in Point 6 of the Data Sheet of the grant agreement. In EU grants it is 5 years after the final payment, and 3 years for grants of up to EUR 60,000. If a check, audit, investigation or dispute is under way, the records are kept until it ends. In Horizon Europe an audit itself can be started within two years of the final payment, but that does not shorten the retention period.

The clock runs from the last payment, not from the date of the document. An invoice from the first month of a four-year project will have to be kept for roughly ten years.

What to keep

• Finance: contracts, invoices, acceptance certificates, payment documents, bank statements, accounting ledgers. The amounts in the financial statement, in the accounts and in the source documents must reconcile.
• Personnel: employment contracts, orders, payroll, the daily rate calculation and time records.
• Procurement: requests, offers, the reasons for choosing the supplier.
• Evidence of results: reports, minutes, participant lists, photos, publications, data.
• Changes: correspondence with the granting authority and every amendment.

For simplified forms of costs you do not have to prove actual costs, but you do have to prove the number of units or the work carried out.

Originals, scans and missing documents

Originals must be kept in the form in which the document was created or received. Paper stays paper, electronic stays electronic, and there is no need to print it. A scan in place of a paper original is acceptable if national law treats it as equivalent. Otherwise the decision is the granting authority's and the risk is yours. Each participant keeps its own records, and the coordinator is no substitute.

Costs without sufficient evidence are ineligible: they are rejected and what was already paid is recovered. The grant may be reduced. If the lack of documents is systemic, the audit findings are extended to other EU grants of the same beneficiary. Proving that a document once existed is nearly impossible, so losing the archive means losing the money.

Ukrainian periods and other donors

The grant agreement does not override national rules; the longer period applies. The Ministry of Justice list of standard documents sets 5 years for accounting source documents and 1 year for attendance sheets, and these periods are minimums. The Tax Code requires legal entities to keep source documents and ledgers for at least 1,825 days. But Ukrainian periods run from the creation of the document or the filing of the return, while the European one runs from the final payment. So project documents cannot be destroyed on the ordinary archive schedule: an attendance sheet that is one year old is still live for the grant.

With other donors the periods differ, but the principle is shared: the clock runs from the end of the grant or the last report, plus an extension while checks are pending. Look in the agreement for the section on record retention and audit rights, and in contracts with Ukrainian funds also for the requirements on supporting documents.

A practical system

1. One folder structure for all projects: agreement and amendments, reports, personnel, procurement, travel, results, correspondence.
2. In the file name: date, counterparty, document number and budget line.
3. Scan on the day the document arrives, not before the report.
4. Set by internal order the date before which the project file is not destroyed, and the person responsible.
5. Keep a backup outside the office. In wartime this decides whether the archive survives.