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no

ACC - Expenditure - Should the Accounts be submitted if there's no expenditure in the Accounting year?

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)