"The budget formulation and execution is based on administrative, economic and sub-functional classification, using GFS/COFOG standards or a standard that can produce consistent documentation according to those standards. (Program classification may substitute for sub-functional classification, if it is applied with a level of detail at least corresponding to sub-functional.)"
(PEFA - PFM Performance Measurement Framework - Revised January 2011:17)
This seems to me to suggest that a government having a programme classification and not a sub-functional classification will have to have at least 69 programmes if its efforts are to be taken into account under PEFA scoring.