All Users who have the role MSPA (Paying Agency) or MSCB (Coordinating Body) on a Node (top or lower Node) where the Declaration EAFRD was created can download XML files for expenditure and sign for any paying agency. In fact, in terms of security, SFC2021 only recognizes that Users have the MSPA or MSCB role for a given Node, but it does not know that such a User actually serves a paying agency or not. Moreover, for reasons of flexibility/ease (as some MS do not have a Coordinating Body), there is no real distinction between the MSPA and MSCB roles, both can create, upload files, sign and send the Declaration EAFRD to the Commission. It is up to the Member State to ensure that the right people upload and sign for the right paying agencies, and also to ensure that the right person sends the Declaration to the Commission.