Guides

Justifying a cultural grant

Revised on 7 November 2026. Should any information have changed, please notify me and I shall update it.

A grant is conditional funding. The recipient undertakes to perform an activity and to demonstrate, within a set period, that it was performed and how the money was spent. If they fail to demonstrate this adequately, they must return the funds, with interest. The law terms this demonstration 'justification', and it is described here for grants subject to Law 38/2003, the General Subsidies Act, and its regulations. Autonomous communities have their own laws, and the terms of each call for applications specify what appears here in general terms. In the event of any discrepancy, the terms of the call prevail.

Before incurring the first expense

Justification must be prepared at the outset. Open a folder for each grant and store the award resolution, the terms and conditions, the submitted project and the approved budget. Verify three key details: the period during which expenses are eligible, the deadline for justification and the type of reporting required by the terms and conditions.

If the approved budget does not match the one submitted, because you were awarded less than requested, check whether the terms and conditions require you to reformulate it. Executing the original project with less funding without prior notification is a direct route to complications during the justification process.

Reporting methods

The most common method is the standard justification report, which requires the submission of supporting documents. It consists of two parts. The performance report details what was done, when, with whom and with what results, comparing these against the original proposal. The financial report lists expenditure categorised by budget line, including the creditor, invoice number, amount, date of issue and date of payment; it must include the invoices and proof of payment, detail other income or grants that funded the same activity and, if there is a surplus, provide evidence of its repayment.

The justification report with an auditor's certificate replaces the submission of invoices with a review by a registered auditor. The cost of this service may be an eligible expense if permitted by the terms and conditions.

The simplified justification report is intended for grants of less than 60,000 euros where specified by the terms and conditions. A performance report and a classified list of expenses are submitted without invoices, and the administration subsequently audits a sample. For aid financed by Recovery Plan funds, Royal Decree-Law 36/2020 raised this limit to 100,000 euros. Not submitting invoices does not mean they are not required: if your file is selected for the sample, they will be requested.

Some terms and conditions use other formulas, such as standard scales or financial statements. If this applies to you, the terms and conditions themselves will describe the required content.

Eligible expenditure

The law defines eligible expenditure as that which clearly relates to the nature of the activity, is strictly necessary and is incurred within the established timeframe. Unless the terms and conditions state otherwise, only expenditure effectively paid before the end of the justification period is counted: an invoice issued but not paid within that period does not constitute valid evidence.

There are rules that often surprise those justifying a grant for the first time:

Input VAT is only eligible if it cannot be recovered. An artist under the general VAT regime deducts it in their tax returns and therefore cannot charge it to the grant. An exempt association that does not deduct VAT may do so.

When expenditure exceeds the thresholds for minor contracts applicable to the type of service, you must solicit at least three tenders from different suppliers before contracting, except in specified cases. Retain all three.

Cash payments between professionals are limited by law to 1,000 euros, and many terms and conditions prohibit them entirely. Pay by bank transfer and retain the statement.

Your own labour is the question with the least general consensus. Some terms and conditions permit fees for the individual beneficiary within set limits; others exclude them. If the terms do not clarify this, submit a written enquiry to the managing body before allocating them.

Deadlines and requirements

The justification period is established by the terms and conditions or the resolution. If the deadline arrives without you having submitted anything, the administration will require you to do so within fifteen days. This requirement does not extend the deadline in your favour: it serves to avoid full repayment, but may result in a penalty.

If execution is delayed, request an extension of the deadline before it expires. Once expired, it cannot be extended.

Repayment

The administration may demand full or partial repayment when the activity was not performed, when it was insufficiently justified, when the obligation to publicise public funding was not met, or when the aid was obtained by falsifying conditions, among other reasons. Default interest from the date of payment is added to the amount.

The obligation to publicise is easy to forget and easy to fulfil: include the logo or mention of the organisation on posters, websites, catalogues and social media, in the terms specified by the guidelines. Photograph the materials and store them in the folder.

The administration's right to claim expires, in general, after four years. Retain the documentation for at least that period.

A table that saves work

My recommendation: maintain a spreadsheet from the first day with these columns: approved budget item, supplier, tax identification number, description, invoice number, invoice date, base amount, VAT, total, payment date, payment method, amount allocated to the grant and file location. At the end of the project, this sheet is effectively the financial report. And if the administration requests a specific receipt months later, you will find it in a minute.

On the open conversation

If you work in a grant-managing body or have undergone a repayment process, your experience can improve this guide. This notebook remains open.

Sources

Law 38/2003, General Subsidies Act, arts. 18, 30, 31, 37 and 39.
Royal Decree 887/2006, Regulations of the General Subsidies Act, arts. 69 to 75 and 70.3.
Royal Decree-Law 36/2020, of 30 December, art. 63.
Law 7/2012, art. 7, on the limitation of cash payments.