If you are a beneficiary of an EIC Accelerator blended action, you are requested to complete the Know Your Customer (KYC) and Due Diligence processes for the investment part of your project. Both are long, time-consuming analyses that require you to provide numerous documents and a lot of information.

What happens if at the end of this process you receive a rejection letter from the EIC Fund (EICF) that says that the intended investment has been categorised as a bucket 0 case, and that the EC staff in charge of the grant part of your project has been informed about the EICF decision?

What does bucket 0 mean?

All operations are assigned to specific categories (buckets) based on their level of maturity in terms of attracting investors and the results of KYC and DD analyses (from bucket 0 to 3).

According to the EIC Fund Investment guidelines, bucket 0 includes cases for which conducted assessment revealed substantial negative issues preventing investment. The guidelines provide examples of various types of such issues:

• fraud, money laundering, tax avoidance
• failure to submit requested information or submission of false data
• significant changes to the scope of the project putting into question its commercial potential or resulting in the team losing key competences for the project
• issues related to the company’s ownership structure or IPR.

If the analysis conducted revealed substantial negative changes calling into question the decision awarding the grant, the EC may also decide on the termination of your grant agreement.

Can you appeal?

There is no established appeal procedure for this decision.

You can however reach out to the Investment Officer (from the EIB) who assisted you during the investment process to request further clarification regarding this decision and inquire whether there is still an opening for a discussion.  Especially if the provided rationale for the decision is very general and does not give any specific indications of where the problem lies.

Does this mean that your grant is at risk?

Not necessarily.

The EC tends to apply a case-by-case approach, and the negative investment decision doesn’t mean that your EIC Accelerator project cannot be continued.

Various factors can influence the EICF decision and not all of them necessarily pose a risk to your grant. For that reason, every situation requires individual analysis.  

Would you like to discuss your specific case and consult on possible further actions? Feel free to reach out to us – [email protected]