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Yes, the Accounts should be submitted (with zero expenditure), a disclaimer of opinion can be issued (in section Audit opinion > Opinion).

The updated guidance note "Guidance for Member States on the Annual Control Report and Audit Opinion to be reported by audit authorities and on the treatment of errors detected by audit authorities in view of establishing and reporting reliable total residual error rates (EGESIF_15-0002-04)" is published on Inforegio(*) under Management and Control and clarifies that:

(refer to page 37)

Yes, unless no expenses are declared in Appendix 1 and Appendix 7 of the Accounts.

When creating the Accounts the system automatically copies the amounts in Appendix 1 and Appendix 7 from the Final Payment Application for the Accounting year.

If the Final Payment Application has not been submitted in SFC2014, the same amounts that would be declared in the Final Payment Application should be entered in Appendix 1 and Appendix 7.