Statement of Use

Statement of Expenditures - The statement of expenditures is a document used by recipients of public funding (KfW, BAFA, urban development grants) to demonstrate that the funds were used for their intended purpose. It includes a factual report on the measures carried out and a detailed breakdown of expenses supported by receipts. Failure to submit a complete statement of expenditures may result in the recovery of the grant funds.

Structure and Requirements

A statement of use consists of two parts:

Factual Report - Description of the measure implemented (e.g., heating system replacement, facade insulation, window replacement), implementation period, achieved result (e.g., energy efficiency class according to GEG), and, if applicable, deviations from the original grant application. For energy efficiency measures, the energy consultant (energy efficiency expert, or EEE for short) must issue a certificate of completion (TPN) after the measure is completed - without this, most KfW and BAFA programs will not disburse funds or issue a repayment subsidy confirmation.

Financial Statement - A list of all income (grants, personal contribution) and expenses (contractor invoices, material costs, planning costs) with allocation to the subsidized measures. Copies of invoices specifying the subsidized measures, proof of payment (bank statements or transfer receipts), the energy consultant’s confirmation, and, if applicable, acceptance reports must be attached.

Important: Invoices must be itemized - lump-sum invoices such as “construction work as per contract” are not accepted by the funding agencies. Labor costs and material costs should be listed separately, as some funding programs only subsidize labor costs or only certain materials.

Deadlines and Consequences

The deadline for submitting the statement of funds used varies depending on the funding program:

KfW Programs - generally 12 months after completion of the project, calculated from the date of the last payment. A 36-month deadline from the loan commitment often applies to the entire project. In justified exceptional cases, KfW allows for a deadline extension - however, this must be requested before the original deadline expires.

BAFA grants (e.g., BEG EM - individual measures) - the statement of use is submitted as part of the payment request. The BAFA will not disburse funds until the statement is complete and has been reviewed. Typical processing time: two to six months after submission.

Urban development funding and municipal programs - individual deadlines and requirements apply here, which are specified in the grant approval notice.

If the statement is not submitted or is not submitted on time, the funding agency may reclaim the funds in full - plus interest from the date of payment. Retrospective audits are also possible: KfW and BAFA conduct random audits of statements of expenditure, even years after the funding was granted.

Common errors in statements of expenditure

In practice, statements of use often fail due to typical errors: missing or unspecified invoices, missing proof of payment (cash payments are not accepted), missing confirmation from the energy consultant, or discrepancies between the subsidized measure and the work actually performed. Submission after the deadline has passed without a prior request for an extension is also a common problem.

Especially for complex energy-efficient renovations involving multiple trades, we recommend compiling the statement of use in parallel with the project’s execution-that is, systematically collecting invoices and receipts from the start rather than gathering them retroactively.

Practical Tip for Homeowners in Nuremberg

We recommend that property owners in the Nuremberg metropolitan region who have received KfW or BAFA subsidies for energy-efficient renovations systematically prepare the statement of use from the very beginning. Create a separate folder (physical or digital) and collect all invoices, proof of payment, and the energy consultant’s confirmation in it.

Make sure the invoices clearly identify the subsidized measures: e.g., “Installation of an air-to-water heat pump, model XY, rated output 12 kW - labor costs 4,500 euros net, material costs 8,000 euros net.” Without this specification, the funding agency may reject the invoice.

Your energy consultant will prepare the technical confirmation after completion (TPN)-be sure to schedule the inspection of the completed property well in advance, as some energy consultants require several weeks’ lead time. Without the TPN, there will be no confirmation of the repayment subsidy for KfW-BEG programs. Upon request, we assist property owners with coordination between energy consultants and funding agencies.

Frequently Asked Questions

What happens if I don’t submit the proof of use?

Without a timely proof of use, the funding agency may demand repayment of the entire grant-for KfW loans, the repayment subsidy will be reclaimed; for BAFA grants, the amount paid out will be reclaimed. In addition, interest may be charged from the date of disbursement. For minor delays, KfW and BAFA generally grant an extension-please proactively contact the funding agency if you anticipate that you will not be able to meet the deadline.

Who can help me with the proof of use?

Your energy consultant (for energy-related measures) prepares the technical portion of the proof of use and the post-implementation confirmation (TPN). For the financial documentation, you can consult a tax advisor-especially if tax deductibility and funding are combined. For urban development funding, the City of Nuremberg’s Urban Renewal Department provides guidance. KfW and BAFA provide templates and filling-in guides on their websites; use these as a checklist before submitting the report.

Can the funding agency conduct a retroactive audit?

Yes, KfW and BAFA conduct random audits-even years after the funding has been granted. These audits verify whether the project was carried out as applied for and whether the supporting documents are accurate and complete. Incorrect information can lead to a demand for repayment and, in extreme cases, to criminal consequences (subsidy fraud under Section 264 of the German Criminal Code). Keep all documents-invoices, payment receipts, confirmations, correspondence with the funding agency-for at least 10 years.

What to do if the energy consultant is no longer available for the TPN?

In practice, it occasionally happens that the commissioned energy consultant is no longer available for the technical confirmation after completion (TPN) once the project has been completed-for example, because they have ceased operations or moved away. In this case, another certified energy consultant (energy efficiency expert according to the EEE list) can be commissioned to inspect the completed property and issue the TPN retroactively. This requires that the new energy consultant be able to assess the project based on the available documentation and an on-site inspection. The costs for this follow-up inspection are borne by the owner; they typically range from 150 to 350 euros. In the Nuremberg metropolitan region, appropriately qualified energy consultants can be found through the Energy Consultant Exchange of the German Energy Agency (dena) or the Nuremberg Chamber of Commerce and Industry for Middle Franconia. We assist our clients with coordination and, upon request, recommend suitable energy consultants in the region.

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