When it comes to time recording, i.e. recording of days worked in EU funded projects, a minimum of requirements must be fulfilled, whether your employees are working exclusively on the projects or working also on other activities and projects.
Eligibility of Personnel Costs
In Horizon Europe, personnel costs generally represent a substantial proportion of the total project budget. These costs are eligible only to the extent that they correspond to actual working time dedicated to the action, evidenced through reliable time recording systems. From an audit perspective, the absence of adequate time records is one of the primary grounds for financial corrections and recovery of funds.
Mandatory minimum requirements
Regardless of whether personnel work exclusively on the action or in parallel on other activities, Horizon Europe requires beneficiaries to maintain time recording systems that are reliable and verifiable, consistently applied across the organisation and approved by the persons responsible for the action.
Each record must reflect the actual working time, be properly signed by the employee and the supervisor, be consistent with job descriptions, and project-related responsibilities.
Importance of time recording in case of audit
Time recording constitutes a core element of the audit trail in Horizon Europe. Auditors will systematically assess whether the number of days declared corresponds to signed and approved time records and that the recorded time aligns with project tasks, deliverables, and milestones.
Further verifications may be carried out to ensure consistency with other internal records (e.g., payroll, organisational calendars, meeting logs, technical work completed) and to confirm that the timekeeping methodology is applied uniformly and without any possibility of manipulation.
Failure to demonstrate consistency across these elements may result in adjustments to the amounts declared or ineligible cost findings.
Benefits of maintaining robust Time Recording System
As a rule, robust timekeeping practices minimise compliance risks and reinforce the organisation’s internal control environment. But beyond compliance, a well-structured time recording system contributes to effective financial and administrative project management. By ensuring accurate cost allocation and forecasting, enabling sound internal oversight, reinforcing the trustworthiness of the financial statements, and minimising the risk of disputes in audits, a solid time recording system plays a central role in maintaining strong financial and compliance management. For organisations participating in multiple EU actions, consistent time recording is essential to demonstrate a high level of reliability and accountability.
To conclude, in Horizon Europe, reliable time recording is not merely an administrative requirement; it is a critical component of the project management that underpins the eligibility of personnel costs and the integrity of the financial reporting process. Beneficiaries must ensure that their time recording systems meet the minimum requirements set by the programme, align with internal control principles, and provide auditors with clear, traceable, and verifiable evidence of the work performed.
Maintaining compliant and well-documented timekeeping practices is essential for avoiding financial corrections and ensuring that EU funds are managed in accordance with the principles of transparency and sound financial management.
