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Frequently asked questions

Eligible expenditure shall be investment expenditure relating to the implementation of a works contractin accordance with Article 13 of Law 9/2017, of 8 November, on Public Sector Contracts, provided that they respond to the nature of the subsidized purposes and that they are carried out after 28 October 2024.

Under the same conditions, the commissions to a medium of one's own personified, formalized in the terms provided in article 34 of Law 9/2017, of November 8.

In accordance with paragraph 5(2) of Order TMD/101/2025, of 31 January, the Project Development Costs (Development of construction projects, construction management and the cost of health and safety coordinator during construction). This includes the expenses incurred by the local entity for the preparation of all the documentation comprising the project works to satisfy the provisions of article 233.1 of Law 9/2017, of 8 November, on Public Sector Contracts.

In addition, they will also be eligible the costs of technical work that proves necessary for the preparation of the respective projects (e.g. Geotechnical studies, topographic surveys, etc. ), as well as the costs of drafting the corresponding valued report that had been submitted to the Ministry of Territorial Policy and Democratic Memory.

Now, all these expenses will be financiable provided they have been contracted or specifically commissioned for works subject to subsidy, in accordance with Law 9/2017, of 8 November, on Public Sector Contracts.

Also, through a project of technical assistanceeligible expenses directly linked to the preparation, management, monitoring, control and justification of projects financed under Order TMD/101/2025 shall be eligible.

No. the works carried out in the execution of the work with non-personified own media of the local entity, be it materials, machinery or personnel.

Neither will the acquisition, lease or rental of a product or movable property be eligible, this type of actions are typical of a supply contract which is not the subject of the subsidies regulated in this order.

As stated in paragraph 5 of Order TMD/101/2025 of 31 January, “Value Added Tax will be considered eligible as long as it cannot be eligible for full or partial recovery or compensation.”

Consequently, for the purposes of these subsidies, the amount of VAT it will be bankable if the beneficiary entity has supported it and cannot deduct it in accordance with Law 37/1992, of 28 December, on Value Added Tax, all this, regardless of whether that VAT has been paid for a service performed in execution of a contract or an order.

It will not be possiblesince the main purpose of the grant is to finance projects aimed at repairing, restoring or reconstructing works, eligible expenditure being investment expenditure relating to the performance of a works contract (see 11th paragraph, 3, a, 4th: «Budget of the works broken down by chapters, taxes included. If applicable, the costs of preparation of construction projects, construction management and health and safety coordinator during the execution of the work that the entity will incur’, of Order TMD/101/2025, of 31 January).

In accordance with paragraph 5(2) of Order TMD/101/2025 of 31 January, “Project development costs, construction management and health and safety coordinator costs during the execution of the work will be eligible if they have been specifically contracted for the work to be subsidised.”

This concept includes the costs of writing the respective valued memory. If such expenditure has been subsidised by another aid, it cannot be included in the section of other costs, While the costs of: project development, construction management and health and safety coordinator, if not subsidised by the other aid, may be included.

Taking into account that these expenses will be financiable as long as they have been contracted or commissioned specifically for the works subject to subsidy, in accordance with Law 9/2017, of November 8, on Public Sector Contracts. They will not be eligible if they have been carried out with their own non-personified means of the local entity, whether materials, machinery or personnel.

No. The hiring of an emergency technician and/or emergency inspector will be accepted, since it is not included in the object of the grant.

It should be taken into account that a rented property It was not a municipal owned infrastructure, equipment or facility. Therefore, they will only be considered elements of municipal ownership recorded investments that would have been carried out by the local authority in those facilities for condition them for the provision of public service.

Consequently, in that case, the eligible cost would remain bounded to those who had the works of repair, restitution or reconstruction of the elements that were of municipal ownership to return them to the state that they previously had.

The revenue that the concessionaire could obtain would not be relevant for the purposes of this subsidy. In order to be able to finance the recovery works from this grant, it is necessary that the concessionaire has no legal obligation to take over the works.

In this regard, in indirectly managed services, the local entity must certify that, in accordance with the conditions stipulated in the contract, is obliged to carry out and finance from its budget the works of repair, restitution or reconstruction contained in the project.

It will be possible to hire staff with the Qualifications to perform the tasks indicated on that point, that is, activities to manage, monitor and justify the grants awarded.

They can be done: service contracts; orders to own resources; -and/or municipal personnel assigned or contracted specifically for these tasks, as provided in the applicable regulations.

The amount of aid to be received for these items shall be determined as follows: such a high, by applying a percentage of 3.5 percent on eligible expenses that have been properly justified In all the projects presented by the entity. This amount must be included within the grant granted, without being able to generate a further increase in the aid granted.

Consequently, the maximum admissible amount will be the lower of 3.5% of the finally justified eligible expenses and 3.5% of the total amount of the grant granted.

In this way, if the amount finally justified is lower than the one granted, the calculation will be made on the justified amount, without applying 3.5% on unexecuted amounts.

This project must be presented until 3 p.m. on 5 July 2026as well as the other regular projects, in accordance with point 2 of the 10th paragraph of WTO/101/2025 as amended by WTO/1586/2025. Any project submitted after the deadline will be inadmissible.

Eligible expenses within the technical assistance project are those directly linked to the preparation, management, monitoring, control and justification of projects financed under Order TMD/101/2025. In particular, the following types of expenditure may be charged::

(a) External service contracts, such as: technical support in the preparation of projects; assistance in administrative or economic management; specialist consultancy; support in documentary or technical justification.

b) Commissions to own media personified, provided that: the order is formalized according to the applicable regulations; the object of the order is directly related to the technical assistance tasks; the cost is determined according to the system of tariffs or cost structure approved for the own medium.

(c) Specifically seconded or contracted municipal staff in the case of municipal personnel specifically assigned to technical assistance tasks, or additional personnel have been recruited for the execution of such tasks, always within the applicable regulatory framework.

Being an estimate, it seems advisable to include the indicated increases. As indicated in the email sent to all local entities with the operating guidelines of the new technical assistance project.

Yesin the case of technical assistance, the settlement shall be made for the amount actually certified, without penalty for the entity when it is less than the authorized amount.

Currently, according to OTMD 101/2025, Once the application period is closed, no changes can be made.

Exceptionally, in the event that the final real costs exceed the amount requested, they are check whether the justified actual cost of care is within the limits indicated in response 2.2. On the assumption that these limits shall not be exceeded, it would be studied how to compensate it in case they have amount of subsidy granted unused.

Projects can be submitted until 3 p.m. on 5 July 2026. Any project submitted after the deadline will be inadmissible.

However, as reflected in point 1, paragraph Eighteenth. Extension of the deadlines of the OTMD 101/2025: The Commissioner may agree, ex officio or at the request of the beneficiary entities, if the circumstances so warrant and in so doing do not prejudice third party rights, up to two extensions of the period established in the tenth paragraph that do not exceed, each of them, six months.

Regarding the deadline for submission of the award formas stipulated in paragraph 15 of WTO/101/2025 as amended by WTO/1586/2025 (extended by DGCAL Resolution dated 7/10/2025): In the maximum period of twelve months Following the acceptance of the project by the Commissioner, the beneficiary entities will communicate through the application “ALBA-DANA 2024” the list of contracts or work assignments through which they will execute the project.

In the event that one is necessary enlargement the time limit for submission of the award form, as set out in point 2a of paragraph Eighteenth of that order, before the deadline, refer to DIR EA0056568 - Office for Coordination and Promotion of the Execution of Aid (belonging to Commissioner DANA), through the General Electronic Register, job with motivated request for an extension which may be at most 6 months.

The works must be finished in the maximum period of twenty-four months from the date of its validation. In the case of the minor contractsthe implementation period may not exceed 12 months.

If one is necessary enlargement of that time limit, in contracts which they are not minorsas reflected in paragraph 2b of paragraph Eighteenth of TMD 101/2025, before the deadline, refer to DIR EA0056568 - Office for Coordination and Promotion of the Execution of Aid (belonging to Commissioner DANA), through the General Electronic Register, job with motivated request for an extension which may be at most 24 months.

The beneficiary entities must present the supporting documentation in the time limit three months from the end of the project implementation period.

In the event that one is necessary enlargement of that time limit for the submission of the justification form, as reflected in point 2c of paragraph Eighteenth of the said order, before the end of the deadline, refer to DIR EA0056568 - Office for Coordination and Promotion of the Execution of Aid (belonging to Commissioner DANA), through the General Electronic Register, job with motivated request for an extension which may be at most 2 months.

The certificate of entitlement and service provided for in paragraph 11.3.c) of Order TMD/101/2025, of 31 January, must encompass The infrastructures, equipment, facilities and services of municipal ownership already existing as those in which the new reconstruction is planned.

The eleventh paragraph of Order TMD/101/2025 of 31 January states that the project may cover infrastructure, equipment or facilities of a similar nature and destination (e.g. Urban Street Repair Project; Public Library Repair Project, etc. ), but in that case, you will need to properly identify each of them.

However, in the case of the reconstruction of several infrastructures, equipment or facilities and services, the recovery of which will take place in a single installation, it is possible to submit a single project (Valued memory), which groups together all the works necessary for the recovery of the former.

In this sense, in the fields of “typology” and “main service provided in the infrastructure” that appear in the application (application ALBA-DANA), The typology and service that will be predominant in the new installation must be indicated.

No.. Each project (valued report) will describe the repair, restitution or reconstruction works that the beneficiary entity proposes to carry out on the infrastructure, equipment or facilities and services of its ownership, which comply with the purpose of the subsidies and with all the conditions to be eligible for subsidies.

Therefore, the valued memory You must collect all the precise works for the full repair, restitution or reconstruction of the infrastructure, equipment or facilities and services of the damage caused by DANA.

The purpose of the grant unfettered the infrastructure that was the subject of the assessment during the technical assessment (served as the basis for determining the amounts to be granted), so that the beneficiary entity may allocate the funds granted Works that are financiable under the Order, although they would not have been valued at that time.

In this sense, the purpose to which the grants are allocated will be described through the projects and their respective valued reports, in the terms indicated in the eleventh section of Order TMD/101/2025, of January 31 (“Each project will describe the repair, restitution or reconstruction work that the beneficiary entity proposes to carry out on the infrastructure, equipment or facilities and services of its ownership, which meet the purpose of the subsidies and with all the conditions to be eligible for funding.”).

No.. In order to submit to the Commissioner the projects describing the works to be financed by the grants (“subventonal” project), only a report is required, together with other documentation, with the content referred to in point 3 of the eleventh and eleventh bis paragraph of Order TMD/101/2025, of 31 January.

It shouldn’t be confused The project from the point of view “grant-based“with the technical project referred to in Law 38/1999, of November 5, on Building Management or with the project of works referred to in Law 9/2017, of November 8, on Public Sector Contracts.

Yes. In the Internet space of the Ministry of Territorial Policy and Democratic Memory, the valued memory model is published, along with other models:

https://mpt.gob.es/portal/ministerio/comisionado-especial-dana/dana-orden-tmd-101-2025/instrucciones-modelos-info-tmd-101-2025

  • Valued Memory (unique).
  • Certification of ownership and use/service (direct and indirect management).
  • Responsible declaration of the managing body on aid (in cases with indirect management).
  • (Award Phase) Indicative Intervention Report of the unique and invariable code attributed to the project of expenditure throughout its life.

The project submitted to the Commissioner (and their respective valued memory) may cover one or more infrastructures, equipment or installations. Now, if there are several infrastructures, all of them must be of analogous nature and destiny (e.g. Urban Street Repair Project; Public Library Repair Project, etc. ), each of which must be properly identified.

Therefore, if the nature and destination of the buildings it's different, they can't be grouped The works in a single valued memory.

The eleventh and eleventh bis of Order TMD/101/2025, of 31 January, requires that the project (whose works will be described in a valued report) have eligible costs of at least 10,000 euros. However, in order to carry out these works, the entity you may enter into (or have entered into) contracts for less than that amount.

In this regard, it should be recalled that according to the fifth paragraph of Order TMD/101/2025, of 31 January, eligible expenses will be those of investment related to the execution of a works contract, provided that they respond to the nature of the purposes subsidized and that they are carried out after 28 October 2024.

Consequently, the recovery work that the entity would have carried out through contracts of less than 10,000 euros they can be included in the valued memory, provided that these meet the other established requirements in Order TMD/101/2025 of 31 January.

Order TMD/101/2025, of January 31, establishes that the application must provide graphic evidence of the damage caused by DANA to the infrastructure, equipment or installation and service affected, although it is not necessary that the photograph was obtained at the time that said damage was occurring.

In that sense, a representative photograph will be one that shows the most relevant damage that caused the DANA on the infrastructure, equipment or installation and service affected; in short, of the Damages that will be subject to recovery with the grants.

On the contrary, It would not meet such characteristics A photograph taken, for example, in the middle of the flood, that did not show the damage that it was causing to infrastructure, equipment or installation and service that was flooded.

In the decision to accept the project (subsidy), the Ministry of Territorial Policy and Democratic Memory shall set the maximum total eligible cost of the respective project and the maximum subsidy allocated to it.

If, at the time of drawing up the technical projects, there is a significant slippage in relation to the maximum total eligible cost that would have been set at the time of acceptance, the institution you could request an amendment. However, such a modification must be urged within the maximum award period of the respective project and, in any case within the project submission deadline.

At the time of Submit projects before the Ministry, the beneficiary entity must provide a valued memory “with sufficient information to define and assess the proposed works of repair or restitution”, without it being necessary for this process to have or provide a constructive project (understood as such, a project of works).

At the time of execute the works It must be taken into consideration that the award of a works contract will require the Prior elaboration, supervision, approval and rethinking of the corresponding project that will precisely define the object of the contract, all of this, in the terms of art. 231 of Law 9/2017, of November 8, on Public Sector Contracts.

For the presentation of projects in the ALBA DANA system, there are two profiles user for the entities, MANAGER and REPRESENTATIVE:

1.- MANAGER: Optional profile. He's got the Ability to create new projects and upload data and documentsas well as of sign and submit the response to the corrections which may be required by the investigating body. It may be personnel belonging to the local entity or to another public or private entity that provides support and assistance to the local entity.. In the latter case, the beneficiary local entity itself must assume and regulate the regime of responsibilities regarding the veracity of the information that may be registered or obtained from the system and its custody.

2 - REPRESENTATIVE: Required profile. He's got the manager's capacity and then there is Agent to sign and submit each project created, as well as the signature and presentation at other moments in the life of the projects (p.ej. Withdrawals, waivers, awards…). It must be a person who has powers to represent the local authority (Mayor's Office, President of the Provincial Council, Councillor/Deputy Delegate, higher body in large population…).

For cover the absence of the initial managers or representatives, new managers may be appointed, referring to the Special Commissioner for Reconstruction and Repair of Damage Caused by DANA (DIR3. : EA0056568), via the General Electronic Registration The official model completed and signed. This model can be downloaded at the following link:

Model data users ALBA DANA

In response to the question raised, it is stated that the rules governing this subsidy do not limit or exclude the eligibility of contracts or commissions due to the fact that they were tendered or executed before the projects referred to in the eleventh paragraph of Order TMD/101/2025 of 31 January (valued reports) had been submitted to the Commissioner. The only temporary condition established for the eligibility of contracts or commissions is that they are made after October 28, 2024., the date on which the beginning of the catastrophic episode that motivates the aid took place.

Accordingly, the order does not require prior acceptance of projects by the Ministry, so that the beneficiary entity can enter into contracts or commissions or, to start their implementation.

In this sense, the contracting authority will be responsible for the processing of the contracting dossiers and the choice of the tendering procedure, in accordance with Law 9/2017, of 8 November, on Public Sector Contracts; without the conditions and commitments applicable to these subsidies affecting the use of emergency processing (art. 120 LCSP).

The rules of subsidies do not prevent the local authority from including in the tendered technical project works that would be eligible, together with other works that would not be financed by the grants, but which are part of the functional unit that is the subject of the contract. The works contracts implementing the subsidised actions could therefore also cover, in addition, other actions not financed by the subsidies.

However, on the occasion of the justification of the grant granted, the beneficiary entity shall be required, in the accrediting certification referred to in the seventeenth paragraph. 1.a) of Order TMD/101/2025, of 31 January, Identify which actions, units of work and amount of contract expenditure correspond to the object of the funded projectin order to determine the amount of eligible expenditure that has been justified.

Yes, It is possible. In addition, it will not be necessary to provide a new memory, provided that the modification is in accordance with the object the approved project and the total contract amount do not exceed the amount allocated by Project Acceptance Resolution.

The recruitment decisions correspond to the contracting authority of the beneficiary entity within the framework of the public sector contract law.

By code of the “expenditure project” is meant the accounting treatment provided in rules 21 and following of Order HAP/1781/2013, of 20 September, approving the Instruction of the normal model of local accounting. It is a clearly identifiable unit of expenditure, financed with one or several budgetary applications, which can be extended to one or several years and which must have individualized monitoring and control.

When the expenses have not been accounted for within the corresponding expenditure project, the Intervention or body responsible for the accounting of the beneficiary entity must take the necessary measures for its correct implementation and to guarantee the separate accounting of each project, in accordance with the provisions of the eleventh paragraph 4(a) of Order TMD/101/2025, of 31 January.

It is not possible. However, there is the possibility of imputation in the justification of the projects, the percentage of construction contract (Signage) corresponding to each project. As long as the construction contract (signage) meet the requirements set out in paragraph Five. Eligible expenses of the order TMD/101/2025, of 31 January, in accordance with the provisions of its second point: “2. Eligible expenditure shall be investment expenditure relating to the implementation of a works contract, as defined in Article 13 of Law 9/2017, of 8 November, on Public Sector Contracts, which transposes into Spanish law the Directives of the European Parliament and of the Council 2014/23/EU and 2014/24/EU, of 26 February 2014, provided that they respond to the nature of the purposes subsidised and that they are carried out after 28 October 2024. Under the same conditions, the investment expenses related to the execution of an order to a personified medium, formalized in the terms provided in article 34 of Law 9/2017, of 8 November, the object of which corresponds to the one provided in article 13 of said norm, will also be eligible. In both cases, only investment expenses, those of real investment, will be considered imputed to the chapter 6 of the state of expenditure of the budget of the beneficiary entity. (…)”

It should be noted that the seventh paragraph of the Resolution of September 18, 2025, of the General Directorate of Regional and Local Cooperation, which develops the twenty-fourth paragraph of Order TMD/101/2025, establishes that:

“If any of the activities affected by these measures has already been carried out, and it is not possible to comply with the provisions of this resolution, the beneficiary entity must adopt alternative measures that guarantee an equivalent diffusion of the funding provided by the General Administration of the State..”

In that sense, as far as the poster advertising the workspoint 2 of Annex II to that resolution states that:

“The poster will be placed after the award of the work and prior to the start of its execution. It will be maintained in adequate conditions of conservation and visibility until the justification of the project presented by the local entity is validated by the competent body of the Ministry of Territorial Policy and Democratic Memory and, in any case, for a minimum period of six months from its placement.”

Therefore, the advertising poster must be placed in the work until the justification of the project -provided for in the seventeenth paragraph of Order TMD/101/205-, has been validated by the Commissioner and, in any case, for a minimum period of six months from his or her placement.

As regards the publicity measures in the contracts and commissions through which the projects are carried out, if it was not possible to fulfil with the measures indicated in Annex VI because the processing has already been carried out, at least the following alternative measures should be taken to ensure equivalent dissemination. Thus:

- On the assumption that the notices of tender, award and formalisation of the contract or order have already been published in the Public Sector Contracting Platform: a document must be published in the Public Sector Contracting Platform within the respective file, informing that the respective file is financed by the General Administration of the State, through the Ministry of Territorial Policy and Democratic Memory.

- On the assumption that the contracts or orders have been formalizedA reliable communication must be made to the awardee, indicating that the project that is the subject of the contract or order is financed by the General Administration of the State, through the Ministry of Territorial Policy and Democratic Memory.

- On the assumption that Some invoices for the contract/order have already been submitted: by the local authority Intervention, appropriate measures must be taken to charge them to the spending project, stamping or marking the invoices to avoid double financing. All this without prejudice to the fact that, in the following invoices, the express mention that they are financed by the General Administration of the State, through the Ministry of Territorial Policy and Democratic Memory, is incorporated.

According to this section, the poster at work must indicate the project name and the investment thereof that will correspond to maximum total eligible cost indicated in the resolutive part of the Acceptance Resolution, informing that the works they are funded by the General Administration of the State, through the Ministry of Territorial Policy and Democratic Memory. This poster must remain on site until the justification of the subsidy.

Annex II to the Resolution of the Directorate-General for Regional and Local Cooperation, implementing paragraph 24 of Order TMD/101/2025 of 31 January, concerning the advertising of subsidies, states that:

“In those cases in which a work has different locations, it will be fixed in the most important place by amount of the projected work, indicating the different locations if they are not identified in the name of the project.”

Consequently, in those cases in which a work has different locations, the obligation will be satisfied by placing the poster in the place of greater importance by amount of the projected work, with indication of the different locations if they are not identified in the name of the project.

This poster, in the investment space, will reflect the maximum total eligible cost Indicated in the resolution accepting the project (not the one that is being developed in the place where it is located).

If, in addition to the mandatory project poster, the entity decides to place additional posters, in all of them, must do feature the financing received by the General Administration of the State and the elements of visual identity indicated in Annex I and the institutional image available in Annex VI of the aforementioned resolution.

Not necessarily. Support for an accepted project will be used to finance eligible project expenses.

As a result, bidding for a project contract is discontinued may be used to finance new eligible expenses which may be incurred by the local entity during the execution of the same (for example, modifications of contracts whose object complies with the rules provided in the order, excesses of measurements, etc. ).

In the eleventh point 4.a) of the Order TMD/101/2025, the obligation is stated that with each project must be: “Wear accounting by means of a perfectly identifiable unit of expenditurewhich allows the individualized monitoring and control of the project throughout its life, in accordance with the provisions of the applicable Local Accounting Instruction.”

What it entails for the entity to maintain one Separate accounting by an accounting code for each of the accepted projects; without the need for a single and specific account to make the payments arising from the aforementioned subsidy.

However, it is recalled that, in accordance with paragraph fourteenth of the said order: “the interest that may accrue on the subsidy received so far from the expenditure they must be attributed to the object of the subsidy Provided for in this order.”