What (Doesn’t) Work in the Rules of Horizon Europe? A New Analysis Brings Data to the Debate on FP10

The debate on the shape of the next EU Framework Programme for Research and Innovation – FP10 – is gaining momentum in 2026. The political calendar is moving quickly. In the European Parliament, draft reports on FP10 and on the new Competitiveness Fund are expected to be published during the spring, outlining Parliament’s position on these initiatives. At the same time, the Council of the EU is aiming to reach a so-called partial general approach on the proposal for FP10 by the end of June 2026 – that is, a political agreement among Member States on the main parameters of the programme.

Into this debate comes a new European publication, “Horizon Europe’s Legal, Financial & Administrative Rules – A Report on Their Practical Use”, prepared by the community of National Contact Points (NCPs) within the Horizon Academy project. The study is based on a large-scale survey among beneficiaries of the Horizon Europe programme and provides a systematic analysis of how the programme’s rules function in the day-to-day practice of project management.

The analysis draws on 1,360 responses from organisations across Europe – from universities and research institutions to companies and public organisations – capturing the experiences of project coordinators, researchers, and research managers and administrators. By combining statistical data with the experience of people working with the programme’s rules in their daily practice, the study offers a data-driven perspective on how the current rules of European research funding are applied in practice and where the main challenges arise.

What Works – and Where There Is Room for Improvement

The analysis shows that a number of elements of Horizon Europe implementation are perceived positively by beneficiaries. For example, the harmonisation of grant rules across EU programmes (the so-called corporate approach) is largely viewed positively, and respondents indicate that aligning Model Grant Agreements across EU programmes is practically beneficial.

The Annotated Grant Agreement is also considered a useful tool for navigating project rules, particularly valued for its practical examples and explanations of individual provisions.

Positive feedback is also given to the proposal submission system, which most users consider clear and functional, as well as to the grant agreement preparation phase, which respondents generally regard as understandable and administratively manageable. The amendment process during project implementation is also assessed relatively positively. Although amendments are frequently used in practice, most beneficiaries consider the process effective and predictable.

The analysis also shows that in areas that have become an integral part of European research policy – such as open science, gender equality, ethics, or data protection – research organisations generally demonstrate a relatively high level of awareness, and these principles are increasingly integrated into institutional policies.

Alongside these positive findings, however, the results also point to areas where beneficiaries continue to encounter practical difficulties.

One of the first steps in preparing a project proposal is identifying a suitable call. At this stage, many respondents indicate that searching for calls in the European Commission’s portal is not always intuitive, and identifying relevant topics can be time-consuming. Preparing a project proposal itself is often perceived as a very demanding process, which is reflected in the fact that many organisations rely on specialised external consultants when preparing proposals. Respondents also report a degree of uncertainty during the evaluation phase. Although they appreciate the robustness of the peer-review system, some still perceive a risk of subjectivity in the evaluation of proposals.

Challenges also arise during project implementation. In areas such as open science, gender equality, ethics, or data protection, institutions often declare a high level of understanding of the principles and requirements, but their practical implementation in daily project management frequently encounters limitations due to insufficient staff capacity or administrative burden. A similar situation can be observed in the area of exploitation and valorisation of project results. While some organisations actively pursue the further use of research results, the analysis indicates that this aspect is not always systematically followed up.

Personnel Costs: The Largest Budget Item and the Biggest Challenge

One of the most striking findings of the analysis concerns personnel costs, which represent the largest share of project budgets. Audit experience has long shown that this area generates the highest number of errors, and the survey results confirm this trend. More than half of respondents consider the calculation of eligible personnel costs to be overly complex. In open responses, terms such as “complex,” “unclear,” “error-prone,” and “time-consuming” appear repeatedly, illustrating the practical experience of institutions dealing with the administrative burden of this area. At the same time, the analysis shows that the preparation of project budgets is generally perceived as relatively manageable. Difficulties tend to arise later during project implementation, for example when calculating daily rates, recording working time, or applying different limits and calculation methodologies.

Moving Towards Simpler Funding Models

These findings fit into the broader European debate on the simplification of research funding rules. The analysis shows a growing openness among beneficiaries towards simplified funding models, particularly projects funded through lump sum funding. This model is perceived as an effective means of reducing administrative burden and limiting the risk of financial errors. It is therefore not surprising that the European Commission’s proposal for FP10 foresees further expansion of these approaches – for example, with lump sum funding potentially becoming the standard funding model.

At the same time, the analysis shows that the practical implementation of lump sum funding still raises a number of questions, for example when planning budgets in the detailed budget table or in relation to audit processes and record-keeping obligations. These experiences suggest that further methodological clarification and the sharing of good practices will be important in order to fully realise the benefits of this model. Respondents also note that some institutions or coordinators still apply internal procedures resembling the actual-cost model, which may reduce the potential benefits of this simplified funding scheme.

At the same time, the European Commission is proposing the use of Personnel Unit Costs in projects based on actual costs. However, the analysis indicates that this model is currently received rather cautiously by beneficiaries and, in its current form, is not generally considered fully viable. Its broader use will therefore largely depend on further developments in the rules and their practical implementation.

The Role of National Contact Points

The publication also highlights the importance of National Contact Points (NCPs), which operate at the interface between European institutions and beneficiaries. Through their daily work with applicants and beneficiaries, NCPs gather practical experience and data that can contribute to the further improvement of the rules governing European programmes.

The analysis was prepared in cooperation with experts from the entire network of NCPs for legal and financial aspects of Horizon Europe. Activities of this kind also demonstrate that national support structures can contribute not only to successful participation in European programmes but also to their further development.

At a time when discussions on the shape of the future FP10 programme are intensifying, feedback from practical experience can help improve understanding of how the rules of European programmes are applied in the day-to-day management of research projects and contribute to the debate on how to design the future programme as effectively as possible.

Author: Lenka Chvojková, Technology Centre Prague