MRS IVELINA PENEVA,
I.D. CHIEF DIRECTOR OF
THE GOVERNING AUTHORITY OF
OP "INNOVATIONS AND COMPETITIVENESS" 2014-2020
COPY:
MRS RUMYANA BACHVAROVA,
DEPUTY MINISTER-PRESIDENT FOR
COALITION POLITICS AND STATE ADMINISTRATION
MR BOŽIDAR LUKARSKI,
MINISTER OF THE ECONOMY
Subject: The limitation of certain types of ICT investments in OPIC 2014-2020 procedures, regional restrictions and indicative schedules of OPIC 2014-2020 procedures.
Dear Ms. Peneva,
In connection with the upcoming first official meeting of the Monitoring Committee of the Operational Program "Innovations and Competitiveness" 2014-2020 and at the request of the ICT Committee at KRIB, we would like to present our opinions and proposals regarding the limitation of certain types of ICT investments in procedure "Improving the production capacity of SMEs"; the regional imbalance of BFP, which also affects the ICT sector; the effect of postponing the announcement of OPIC procedures and the "Support for Innovations in Enterprises" procedure laid down in the indicative program.
According to the application guidelines for "Improving the production capacity of SMEs", the main objective of the procedure is to provide investment support to Bulgarian SMEs to improve production processes, increase production capacity and strengthen export potential. It is expected that its implementation will lead to an improvement in the competitiveness and market presence of Bulgarian SMEs - through implemented technologies to improve the production process, reduce production costs and, accordingly, increase the added value. At the same time, in ineligible activities and expenses, it is explicitly stated that the purchase of: "computer equipment and software for the administrative needs of the enterprise (including management software systems - ERP, CRM and other similar systems and modules)" is not allowed.
Business and customer management systems are not typical administrative systems, but integrated software for improving the production process, monitoring resources in real time, quantitative and qualitative control of raw materials and the final product, reducing production costs and optimizing production chains.
World practices show that the implementation of ERP and CRM systems in enterprises helps their economic efficiency, flexibility in management and investments, expansion of production capacity and better market positioning.
According to a study by Digital Agenda Scoreboard, 76% of global enterprises use ERP systems, and only 27% of Bulgarian SMEs have managed to implement them. The share of SMEs with implemented CRM systems is even lower – 16%. This puts Bulgarian businesses in an extremely unfavorable position compared to their global competitors in terms of efficiency, flexibility, growth opportunities, accuracy and speed of transactions, optimization of time and resources for the production of quality products and services.
In connection with the above, we propose that the explicit restriction on the purchase of ERP CRM systems be dropped and that Bulgarian SMEs be given the opportunity to "catch up" with their global competitors, taking advantage of the resources of "Improving the production capacity of SMEs" of OPIK 2014- 2020.
In relation to the regionalization of the BFP intensity: The reduced intensity of the BFP for the South-West region is in accordance with the EU guidelines for concentrated support of the most backward regions, but at the same time puts the regions outside Sofia-city, included in it, at a disadvantage. The high thresholds of the minimum sizes of BFP do not guarantee that a significant number of enterprises outside the SZR will be supported (especially in the North-West, where the most efforts should be targeted). At the same time, the ICT sector, declared a priority, is also among the affected, given the fact that most ICT companies are located in Sofia. In this regard, we propose that the MA provide an opportunity to purchase DNA with a higher intensity of BFP under the "de minimis" regime.
Regarding the indicative programs of OPIC 2014-2020: We understand well that the annual programs of the Operational Program are working and preliminary and they are subject to change, but often the planned procedures are postponed by more than two months. The practice of the previous program period 2017-2013 showed that the excessive delay of planned procedures, and subsequently the long evaluation of projects, leads to the accumulation of tension among potential beneficiaries, often makes the investment meaningless, does not allow enterprises to plan rhythmic investments and blocks financial resources. In order not to create a "vacuum on the investment market" and to increase the effect of public support for Bulgarian business, we ask the Administrative Council to consider introducing a practice for not allowing the postponement of a procedure laid down in the indicative schedule for more than one month.
One of the expected procedures in 2015 is "Support for innovations in enterprises". The experience of the previous program period shows that the set criteria made it impossible or too time-consuming to prove innovations, especially in the ICT sector. Only in some of the recent procedures for promoting the innovativeness of enterprises was it accepted that companies that implement an innovation (own development or based on intellectual rights acquired by third parties) that is new for the enterprise will be supported. These were also the first successful procedures for supporting innovations, because it was not necessary to limit the implemented innovations to "new for the world market" or "new for the Bulgarian market". In this regard, we hope that enterprises will be supported again to implement innovative solutions that they lack and are necessary for their development and competitiveness without being limited by the fact that there are similar innovations on the Bulgarian market. We insist that there should be no capping of DNA expenses under the scheme, but that the needs of investment-type companies in solutions/innovations should be taken into account. In case there are doubts about the unreasonableness of costs, it is necessary to introduce minimum criteria or to request the necessary evidence from the applicant who introduced the innovative solution, and not to set general restrictions.
We hope that our comments and recommendations will be taken into account and thus contribute to better planning and use of OPIC 2014-2020 resources.
We remain available for further discussion.
With respect,
EVGENIY IVANOV
CEO
MEMBER OF THE MANAGEMENT BOARD
http://www.turbulence.tech