The General Comptroller's Office unifies the processing of grants in kind

The General Comptroller’s Office of Cantabria has approved Instruction 2/2026, of October 1, which establishes a homogeneous treatment for the processing of grants in kind within the economic-budgetary framework. The regulation, signed in Santander by the General Comptroller José Manuel Ramírez Bonilla, is published in the Official Gazette of Cantabria no. 193, of October 7, 2026, with the reference CVE-2026-7844. The text affects all managing bodies of the Government of Cantabria that grant free deliveries of goods, rights, or services acquired for third parties.

Grants in kind are simultaneously governed by subsidy regulations and public procurement regulations. Article 2.2 of Law 10/2006, of July 17, on Subsidies of Cantabria —equivalent to the fifth additional provision of the General Subsidies Law 38/2003, of November 17— establishes that the acquisition of goods is subject to contract legislation, while their free delivery to third parties is subject to the subsidy law. This dual nature creates disparate situations that the instruction aims to unify.

Article 3 of Royal Decree 887/2006, of July 21, which approves the Regulation of the General Subsidies Law, incorporates budgetary management particularities applicable on a supplementary basis in Cantabria. To this are added Article 17 of Law 10/2006 and Royal Decree 130/2019, of March 8, which require these grants to be published in the National Subsidy Database (BDNS), and the Resolution of April 12, 2010, which orders them to be allocated to chapters 4 (current transfers) or 7 (capital transfers) of the budget.

Two distinct electronic files

The instruction, structured in six sections, orders each grant to be processed in two independent electronic expenditure files: one for the acquisition of the goods, rights, or services —usually through an administrative contract— and another for the granting of the aid itself. Both must state their common purpose so that an explicit link exists between them.

The scope of application is limited to deliveries acquired through an administrative contract with the exclusive purpose of being delivered to third parties and which meet the requirements for subsidies. Deliveries without that exclusive purpose, which will be governed by patrimonial legislation, and those that do not meet the subsidy requirements are excluded.

Acquisition prior to or after the call for applications

When goods are acquired before the call for applications, the expenditure must be allocated to chapters 4 or 7 of the budget, and the call file does not involve budgetary execution in any of its phases, therefore requiring no comptroller function. The call must indicate the estimated amount of the grants and not the total maximum amount.

If the acquisition occurs after the call for applications, the call file must be accompanied exclusively by an RC accounting document to certify adequate and sufficient credit, and must be previously audited. Subsequently, the acquisition expenditure is recorded directly against available credit using accounting document A(200) or AD(220), simultaneously canceling the previous credit retention.

Granting, delivery, and publicity

Granting and delivery files are also not subject to the auditing function, regardless of the timing of the acquisition. However, during delivery, the requirements of Chapter III of Title I of Law 10/2006 regarding the asset, right, or service subject to the aid must be verified.

The call, the granting, and the delivery must be published in the BDNS by the processing bodies. In the event of reimbursement, the amount to be returned is equivalent to the acquisition price of the asset, right, or service, plus the late payment interest provided for in Article 37 of Law 38/2003.

This instruction provides legal certainty to an increasingly frequent type of aid and avoids accounting duplications in expenditure files. Its application is mandatory for all managing bodies of the Government of Cantabria, which must adjust their electronic procedures to the described specifications.

Source: Official Gazette of Cantabria, no. 193, October 7, 2026, Section I, pp. 50362-50365 (official reference: CVE-2026-7844).