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How to follow donor procurement rules

By the EMPOBase team · · 4 min read

Short answer

To follow donor procurement rules, read each grant agreement and its annexes, extract the rules into one table per grant, and apply the stricter of the donor rule and your own policy. Train staff, charge purchases to the right grant, keep evidence in the purchase file and ask the donor early when a rule is unclear or a purchase will not fit.

Key points

  • Read the agreement, its annexes and any donor guide; the rules are often in more than one place.
  • Build a short rules table for each grant and put it where buyers can see it.
  • When rules differ, follow the stricter one for purchases charged to that grant.
  • Ask the donor in writing before a purchase that might not fit; keep the reply.

Why do donor rules matter?

A donor’s money comes with conditions. Procurement rules are among the most checked. They say how much competition you need, which suppliers you may use, what you must document and what you may not buy. Break them and the cost can be declared ineligible, which means the NGO pays from its own funds.

Most breaches are not fraud. They come from not knowing the rule, reading an old version, or assuming a rule from another donor applies.

Where are the rules?

They hide in several places. Check each one for every grant:

  1. The grant agreement itself.
  2. Annexes, general conditions and budget notes.
  3. A donor procurement guide or manual, if the agreement refers to one.
  4. Eligibility rules for suppliers, origin of goods or sanctions.
  5. Rules on assets, vehicles and equipment.
  6. Reporting and record-keeping rules.
  7. Any written approvals or letters from the donor during the grant.

Laws and donor rules differ by country and by agreement. Do not rely on a rule you remember from a different grant. Read the current text, and if a rule is unclear, ask.

How to build a rules table for each grant

A one-page table is more useful than a thick agreement. For each grant, record:

TopicWhat to capture
CompetitionHow many quotations or tenders at each value
ApprovalWho in your organization must sign, and whether the donor must approve
Eligible suppliersAny limits on origin, sanctions or registration
Prior approvalPurchases that need donor consent first
AssetsRules for equipment, vehicles, title and disposal
RecordsWhat to keep, and for how long
ExceptionsHow to handle sole source and emergencies

Add the clause or page reference for each row, so the next person can check your reading. Date the table, and update it when the agreement changes.

How do you combine donor rules with your own policy?

Your organization has its own policy, and each donor adds rules. Use this order:

  1. Read both.
  2. For each topic, find the stricter requirement.
  3. Apply the stricter one to purchases charged to that grant.
  4. If you want an exception, ask the donor in writing.

Our article on approval limits for NGO procurement shows how to build the policy side, and how many quotations you need shows how to set competition bands.

How to put the rules into practice

  1. Tell buyers which grant is paying. Every request names the project and budget line, and so the grant.
  2. Put the table where people work. Share it with logistics, programme and finance staff.
  3. Train staff. A short session at project start, and when a new person joins.
  4. Check before buying. For purchases that are large, unusual or shared across grants, a second person checks the rules.
  5. Keep evidence in the file. Quotations, approvals, delivery records and any donor consent.
  6. Review mid-grant. Pick a few purchases and test them against the table.
  7. Update when rules change. Grants are amended; your table must follow.

When should you ask the donor?

Ask early, in writing, and keep the reply. Typical cases:

  • a purchase above a stated limit that needs prior approval,
  • only one supplier is available,
  • an emergency need that does not fit the normal process,
  • shared costs across donors,
  • an unclear clause,
  • a price rise that makes the original budget line too small.

A short email with the facts, your proposed approach and a request for confirmation is enough. Donors react far better to a question before the purchase than to an explanation afterwards.

What proof will the donor ask for?

For a sampled purchase, expect to show: the request, the competition, the approval, the order, the delivery record, the invoice and the payment, plus any donor consent. Our article on what a procurement audit trail must show lists these in order. If your file holds them together, a review is short.

Where EMPOBase fits

In EMPOBase, a procurement request carries its project and budget line, goes through approval levels L1 to L5 that your organization sets, and records who approved, when and any note. The requester cannot approve their own request, and one person cannot approve two steps. External Access gives donors and auditors scoped, read-only, logged access to what you choose to share. EMPOBase does not know a donor’s rules for you, and keeping records does not establish compliance on its own, so your rules table and the donor agreement stay in charge. See the procure-to-pay workflow.

Questions people ask

What happens if we break a donor's procurement rule?

The donor may treat the cost as ineligible and ask you to repay it, or may add conditions to the grant. The effect depends on the agreement. Raise problems early; donors usually prefer early disclosure.

Which rules apply when a project has several donors?

Each donor's rules apply to the part of the purchase it pays for. Where one purchase is shared, apply the strictest rule that touches it, and record how the cost was split.

Where do we find the rules?

In the grant agreement, its annexes, general conditions and any procurement guidance the agreement refers to. If you cannot find a rule, ask the donor in writing.