FAQ - Digit

1. Plan is to establish a new micro/small enterprise in the Republic of Croatia, which would act as the applicant for the VALID call. The new company would be established before submitting the project proposal and would not be formed through a merger, acquisition, or transfer of assets, employees, contracts, revenues, users, IP, software code, or other business activity from another undertaking.
Can such a newly established company be an eligible applicant if the founder/natural person currently has or previously had other companies older than five years?
Additionally, if a similar project idea or brand/name existed before, but no actual project implementation, development costs, revenues, users, contracts, employees, IP, software code, or transfer of assets related to the project took place through previous companies, would this be considered as “taking over the activity of another undertaking” under Section 4(a) of the Guidelines for Applicants? Correction 28.07.2026

Applicants eligible under the VALID Call are defined in Section 4 of the Guidelines for Applicants: Eligible applicants are unlisted micro or small enterprises, up to 5 years following their registration, as defined in Annex I of Commission Regulation (EU) No. 651/2014 – SME definition, that meet all of the following criteria:

a) it has not acquired another undertaking or has not been formed through a merger, unless the turnover of the acquired undertaking accounts for less than 10% of the turnover of the eligible undertaking in the financial year preceding the acquisition or the turnover of the undertaking formed through a merger is less than 10% higher than the combined turnover that the merging undertakings had in the financial year preceding the merger.

b) it has not taken over the activity of another undertaking, unless the turnover of the overtaken activity accounts for less than 10% of the turnover of the eligible undertaking in the financial year preceding the take-over;

c) it has not yet distributed profits;

Please note that the Ministry of Science, Education and Youth is not in a position to interpret individual eligibility conditions or assess the eligibility of a specific applicant without reviewing the complete project proposal and all relevant supporting documentation. Applicants eligible under the VALID Call are defined in Section 4 of the Guidelines for Applicants. Compliance with all eligibility requirements, including those related to the applicant’s status and business activities, will be assessed during the evaluation process based on the information and evidence provided in the project proposal.

Note: Please see also answer to Q#32 and Q#21.

2. Are crafts/sole proprietorships eligible applicants for this call?

An applicant/partner that is association, charity organization, or trade business is not eligible applicant.

3. If a newly established Croatian company has no employees at the time of application, can it still include planned new employment in the project budget, with employees to be hired only after project approval and contract signing?
More specifically:
Are personnel costs for employees hired after project approval eligible?
How should the daily rate be calculated for planned new employment if the applicant has no payroll in the month before submitting the application?
Is it mandatory to have at least one employee before submitting the application in order to include personnel costs in the budget?

Personnel costs for newly hired staff are eligible. Personnel costs shall be calculated in accordance with the methodology for calculating personnel costs, as defined in section 11 of GfA, which applies to both existing employees and newly hired staff working on the project. Whole month salary must be used for calculation.

4. The Call documentation states that, where an applicant did not have any employees during the previous financial year, the daily rate is calculated based on the payroll record for the month preceding the submission of the project proposal.
We would appreciate clarification on how to proceed in a situation where the applicant:
did not have any employees during the previous financial year; and
does not have a payroll record for the month preceding the submission of the project proposal.
Specifically, we would appreciate information on the following:
May such an applicant include personnel costs in the project budget?
If yes, how should the daily rate be determined in such a case?
Is there an alternative methodology or another acceptable approach for determining personnel costs for applicants who do not have the data required to calculate the daily rate in accordance with the methodology specified in the Call documentation?

5. Is company established as a simple limited liability company (j.d.o.o.) in 2026 and classified as a micro-enterprise, an eligible applicant under the VALID Call, provided that all other eligibility requirements are met (e.g. startup status within five years of registration, enterprise size, etc.).

Applicants eligible under the VALID Call are defined in Section 4 of the Guidelines for Applicants:

c) it has not yet distributed profits;

6. Is an applicant considered eligible if the enterprise (micro or small enterprise) is incorporated/registered in August 2026, directly preceding the project application deadline? Given that the newly established enterprise will not have historical financial records (such as balance sheets, profit and loss statements) or prior payroll/salary disbursements at the time of submission, would this status negatively affect or disqualify the applicant during the financial capacity evaluation, provided that all other criteria under Section 4 are fully met (e.g., being an unlisted micro/small enterprise up to 5 years following its registration, not formed through a merger, and has not distributed profits)?

Eligible applicants are unlisted micro or small enterprises, up to 5 years following their registration, as defined in Annex I of Commission Regulation (EU) No. 651/2014 – SME definition, that meet Call criteria. Personnel costs shall be calculated in accordance with the methodology for calculating personnel costs, as defined in section 11 of GfA, which applies to both existing employees and newly hired staff working on the project. Whole month salary must be used for calculation.

7. Under this Call, is it eligible to fund research and development (R&D) activities focused on a substantial upgrade, a new version, or the implementation of entirely new innovative features, product modules and processes for an existing proprietary software product (which already has early users and paying customers)? Or must the project strictly focus on creating an entirely greenfield product with a brand-new market name?

The call supports experimental development activities (TRL 5–8). Applicants must include mandatory indicators defined in Section 3 of GfA in their project proposals.

8. Can the project implementation period, along with the eligibility of expenditures, start before the official signing of the Grant Agreement? What is the earliest possible start date for the project?

The project may not start before the submission of the project proposal, and no costs may be incurred before the submission date of the project proposal. All project activities and related costs must be completed and incurred no later than 31 October 2028.

9. After submitting the project proposal through eDIGIT, may the applicant start certain project-related activities (at its own risk) before Grant Agreement signing, provided that the project was not started before submission and is not completed before signing?

As stated in GfA, the project must not start before the submission of the project proposal, which means that project activities can start after the project submission and before GA signing.

10. If post-submission / pre-signature activities are included in the approved project scope and budget, can the related costs later be considered eligible/reimbursable, assuming that all procurement, documentation, payment, and reporting requirements are met?

Eligible costs are those incurred after the date of project proposal submission, and costs incurred before October 31, 2028. Activities and related costs incurred after submission of the project proposal may be considered eligible provided that they form part of the approved project scope and budget, comply with all applicable eligibility requirements, procurement rules, documentation and audit requirements.

11. Does the rule on procurement procedures before Grant Agreement entry into force apply only to procurement procedure preparation/selection, or also to signing contracts, receiving services, and incurring/paying costs before the Grant Agreement enters into force?

All grant beneficiaries must adhere to applicable procurement rules outlined in Annex I. Any procurement-related actions, including subsequent contractual arrangements and implementation activities arising from the project, irrespective of whether they are incurred before or after the signing of the Grant Agreement, must be in line with procurement rules set out in Call documentation.

12. Can insights or contacts generated through pre-award market activities be used as VALID outputs, costs, pilot participants, or mandatory indicators?

All outputs, results and indicators must be achieved as a result of the project activities carried out. Any outputs, indicators, participants or results reported under the project must comply with the approved project scope, eligibility requirements, reporting obligations and applicable verification procedures.

13. If post-submission / pre-signature activities are allowed, how should the applicant define the official project start date and M1 in the Application Form and Annex XII budget?

The project start date should be defined by the applicant in accordance with the planned implementation schedule and presented in the Application Form and Annex XII. Applicants are responsible for ensuring consistency between the proposed project timeline, planned activities and budget. Any activities undertaken at the applicant’s own risk prior to Grant Agreement signature should be reflected and documented in a manner consistent with the approved project implementation plan. Project activities cannot start before project submission.

14. What documentation would be required to prove that any pre-signature activity was started only after submission, was not completed before signing, complied with procurement rules, and does not constitute double financing?

All the costs must comply with the rules on eligibility and must adhere to national legislation and audit requirements. All the supporting documents that justify the incurred costs, for example, procurement contracts (goods and services) (and amendments, if any) with invoices from contractors and suppliers, service providers, acceptance certificates, lists and other documents proving the acceptability of costs (proof of publicity activities such as articles, photos, etc.), list of participants, studies, certificates, etc.), must be provided for verification within reports.On-site visits include verification of project activities and costs for which, in addition to administrative verification, it is also possible to verify the progress of physical indicators. The goal of on-site visits is to verify the actual implementation of the project, i.e. the costs and deliveries, and to obtain information that supports the conclusions of the administrative check, i.e. to provide a guarantee of the regularity and legality of the costs.

15. Could you please clarify definition of an Applicant in VALID Call? Specifically, what does the reference “public entity” GfA means, since Eligible applicants are enterprises?

In this Call, Applicant is private entity that intends to submit or has submitted a project proposal to this Call. Please note that the reference to a “public entity” in the Definitions section of the Guidelines for Applicants was included inadvertently. For the purposes of this Call, the term should be understood as referring to a private entity.

16. Can you please clarify the following call provision: grant cannot be awarded to an applicant/partner that is trade business? How exactly is “trade business” defined in the context of Croatian legislation?

For the purposes of this Call, the term “trade business” refers to business activity carried out by a natural person in the form of a craft/trade business.

17. The potential applicant is a new company established specifically for the further development and validation of an innovative solution.
Since the company is newly established, it has no personnel costs recorded in a completed financial year or month before application.
In this context, we kindly request a precise clarification regarding the calculation and supporting documentation for personnel costs:
1. Can the daily personnel cost rate for a project team member be calculated on the basis of the gross salary from a signed employment contract, if no payroll calculation is available for the month preceding the submission of the project proposal?
2. If an employment contract alone is not an acceptable basis, does the requirement referring to the payroll for the month preceding the submission mean that the employee must have been employed for the entire preceding calendar month, or may a payroll calculation covering only part of that month also be used?

18. In the Guidelines for applicants, eligibility is stated as: “Eligible applicants are unlisted micro or small enterprises, up to 5 years following their registration”. Please confirm that SMEs that are younger than 5 years at the time of application but will be older than 5 at the time of the call deadline and contract are eligible for funding. From which date do we calculate the applicant’s maximum age of 5 years?

The eligibility conditions regarding registration must be met at the time of submission of the project proposal. The date of incorporation shall be determined based on the company’s articles of association.

19. In Questions No. 3, 4 and 17, applicants asked for clarification on the methodology for calculating personnel costs in the case of newly established companies without employees. In all three replies, it was confirmed that personnel costs for newly hired staff are eligible, that the methodology from Section 11 of the GfA applies, and that a whole month salary must be used for calculation. However, none of the replies addressed the specific situation where an applicant has neither employees in the previous financial year nor a payroll record for the month preceding the submission of the project proposal.
Section 11 of the GfA provides that, in such cases, the daily rate shall be calculated based on the payroll(s) for the month preceding the submission of the project proposal. At the same time, neither the GfA nor the FAQ explicitly require applicants to employ staff prior to submission.
Therefore, we kindly request a precise clarification:
1. Does an applicant that had no employees in the previous financial year and does not have a payroll record for the month preceding the submission of the project proposal have the right to budget personnel costs for newly hired staff?
2. If the answer is yes, please specify the exact methodology and supporting documentation that should be used for calculating the daily rate in such circumstances.
3. If the answer is no, does this mean that, in practice, an applicant must employ at least one person before submitting the project proposal and have a payroll calculation for a full calendar month preceding submission in order to be able to calculate and budget personnel costs in accordance with Section 11 of the GfA?

In order to budget personnel costs, the applicant must have at least one employee during the calendar month preceding the submission of the project proposal. If the project is selected for funding, the applicant will be required to submit the supporting documentation used to calculate the personnel cost daily rate before the Award decision is issued. Accordingly, an applicant that has no employees during the calendar month preceding the submission of the project proposal is not eligible to budget personnel costs under the project.

20. Section 10 of the Guidelines for Applicants states that the overall grant intensity on project level may not exceed 80% of eligible costs. At the same time, chapter “Grants awarded to research organizations” states that grants awarded to research organization partners do not represent state aid and may reach up to 100% of
eligible costs. When applying the maximum permissible rates for eligible costs up to 80% for the enterprise applicant and up to 100% for the research organization partner the resulting overall project-level intensity mathematically exceeds 80%.
Please clarify whether the enterprise applicant’s aid intensity should be reduced below 80% in order to keep the overall project intensity within the 80% limit, or whether the research organization’s non-state-aid grant is excluded from this calculation?

The aid intensities specified in the Guidelines for Applicants represent the maximum grant intensities that may be awarded to each type of project partner. However, regardless of the maximum intensity applicable to individual partners, the overall grant intensity at the project level must not exceed 80% of the total eligible project costs. For the purpose of this calculation, the grant awarded to the research organization must also taken into account. It is the responsibility of the applicant, together with all project partners, to design a project budget that is realistic, complies with the rules of the Call, and ensures that the overall project grant intensity does not exceed the maximum level set in Call. Within these limits, applicants are free to determine the allocation of the budget and the grant intensities among the project partners, provided that all applicable eligibility and state aid rules are respected.

21. If a natural person who has independently developed software outside the scope of any company or registered business activity later establishes a new company to further develop and commercialise that software, would the use of such software be considered as “taking over the activity of another undertaking”? Or does this provision apply only to the transfer of business activities, assets or intellectual property from another undertaking (i.e. an existing legal entity or registered business)?

The condition set out in Section 4(a) of the Guidelines for Applicants refers to taking over the activity of another undertaking. For the purposes of State aid rules, an “undertaking” is an entity engaged in an economic activity, irrespective of its legal form. Development activities carried out by a natural person outside the scope of any registered business activity and without the performance of an economic activity (i.e. without offering goods or services on a market) do not, as such, constitute an undertaking within the meaning of this provision. Accordingly, Section 4(a) applies to the transfer of business activity, assets or intellectual property from an existing undertaking (a legal entity or a registered business activity, including a craft/trade business). Please note, however, that the Ministry cannot provide an assessment of the eligibility of a specific applicant without reviewing the complete project documentation; eligibility can only be determined during the formal evaluation process, based on all information and evidence submitted with the project proposal, including the accuracy of the statements provided in the Declaration by the Applicant.

22. According to Section 4 of the Guidelines for Applicants, eligible applicants must be unlisted micro or small enterprises that, among other conditions, “have not distributed profits”.
Could you please clarify whether this condition should be interpreted as an absolute eligibility criterion?
More specifically, if an otherwise eligible micro or small enterprise has distributed profits at any point prior to the submission of the application, does this automatically render the applicant ineligible under this Call, or are there any exceptions or specific circumstances under which such an enterprise could still be considered eligible?

Pursuant to Section 4(b) of the Guidelines for Applicants, an eligible applicant is an enterprise that has not yet distributed profits. This is an eligibility criterion that must be met at the time of submission of the project proposal. The Call documentation does not provide for any exceptions to this condition. Accordingly, an applicant that has distributed profits at any point prior to the submission of the project proposal does not meet this eligibility criterion.

23. If an applicant hires one person in August, pays one full monthly salary, and submits the project proposal in September, can the daily rate calculated based on this payslip be used to plan personnel costs for additional new employees who will work on the project after its start?

In other words, is it acceptable to use one employee’s reference salary from the month preceding the application submission to estimate personnel costs for two project employees, applying the same daily rate, with the actual costs later supported by employment contracts, payroll records, and timesheets?

The payroll of the employee hired in August (full month), with project application in September, serves as the calculation base for the fixed daily rate which applies to all persons working on the project, including existing and newly hired staff after project start, as stated in GfA, Section 11.

24. Does the person employed in the month preceding the submission of the application, whose salary is used as the basis for planning the costs of newly hired employees, need to remain employed until the start of project implementation (i.e. until project approval)? This is particularly relevant for start-up companies, for which avoiding the obligation to pay salaries before project approval and the start of implementation is important.

The Call does not prescribe that the applicant must have employees at the time of application submission or during the period preceding project implementation. However, the applicant must demonstrate sufficient implementation capacity in the project proposal, including the capacity to ensure the availability of appropriate human resources for successful project implementation. Personnel costs planned in the application must be justified in accordance with the Call rules supported by relevant employment documentation, payroll records and other required supporting documents (before Award decision and Grant Agreement signing).

25. In the application, we would potentially like to include more than three project collaborators. Could you please confirm whether it is possible to enter more than three collaborators in the portal and, if so, how additional collaborators should be added?

If should be possible to enter more than three collaborators in eDIGIT. All Declarations by the Collaborator may be uploaded jointly within the designated section.

26. Is the Call documentation available in Croatian?

The Call documentation is available in English only and the application must be completed in English.

27. Does the applicant need to have employees in the month preceding the application submission if it had employees during the previous year?

If the applicant had employees in the last closed full financial year, the daily rate is calculated using the formula defined in Section 11 of the Guidelines for Applicants, based on the total staff costs and annual work units from that financial year. The rule referring to the payroll for the month preceding the submission of the project proposal applies exclusively in cases where the applicant did not have any employees in the previous financial year.

28. If an applicant qualifies as an eligible applicant under Section 4. Eligible Applicants of the Guidelines for Applicants, namely as an unlisted micro or small enterprise, up to 5 years following its registration, as defined in Annex I to Commission Regulation (EU) No. 651/2014, and fulfils all other eligibility requirements, would the applicant remain eligible if it has a linked enterprise that was registered more than 5 years ago?

For the purposes of this Call, newly established SMEs are undertakings that were established no more than 60 months before the submission of the project proposal. This definition does not include existing undertakings that have been closed and reopened or undertakings resulting from mergers or demergers. Where the applicant is a linked enterprise within the meaning of Article 3 of Annex I to Commission Regulation (EU) No. 651/2014, the eligibility criterion relating to the age of the undertaking at the time of submission of the project proposal must also be fulfilled by all undertakings within that linked relationship in order for the applicant to be considered a newly established SME eligible under this Call.

29. Regarding references to literature in the project application, is inline referencing required, is it sufficient to provide only a list of references at the end of the relevant application section, or should references be provided in another format?

The Call documentation does not prescribe a specific referencing format. Applicants may use inline references, a list of references at the end of the relevant section, or another consistent format of their choice. Please note that all character limits in the Application form include spaces and apply to the full content of each section, including references.

30. Is an enterprise eligible as an applicant if it recorded 0 employees in FTE terms for 2025, but employs 1 person on a full-time basis in the month preceding the submission of the project proposal?

31. What are the durability requirements referenced in Article 7 of the Grant Agreement template, and does a change of ownership of the beneficiary or a transfer of project results to a third party during the five-year post-implementation period require prior approval?

The durability requirements referred to in Article 7 of the Grant Agreement template apply throughout the five-year period following the completion of project implementation. Any change related to the project during this period, including a change of ownership of the beneficiary or a transfer of project results to a third party, requires prior approval by the Contracting Authority. Beneficiaries are therefore required to notify and obtain approval for any changes that may affect the project, its results, or compliance with the obligations set out in the Grant Agreement.

32. If an applicant qualifies as an eligible applicant under Section 4. Eligible Applicants of the Guidelines for Applicants, namely as an unlisted micro or small enterprise, up to 5 years following its registration, as defined in Annex I to Commission Regulation (EU) No. 651/2014, and fulfils all other eligibility requirements, would the applicant remain eligible if it has a linked enterprise that was registered more than 5 years ago?

Where the applicant is a linked enterprise within the meaning of Article 3 of Annex I to Commission Regulation (EU) No. 651/2014, the eligibility criterion relating to the age of the undertaking at the time of submission of the project proposal must also be fulfilled by all undertakings within that linked relationship in order for the applicant to be considered a newly established SME eligible under this Call.

33. Is a project under the VALID Call eligible if it focuses on developing an innovation that represents a green/environmentally friendly product, while the final product would later be commercialised through the company’s production activities? Can the expected project result reach TRL 8, or is it possible for the project to also include bringing the product to TRL 9 and market readiness?

The project may be eligible only if the green product simultaneously constitutes a social innovation addressing a defined societal need; the Call supports experimental development up to TRL 8, and activities aimed at TRL 9 / market launch are not supported.

34. Is it possible to finance the procurement or depreciation costs of a company-owned machine if the machine is used for testing and producing the prototype, i.e. if the prototype is manufactured using that specific equipment?

Depreciation costs of instruments and equipment necessary for the implementation of the project are eligible, provided the equipment is used during the project period. If the instruments and equipment are not used for the project during their entire useful life, only the depreciation costs incurred during the project period, and corresponding to the extent of use on the project, will be considered eligible, in accordance with generally accepted accounting principles.

35. If the applicant currently employs a person whose salary is supported through an HZZ subsidy (where the employer’s current cost corresponds to gross salary level 1, as the subsidy covers part of the gross 2 cost for several more months), please clarify the following:
When budgeting the reference salary, should the applicant use the gross 1 amount in order to avoid overlapping with the HZZ subsidy?
Furthermore, if the project is approved and implemented, can the current gross 1 employer cost be considered as an eligible gross 2 personnel cost under the Call, given that the HZZ subsidy will have expired by then? The gross 2 amount would be defined through an amendment to the employee’s contract. Therefore, the employer’s total cost would remain unchanged and would not increase due to the expiry of the HZZ subsidy.

The applicant should include in the calculation of personnel costs the actual salary-related costs incurred by the employer, while ensuring that no double financing occurs. Any costs already covered by other public sources, including HZZ subsidies, cannot be financed from the project budget for the same period and purpose. In accordance with the personnel cost calculation methodology defined under the Call, the applicant should calculate the daily personnel cost rate based on the eligible salary costs and determine the number of days that the employee will be engaged in project activities. The eligible amount will then be calculated and reimbursed based on the actual number of days worked on the project, in line with the approved methodology and applicable reporting requirements.

36. In the case of developing a digital platform that is directly linked to achieving the project objectives, is the cost of engaging external IT experts for the development of the platform considered an external research activity cost and therefore subject to the 10% limit of total eligible project costs?

In accordance with Table 3 of the Guidelines for Applicants, costs of contractual research (external research services) are eligible only if the research team cannot independently carry out the activities concerned, and up to 10% of total eligible direct project costs.

37. If a public institution in Croatia is a Project Collaborator, can one of its employees be contracted by the project as an external expert (e.g. through a service contract), or must all work performed by institution employees be carried out exclusively through the institution as the Project Collaborator?

It is not eligible to be contracted as external expert in project while also working for Collaborator.

38. A potential partner is a j.d.o.o. (simplified limited liability company) with a subscribed capital of €1. In the financial year 2025, the undertaking recorded a net loss of €26,243, which significantly exceeds the subscribed capital. However, the total equity and reserves as of 31 December 2025 amount to €50,799 – a positive value – due to accumulated retained earnings from previous profitable years.
Is the above-described undertaking considered an “undertaking in difficulty” within the meaning of Article 2(18) of Commission Regulation (EU) No 651/2014, and is it therefore excluded from participating in this Call as a partner?

The exclusion criteria applicable to applicants and partners are set out in Section 1.1 of Annex I to the Call documentation. Without reviewing the complete project application and all relevant supporting documentation, the Ministry cannot provide a prior assessment or interpretation of whether a specific applicant or partner meets the eligibility requirements. Compliance with all eligibility requirements, including the exclusion criteria, will be assessed based on the complete application and the supporting documentation submitted, in accordance with the provisions of the Call documentation.

39. Is the transfer of business activities from a sole proprietorship (craft/trade business) owned by a natural person to a newly established limited liability company (j.d.o.o.) owned by the same person considered a “takeover of the activities of another undertaking” within the meaning of Section 4(a) of the Guidelines for Applicants? Correction 28.07.2026

Please see answer to Q#21.

40. Can an individual natural person (e.g. a professor, researcher or other expert), acting in a personal capacity and without financial compensation, be designated as a Project Collaborator and sign Annex X (Declaration by the Collaborator), or must Project Collaborators be legal entities only?
Can a d.o.o. company that is 100% publicly owned by local government (županija, grad) be listed as a project collaborator if it does not receive any project funding and only supports the project as a collaborator would?

As defined in GfA, Section 6. project collaborators may include entities from the Republic of Croatia or abroad: Other non-profit organizations, State authorities and public administration bodies, Local and regional self-government units, Public institutions providing social, educational, healthcare, cultural, environmental, or community services, where relevant to the social challenge addressed, Non-governmental organizations (NGOs) that contribute domain expertise, community engagement, or representation of user needs.

A company (d.o.o.) that is 100% owned by a local or regional self-government unit may be designated as a Project Collaborator, provided that it fulfils the role of a collaborator as defined in the Guidelines for Applicants. The applicant should clearly describe the collaborator’s role, expected contribution and added value for the project in the Application form. As a Project Collaborator, the entity does not receive project funding and does not act as a beneficiary or project partner.

41. Will the supplementary work contract be accepted for calculation of annual work units (AWU), considering that one additional person will be newly employed at FTE post project start? In case of supplementary work contract that has defined gross salary for specific number of working hours per month, can this be used to calculate hourly rate and from that the daily/monthly rate of FTE. If not, please advise how to calculate the AWU.
Does the daily rate calculated from the supplementary work contract applies to all the applicant’s staff working on the project (including staff employed after the submission of the project proposal, i.e. new FTE employees), regardless of their individual salary levels?

A supplementary employment arrangement (additional work) cannot be used as the basis for calculating the daily rate under the Call. The daily rate must be calculated based on the salary costs of an employee engaged under a full-time employment relationship (1 FTE) for a full month, in accordance with the methodology set out in the Call documentation. Accordingly, a supplementary employment arrangement cannot be used for the calculation of the annual work units (AWU), hourly rate, daily rate or monthly personnel cost rate for the purposes of the project budget. The daily rate calculated in accordance with the prescribed methodology applies to all personnel whose costs are declared under the project, including employees hired after the submission of the project proposal, provided that the personnel costs are eligible under the Call and that all other applicable eligibility conditions are met.

42. Is it possible to employ a person under a supplementary employment arrangement (additional work)? The company currently has an employee whose salary would be used as the reference salary; however, after project approval, the company would employ two persons under additional work arrangements for project activities. Would this approach be considered eligible?

The Call documentation does not prescribe a specific type of employment contract for persons working on the project. Personnel costs are eligible, provided that the engagement complies with applicable national labour legislation and that the costs are supported by employment contracts, payroll records, and monthly timesheets signed by the employee and the project manager.
Please note that, in the project proposal, the applicant should plan the capacities and workload of the project team in accordance with the planned project activities. The engagement of each person in the project activities must be specified and described in the Application form, and the adequacy of the project team’s capacity to implement the planned activities is subject to quality assessment. Any planned engagement arrangement, including supplementary employment, must therefore be realistic and consistent with the workload foreseen for the respective project activities.
The Ministry cannot provide a prior assessment of the eligibility of a specific engagement arrangement; compliance will be verified during project implementation based on the submitted supporting documentation.

43. If we don’t plan to fund the salary, only the other types of costs, is it necessary to hire someone at least a month before the project application? For example, we would attach the CV of the Company owner, even if not employed in the company yet. If we’re not requesting funding for salaries, can we apply without any employees in the moment of application? Also do we need to hire someone (on our cost, but to have an employee) if we manage to sign the contract and start the project implementation?

The applicant it is not required to employ staff at the time of submitting the application if no personnel costs are planned under the project budget.
However, regardless of whether personnel costs are claimed, the applicant must demonstrate that they have, or will have, sufficient operational and professional capacity to successfully implement the project. The project proposal should therefore clearly describe the planned project team, the roles and responsibilities of the persons involved, and how the necessary capacities for project implementation will be ensured. Where relevant, the qualifications and experience of key persons should be evidenced through the documentation required under the Call (e.g. CVs).
The adequacy of the proposed implementation capacity will be assessed as part of the quality assessment. During project implementation, the beneficiary must ensure that the planned capacities are available and that the project is implemented in accordance with the approved proposal and the applicable eligibility rules.

44. Are data on the number of employees irrelevant for the purposes of eligibility under this Call? In other words, may an enterprise that has no employees at all at the moment of submission of the project proposal apply, with the intention of employing staff only after the grant has been awarded? We kindly ask for a clarification of this point, as it is not clear from the previous answers.

If the applicant plans to include personnel costs in the project budget, the applicant must have employees both at the time of submission of the project proposal and at the time of Grant Agreement signature. In addition, the applicant must demonstrate that it has adequate operational and professional capacity to implement the project, as described in the Application form.
For the purpose of calculating the reference personnel cost, the methodology set out in the Call documentation applies:
• if the applicant had employees during the previous financial year, the daily rate is calculated on the basis of the data reported in the annual financial statements (GFI);
• if the applicant did not have any employees during the previous financial year, the daily rate is calculated on the basis of the salary data for the month preceding the submission of the project proposal, in accordance with the methodology prescribed by the Call.

45. Regarding Environmental and Social Screening Questionnaire:
a) Are the questions 34. to 39. exclusivelly realated to AI, i.e., question 33?
b) Does answering “Yes” to “Have the potential social impacts of the project results been considered? […]” imply exclusivelly negative social impact or is it an assessment question if the social impacts were even considered on the project? Are we talking about potential or established negative impact, if so?
c) Are Question 26 and Question 32 duplicates, or is there different context to them?
d) Is the applicant expected to sign anywhere on the questionnaire sheet?

a)Yes. Questions 34–39 are applicable to projects involving the development or upgrade of AI, as referred to in Question 33. If the answer to Question 33 is “No”, Questions 34–39 may be marked as “Not applicable”. Please note that Questions 40–44 relate to stakeholder engagement and should be completed regardless of whether the project involves AI.

b)Answering “Yes” does not imply that the project has a negative social impact. The question asks whether potential social impacts of the project results have been considered and assessed.
The assessment should consider both potential positive and negative social impacts. Where potential impacts have been identified, they should be briefly described in the “Additional Clarifications” section. A “Yes” answer therefore indicates that social impacts have been considered, not that a negative social impact has been established.

c)Questions 26 and 32 are duplicated due to an inadvertent error in the questionnaire. Applicants may provide the requested information under either Question 26 or Question 32 and, under the other question, refer to the response already provided.
Please note that Question 32 provides additional examples of potential social impacts that may be considered when preparing the response.

d)No. The applicant is not required to sign the Environmental and Social Screening Questionnaire (ESSQ).

46. Is it neccessary for a d.o.o. to have a stamp, or is it allowed to mentioned on such fields that “Operates without a stamp” or any similar formulation?

Croatian law does not require a company to hold or use a stamp. Where the applicant, partner or collaborator does not use a stamp, a document is validly executed when it is signed by the person authorised to represent the entity.

In fields that provide for a stamp, such an entity may enter a note (for example, “Operates without a stamp”) or leave the field blank. The absence of a stamp will not lead to rejection at the administrative check, provided the document is duly signed by the authorised representative and submitted in accordance with the prescribed template.

47. Should the applicant and each partner sign their own Group Statement and then merge it into a single PDF, or are they expected to add lines to the first section and their own separators for the ownership structures in Table 1?

Each enterprise involved as applicant or partner completes and signs its own separate Group statement. The form is designed for a single entity: Table 1 provides for one applicant/project partner, and the signature block provides for one authorised representative.
Applicants should not enter several entities as additional rows in the first section of Table 1, and should not insert their own separators for multiple ownership structures. The form states that it may not be changed in any way, except in the tables where rows may be added; rows are added to record a single entity’s own related enterprises, related persons and partner enterprises (Tables 2, 3 and 4), not to record a second applicant or partner.
For each enterprise, both a completed and signed version in .pdf and a completed version in .xls or .xlsx are required. Where the project involves partners, the individual PDF files should not be merged into one document; all files are submitted together in the designated section of eDIGIT.
As stated in Table 7. Chapter 12 of the Guidelines sll documents must be submitted together in a .zip file (English).

48. Please provide clarification on the scope of the answers to Questions 28 and 32 concerning the age (maximum 60 months) eligibility criterion for a newly established SME under Section 4 of the Guidelines for Applicants. Those answers state that, where the applicant stands in a relationship within the meaning of Article 3 of Annex I to Commission Regulation (EU) No 651/2014, the age criterion must be met by all undertakings in that relationship. We would appreciate confirmation on the following:
(a) Where an undertaking holds between 25% and 50% of the applicant’s capital or voting rights, with no other indicator of dominant influence, and therefore qualifies as a partner enterprise under Article 3(2), does the age of that partner enterprise affect the applicant’s status as a newly established SME?
(b) Where a natural person (or several natural persons acting jointly) controls both the applicant and one or more other undertakings — for example a sole proprietorship established more than five years ago — are those undertakings connected to the applicant solely because of that common ownership, or only where they also operate in the same relevant market or in adjacent (upstream/downstream) markets, as provided in the final subparagraph of Article 3(3)?
(c) Where the undertakings have some overlapping registered activities or NACE classifications but their actual business operations, revenue, customers and markets differ, is operation “in the same or adjacent market” assessed on the basis of registered activities or on the basis of the activities actually carried out and generating revenue?
(d) The application documentation does not provide a dedicated field for explaining the actual activities and revenue structure of the entities. May such circumstances be demonstrated at the request of the competent authority during the eligibility check?

a)Where an undertaking holds between 25% and 50% of the applicant’s capital or voting rights and none of the relationships listed in Article 3(3) is present, it is a partner enterprise within the meaning of Article 3(2). As this is a relationship under Article 3, the age of the partner enterprise is taken into account: if the partner enterprise was established more than 60 months before the submission of the project proposal, the applicant does not qualify as a newly established SME. Data on partner enterprises are also used to determine the applicant’s enterprise category (micro, small, medium, large) on a proportional basis under Article 6 of Annex I, and are reported in Table 4 of the Group statement.

b)Common ownership by the same natural person or by a group of natural persons acting jointly does not, in itself, automatically create a relationship under Article 3. Whether such a connection results in a linked relationship within the meaning of Article 3(3) is determined during the eligibility evaluation, on the basis of the complete data relating to all related enterprises and all related natural persons.
The applicant is therefore required to disclose in the Group statement all related enterprises and all related persons, together with the ownership and control relationships between them.

c)The existence of an Article 3 relationship is assessed on the basis of the actual ownership and control relationships, not solely on the basis of registered activities or NACE codes. This assessment is carried out by the Ministry during the eligibility check, using the data disclosed in the Group statement and other available sources of information.

d) The applicant reports all related enterprises and related persons in the Group statement (connections through natural persons in Table 3, partner enterprises in Table 4), together with the associated ownership and control data. The applicant should provide the complete data on all such relationships rather than a selection. Ministry may request additional clarification or documentation during the eligibility check. The burden of proof regarding all facts relevant to establishing the status of an autonomous enterprise lies with the applicant.

The Ministry cannot assess the eligibility of a specific applicant or ownership structure in advance. Eligibility is determined during the evaluation on the basis of the complete project proposal and all supporting documentation, including the accuracy of the statements in the Declaration by the Applicant.

49. Should an owner or management board member who will participate in project governance without being employed by the applicant and without claiming personnel costs be included in the Project team members table, considering that the Employment status field only provides the options “existing employee” and “new employee”? If such a person should be included, which employment status should be selected?

A person who participates in the management or governance of the project should be listed in the Project team members table, whether or not personnel costs are claimed for that person. The table covers all individuals responsible for the administrative and managerial aspects of the project.
For a person already engaged with the applicant and for whom no new employment is foreseen, select “Existing staff”. The nature of the engagement — for example, participation as owner or member of the management board without an employment relationship — and the fact that no personnel costs are claimed should be described in the Project management section of the Application form. The planned FTE engagement should reflect the time the person will actually devote to the project.

50. Is a private university or private higher education institution eligible to participate as a project partner under the VALID Call in the capacity of a research organisation (RO)?

Under Section 5 of the Guidelines for Applicants, eligible partners include Croatian private higher education institutions and private research institutes, established in accordance with the Law on Higher Education and Scientific Activity, that carry out research activities as set out in their statute or other act proving their legal status. “Private higher education institution” and “private research institute” are among the partner legal-entity types provided for in the Application form.

Whether such a partner may receive a grant intensity of up to 100% depends on it meeting the definition of a research and knowledge-dissemination organisation in the Guidelines for Applicants (Annex E of the Annex I) and in the Framework for State Aid for Research and Development and Innovation (2022/C 414/01). In particular, where the entity also carries out economic activities, the financing, costs and revenues of the economic and non-economic activities must be accounted for separately, and undertakings able to exert decisive influence over the organisation may not enjoy preferential access to its results. Where the statute or equivalent act is not publicly available, it must be submitted with the application.

51. Does the non-achievement or partial achievement of project indicators result in a predefined financial correction? If so, please provide the applicable methodology, thresholds and correction percentages, particularly for impact indicators that are to be achieved three or five years after project completion, such as the number of social innovation users.

The Grant Agreement obliges the Beneficiary to achieve the indicators set out in Annex I to the Agreement. The Call documentation does not prescribe a fixed scale of financial corrections linked to defined thresholds of indicator achievement.
Where indicators are not achieved or are only partially achieved, the matter is assessed individually. Under the Grant Agreement, financial corrections for non-achievement will not be applied where the non-achievement results from force majeure or from socio-economic or environmental factors, including significant changes in economic or environmental conditions in the country that affected the achievement of the indicators; the competent authority assesses each case and determines whether such factors occurred and whether the indicators could have been achieved. More generally, the MSEY may suspend or terminate the Beneficiary’s right to use the grant, or seek a refund of all or part of the withdrawn amount, where the Beneficiary fails to perform its obligations under the Grant Agreement.
Applicants are advised to set realistic, well-justified target values, supported by the rationale required in the Outcome and output indicators section of the Application form.

52. Question is related to Methodology for calculating personnel costs. Could you please clarify which supporting documentation will be required to verify the calculation of Annual Work Units (AWU)? Specifically, will the AWU be verified based on the number of employees (according to hours worked) reported in the 2025 annual financial statements (Broj zaposlenih prema satima rada), or may applicants calculate and demonstrate AWU using JOPPD payroll records?
We are asking because the number of employees reported in the annual financial statements is rounded to a whole number and therefore may not accurately reflect the actual Full-Time Equivalent (FTE) employment, particularly where employees work part-time or only for part of the year.

Annual work units (AWU) are defined in Section 11.1 of the Guidelines for Applicants. The AWU figure is taken from the “Number of employees based on hours worked” as reflected in the annual financial statement of the enterprise for the last closed full financial year (or another equivalent document), and the daily rate is calculated in accordance with the methodology set out in Section 11.1 of the Guidelines for Applicants.

The methodology is applied as defined in the Call. The calculation of the daily rate, including the AWU value used, is subject to cost eligibility verification and budget cleaning, during which applicants will be requested to provide the supporting documentation used as the basis for the calculation.

Corrections to Q1 and Q39 published.

Call for proposals "Validation of Social Innovations by Startups (VALID)"