Call for tenders' details

Pilot project - capacity building for Roma civil society and strengthening its i...
Contracting authority:
European Commission, DG Justice and Consumers (JUST)
TED publication date:
Time limit for receipt of tenders:
English (en)
Question details
clarification regarding documents required from subcontractors
We plan to involve partner organizations to undertake specific tasks. The partner organizations may be considered as subcontractors, although the services of each represent much less than 20 percent of the contract. On page 9 of the call, it is specified that “tenderers are required to identify all subcontractors”. On page 10 of the call it is specified that “subcontractor(s) shall not be required to fill in or provide those documents [i.e. the Legal Identity Form] when the services represent less than 20% of the contract”. Should we submit the tender identifying the partners as subcontractors (with their legal data entered into the online system) without submitting a Legal Identity Form for each? Or since they will receive less than 20% of the overall contract sum, they do not even need to be identified as subcontractors in the online submission system?
The partner organisations will be considered as subcontractors and will have to be identified as such in the tender, but they will not have to provide the Legal Identity Form.