Rechts- und Finanz-FAQ des Research Enquiry Service (RES) der Europäischen Kommission zu Horizon Europe

Antragstellung und Einreichung

• Erklärungen zur Budgettabelle
• Erklärungen zur Rolle der teilnehmenden Organisationen
• Schwerpunkt der Projekttätigkeit
• Teilnahme- und Förderfähigkeit             
   

Projektimplementierung

Personalkosten

• Tagsatzberechnung für PhD-Studierende
• Tagsatzberechnung bei Projekteinstieg des Beneficiary während der Berichtsperiode
• Tagsatzberechnung wenn Berichtsperiode während eines Monats beginnt
• Definition "standard annual workable hours"
• Nachweise für Personalkosten
  • Zeitaufzeichnungen
  • Declaration
  • Declaration UND Zeitaufzeichnungen
• Sonderzahlungen
• Zeiten der Elternkarenz
• Papamonat
• Freistellung in der Kündigungsfrist
• Horizontale Obergrenze
  • Horizontale Obergrenze und Aliquotierung
  • Horizontale Obergrenze: Berechnung
• Aliquotierung der 215 Tage
• Überlassene Personen

Reisekosten

• Übliche Reisepraxis
• Anteilsmäßige Verrechnung von Reisekosten und Konferenzgebühren
• Reisekosten Assoziierter Partner:innen

Vorfinanzierung

Gender Equality Plan

Berichterstattung

• Certificate on the financial statements (CFS)
  • Mehrere Certificates on the Financial Statements pro Projekt  
  • Berechnung des Schwellenwerts
• Einnahmen

„Lump Sum“-Förderungen

• Nachweise für Personalkosten in Lump Sum-Pojekten
• Lump Sum-Budget in 2-stufigen Calls
• Begründung für höhere Personalkosten
• Antragsformular

Erklärungen zur Budgettabelle

The budget table in the proposal template/submission system has three new colums "Income generated by the action", "Financial contributions" und "Own resources". Could you please provide further details/explications on that?

Antwort vom 20.7.2021:                           
The new columns related to the income of the proposal have been added following the Financial Regulation which asks for a budget table in proposal that is in balance (expenditure = income).

For all the HE type of actions where the funding rate is at 100% the income columns should be filled with ‘Zeros’. However for the type of actions where the funding rate is <100%, participants are asked from which type of sources the rest of the funding will come: income generated by the action, own resources or financial contributions.

For the time being the Commission has only added this information in the help text of the budget table in the submission tool. Further IT controls and warning to ensure a budget table in balance will be developed in the future.

Kind regards,                           
The Research Enquiry Service back-office

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Erklärungen zur Rolle der teilnehmenden Organisationen

Could you explain the purpose AND the consequences for the evaluation of the indication of the "role of participating organisation in the project" (Standard Proposal Template (RIA IA), Part A, Organisation data, page 12)?

Antwort vom 9.11.2021:                           
The question on the role of participating organisation included in proposal part A will be used by the experts evaluators to assess the capacity and role of each participant, and the extent to which the consortium as a whole brings together the necessary expertise, as part of the evaluation criterion ‘Quality and efficiency of the implementation’. In addition, it will also server for statistical purposes for the implementation of the Horizon Europe Programme, as a whole.

Kind Regards,                           
The Research Enquiry Back-Office

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Schwerpunkt der Projekttätigkeit

Whereas in Horizon 2020 it was mentioned on page 153 of the AMGA that the substantial part of the work should be in principle performed by the beneficiaries, no such phrase can be found in the (A)MGA for Horizon Europe. Instead, the AMGA for Horizon Europe states on p. 17 that "The main actors should be the beneficiaries or affiliated entities. All other roles should be complementary.".

We understand that in Horizon Europe the major part of the work could also be entirely within affiliated entities instead of beneficiaries. Is that correct?

Please explain what is meant by this phrase.

Antwort vom 2.12.2021:                           
Under Horizon Europe, article 7 HE MGA still provides that beneficiaries must have the appropriate resources to implement the action under their own responsibility. Therefore the principle remains that the beneficiary should have the appropriate resources to implement the action, and by exception that they rely on third parties.

Having said that, affiliated entities have a different status from other third parties. In terms of allocation of the work, the work should be done mainly by the beneficiaries as well as their affiliated entities. Differently other third parties should remain in a complementary role.

Against this background, there may indeed be cases where an affiliated entity performs a larger share of work than its beneficiary. However any situation where a beneficiary would be performing by itself a very limited part of its tasks would require a justification.

Kind regards,                           
Legal and financial helpdesk

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Teilnahme- und Förderfähigkeit

According to the Rules for Participation, Article 23 (2) (a)

"(...) exceptionally, other non-associated third countries, shall be eligible for funding in an action, if: (a) the third country is identified in the work programme adopted by the Commission; (...)"

Example: The call conditions state that "Participation to the topic is limited to legal entities established in Member States, associated countries and OECD countries."

The call conditions refer to "participation", but as the Rules for Participation state "identified in the work programme" I wonder if the mentioning of "OECD countries" in the example call conditions is sufficient to not only say that OECD countries are eligible for participation, but also for funding?

Antwort vom 11.3.2022:                           
According to Article 23(2) of Regulation (EU) 2021/695 establishing Horizon Europe, legal entities established in a non-associated third country shall bear the cost of their participation. However, a legal entity established in low to middle income non-associated third countries and, exceptionally, other non-associated third countries, shall be eligible for funding in an action if:

1. the third country is identified in the work programme adopted by the Commission; or
2. the Commission or the relevant funding body considers that the participation of the legal entity concerned is essential for implementing the action.

Under point (a) participants can receive exceptional funding, if their country is explicitly identified in the Horizon Europe work programme and call for proposals as being eligible for funding. An indication in topic conditions that participation is limited to legal entities established in Member 5 States, associated countries and OECD countries concerns the possibility to participate but not the eligibility for funding.

Please see two examples of explicit identification regarding eligibility for funding in the HE Work Programme 2021-2022 for Health (available at https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/horizon/wp-call/2021-2022/wp-4-health_horizon-2021-2022_en.pdf – see p.8 and p.180):

• “any legal entity established in the United States of America is eligible to receive Union funding to support its participation in projects funded under the Health cluster”.
• For mobilisation of Research funds in case of Public Health Emergencies: COVID-19, second quarter of 2021 “legal entities established in Albania, Armenia, Bosnia and Herzegovina, Faroe Islands, Georgia, Iceland, Israel, Kosovo, Moldova, Montenegro, Morocco, North Macedonia, Norway, Serbia, Switzerland, Tunisia, Turkey, Ukraine and United Kingdom are eligible for funding from the Union”

We wish to recall that the most appropriate channel to raise your legal & financial questions remains the Research Enquiry Service, as explained in the email circulated on 10 February 2022 concerning the framework for meetings and communication with L&F NCPs.

Kind regards,                           
Legal and financial helpdesk

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Tagsatzberechnung für PhD-Studierende

Assuming a Horizon Europe project starts on the 1 of Jan 2023 and the first reporting period is 12 months.

• Mr. A is employed as a Ph.D. student at the beneficiary since 1 of Jan 2020.
• Mr. A is not working on the project while he is a Ph.D. student.
• Mr. A has a monthly salary of 1000 € while he is a Ph.D. student.
• On the 1 of April Mr. A finish his Ph.D. studies and continuous to be employed by the beneficiary as a post.doc.
• As of 1 of April Mr. A’s salary is increased to 3000 €/month.
• As of 1 of May Mr. A starts working on the Horizon Europe project.

What daily rate can the beneficiary claim for Mr. A’s work on the project during 2023?3 x 1000 + 9 x 3000 / 215 3000 + 27000 = 30000 / 215 = 139,53 €/dayIs this calculation correct?

• Ms. B is also employed as a Ph.D. student by the same beneficiary.
• Ms. B is not working on the project while she is a Ph.D. student.
• Ms. B has a monthly salary of 1000 € while she is a Ph.D. student.
• On the 1 of April Ms. B finish her Ph.D. studies and is no longer employed by the beneficiary.Ms. B is unemployed for two months.
• As of 1 of June Ms. B is employed as a post.doc by the beneficiary and starts working on the project.
• As of 1 of June Ms. B has a salary of 3000 €/month.

What daily rate can the beneficiary claim for Ms. B’s work on the project during 2023?7 x 3000 / (215/12 x 7)21000 / 125,41 days = 167,45 €/dayPlease clarify if the Daily Rate calculation examples above are correct.

Antwort vom 30.11.2023:      
Please kindly note that the Research Enquiry Service is not in a position to assess (series) of specific cases and/or (real-life/hypothetical) examples and make all corresponding calculation validationsbut can only provide general guidance regarding the correctness and appropriateness of the methodology, based on the information provided (which may be numerical if this is a helpful illustration of a general issue).

Based on the limited information provided in your query, we understand that Mr. A and Mr. B have from May and June respectively an employment contract with the beneficiary, therefore their status would fall within the category of “employees” under Article6.2.A.1 of the Horizon Europe MGA. As to whether another contract during the same reporting period has to be taken into consideration for the calculation of the daily rate, please note that it is only if the other contract is also an employment contract thatthe beneficiary sums up the actuals personnel costs under the two contracts (and the maximum declarable day-equivalents calculated individually for each of these employment contracts) to calculate a single daily rate for the reporting period. 

Therefore if Mr. A and Mr. B worked for the beneficiary as a PhD student under an employment contract, the actual personnel costs and the maximum declarable day-equivalents for the PhD employment contract during the months within the reporting period must betaken into consideration to calculate the daily rate of the reporting period. 

Differently, if Mr. A and Mr. B worked for the beneficiary as a PhD student under a direct contract or agreement (6.2.A.2, A.3 of the HE MGA), only the employment contract under which they worked on the HE project is taken into account to calculate the dailyrate of the reporting period. 

Best regards,                           
Legal and financial helpdesk

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Tagsatzberechnung bei Projekteinstieg des Beneficiary während der Berichtsperiode

The question refers to the calculation of personnel costs under Horizon Europe for beneficiaries who accede to the grant agreement after the start of the action. The calculation of the maximum declarable day-equivalents takes into consideration the length of employment of the person during the reporting period, but it is not clear for me what would be the case for personnel already employed by the beneficiary before acceding to the GA.

In the example given:

• Reporting Period running from 01/09/2022 to 29/02/2024 (18 months).
• The beneficiary accedes to the GA after the start of the action: 01/12/2022 (15 months).
• A fulltime employee starts working on the action on 01/12/2022 but was already employed by the beneficiary (let’s say from 01/01/2022). Consequently, the beneficiary has incurred in personnel costs from the whole reporting period (01/09/2022 to 29/02/2024 (18 months).

The question is, what is the reporting period to be used considering that the beneficiary has incurred in personnel costs from the beginning of the GA (01/09/2022)?

1. from 01/09/2022 to 29/02/2024 (i.e., from the whole reporting period of the action)
2. from 01/12/2022 to 29/02/2024 (i.e., from the accession date until the end of the reporting period of the action).
3. both
4. another

Antwort vom 25.4.2024:      
We understand that you would like to know what are the points of reference, time-wise, to be taken into account when calculating the daily rate for a personnel already employed when its employer/beneficiary joined the grant agreement.

As explained in the AGA, the daily rate is to be calculated over a reporting period as follows:

(actual personnel costs during themonths within the reporting period}      
divided by      
(maximum declarable day-equivalents)

And where the maximum declarable day-equivalents over a reporting period are calculated as follows:

{((215 / 12) multiplied by the number of months [during which the person is employed] within the reporting period)      
multiplied by      
the working time factor

For both the actual personnel costs and the maximum declarable day-equivalents in the context of a daily rate calculation over a given reporting period, the points of references are thus the start and end dates of that reportingperiod during which the person is employed.

Against that background, and in your example, we understand that the person would be employed already since 1 January 2022, while the start date of the reporting period would be 1 September 2022 and the end date 29 February 2024.In that context, the points of reference during which the person is employed, time-wise, would be the 1 September 2022 and 29 February 2024 for calculating a daily rate for that person over this reporting period.

Please bear in mind, that there might be another parameter to take into account which is the working time factor of the personnel (e.g. for instance a full-time or part-time employee over the reporting period).

Eventually, it should also be reminded that only the day-equivalents spent on the action can be considered (and to be multiplied by the daily rate) to calculate the personnel costs over a given reporting period. In the exampleyou describe, if the beneficiary to which the person is the employee has acceded to the grant agreement with no retroactive date but the date of 1 December 2022, it is understood that this person employed by this beneficiary has started working on the actionas from 1 December 2022 and thus can only declared the day-equivalents spent on the action as from 1 December 2022 (and multiplied them by the daily rate calculated as explained above).

Kind regards,       
Legal and financial helpdesk

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Tagsatzberechnung wenn Berichtsperiode während eines Monats beginnt

Frage der spanischen R&F NCPs

If an action does not start the first day of the month and the accounting system only allow to recover costs for completed months, how should the beneficiaries calculate the daily rate for the reporting period? 

Example:
Action start date on 11/07/2023; reporting period 1 from 11/07/2023 until 10/04/2024 (9 months);
full time employee already working in the entity before the action starting date.

For the maximum declarable day-equivalents:
215/12*9 = 161,25 day-equivalents (rounded to the nearest half day-equivalent) = 161,5 day-equivalents

For the personnel costs:

• Option A: Consider actual personnel costs recorded in accounts from 01/07/2023 until 31/03/2023. 

• Option B: Prorate actual personnel costs recorded in accounts:
  July 2023 = personnel costs recorded / 30 days * 20 days;
  April 2024 = personnel costs recorded / 30 days * 10 days

Which option is the correct one?

Antwort vom 29.5.2024:      
Based on your question, we understand that you are asking how to calculate the personnel costs for a project that does not start on the first day of a month.

Please note that, in line with the AGA, you must only include the personnel costs incurred during the month within the reporting period during which the person is employed when calculating the daily rate. Therefore, as explained in the AGA (with example of an employee hired not at the beginning of the month) you must perform a pro-rata calculation of the personnel costs incurred in the first and last month of the reporting period. For all personnel cost calculations, a month is considered to have 30 days.

Returning to your example, the correct way to calculate the personnel costs would be option B - a pro-rata calculation of the personnel costs incurred in the first and last month of the reporting period.

Kind regards,       
Legal and financial helpdesk

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Definition "standard annual workable hours"

In Horizon Europe, does the same definition of "standard annual workable hours" apply as in Horizon 2020 or is there any other document with the definition?

Horizon 2020 AGA: "'Annual workable hours’ means the period during which the personnel must be working, at the employers' disposal and carrying out his/her activity or duties under the employment contract, applicable collective labour agreement or national working time legislation."

Antwort vom 20.3.2023:      
As Horizon Europe will follow corporate rules for personnel costs with a daily basis calculation, no definition of ‘standard annual workable hours’ is provided in the AGA. For the time-being, there is only one reference to this concept for the specific case of beneficiaries recording time worked in hours rather than in days under Article 20.

This being said, ‘standard annual workable hours’ can be considered as a relatively well-established general concept, and can therefore be defined as follows:

The “standard annual workable hours” is the standard number of hours that a full time employee of a given reference group, having similar working conditions, must be present at work under normal circumstances, as defined in:

• the employment contracts of the reference group,
• an applicable collective labour agreement, or
• the national law on working time.

Statutory holidays and public holidays are deducted from the working time to obtain the standard workable hours.

In that sense, and in reference and reply to your specific question, no different definition between H2020 and HE is intended on that issue.

Kind regards,                           
Legal and financial helpdesk

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Zeitaufzeichnungen                      

Frage der isländischen R&F NCPs

Frage der tschechischen R&F NCPs

As in Horizon Europe it is possible to continue documentation of personnel costs via time-sheets, we would like to know if ...

1. the minimum criteria for time-sheets remain the same as for H2020 (see page 179 H2020-AGA)? If not, what would be the exact minimum criteria for Horizon Europe?
2. the EC plans to publish a template for time-sheets for Horizon Europe as well?

Antwort vom 4.3.2022:                           
We understand that your question relates to the requirements that needs to be fulfilled for time records under Horizon Europe. Please kindly note that record-keeping rules (Article 20 HE MGA) are so-called corporate rules (i.e. applying to different EU programmes using the corporate MGA).

In that respect, current draft annotations related to record-keeping (Article 20 HE MGA) set out in the Annotated Model Grant Agreement (version 0.2 of 30 November 2021 available at https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/common/guidance/aga_en.pdf p.119) are still subject to a review and clarification process from Commission services. Therefore, the below explanations reflect the current state-of-play.

According to Article 20.1(e), of the Horizon Europe Model Grant Agreement (HE MGA) for the recording of personnel costs, time worked for the beneficiary under the action must be supported by declarations signed monthly by the person and their supervisor, unless another reliable time-record system is in place.

In that respect, and in terms of ‘minimum criteria’, it is expected that time records should indicate the information that are required in the template on the Funding and Tenders Portal for the monthly declaration of time (e.g. project number, acronym, work packages worked on, etc.).

In terms of template, and since the HE MGA will follow corporate rules by requiring daily rate calculation for personnel costs, only the template for the monthly declaration of time above mentioned will be made available. But it is not foreseen to develop and make available other kind of template.

Best regards,                           
Legal and financial helpdesk

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Declaration

Frage der tschechischen R&F NCPs

The template of the Time declaration provided on the F&T Portal is a compulsory template (it is not possible to create own layout of monthly declaration). Correct?

Antwort vom 7.3.2022:                           
The template accessible via a link in the AGA and on the portal’s reference document page is indeed the template to be used to declare the number of days spent for the action. If the use of this template raises an issue, please let us know the reason.

However, beneficiaries who have a reliable time recording system as part of their usual management practices may use it to support the number of days charged to Horizon Europe grants. In that case, they would not fill in the Time declaration.

Folgefrage der tschechischen R&F NCPs

I have an additional question: In terms of documenting personnel costs in Horizon Europe projects - would it be acceptable if the monthly declaration on days spent for the action were kept for the entire reporting periods (rather than per calendar year)? The provided template is per calendar year, nonetheless, I understand that the beneficiaries can modify the template to fit their needs as well?

Antwort vom 10.5.2022:               
According to Article 20.1 (e) of the HE MGA, for the recording of personnel costs, time worked for the beneficiary under the action must be supported by declarations signed monthly by the person and their supervisor, unless another reliable time-record system is in place.                           
Therefore, in cases that the reporting period is different than the calendar year, the Beneficiaries can adapt the monthly declaration template in order to include all the months of the same reporting period.

Folgefrage der tschechischen R&F NCPs

Is it expected that in Horizon Europe each personnel will have a separate Time declaration for work in each Horizon Europe project? If one personnel has two Horizon Europe projects, two Time declarations have to be filled in by the personnel (considering different months/duration of the reporting period) or one is sufficient (it is up to the decision of the beneficiary)?

Antwort vom 15.11.2022:                           
The template made available on the Funding and Tender Opportunities Portal is designed to be filled in per project. If a beneficiary adapts it to cover different EU projects, this would be under its responsibility.

Folgefrage der tschechischen R&F NCPs

Days recorded in the monthly declaration (template of the Time declaration) do not need to be rounded to the nearest half day (it can be e.g. two decimal places), only the sum of the day-equivalents for the whole reporting period used to calculate the personnel costs have to be rounded to the nearest half-day?

Antwort vom 30.8.2023:                           
Correct, only the overall number for the whole reporting period must be rounded to the nearest half day.

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Declaration UND Zeitaufzeichnungen

How is the procedure in case of discrepancies between parallel declarations and time records?

How to proceed when filling in the declaration if someone has worked e.g. 82, 83 or 87 hours in a month for the funded project? Should the person enter 10.25 "Days worked in the action" for 82 hours, 10.375 days for 83 hours and 10.875 days for 87 hours for the month in question (i.e. only round down or up the nearest half day when calculating the total (at "TOTAL"))? Or should one already round down or up to the nearest half-day in the line for the respective month?

Is there perhaps an illustration example of how exactly the "monthly declaration" is to be filled in? 

Antwort vom 30.8.2023:                           
Please note, that for persons who work for the the beneficiary may either:

• by default, sign a monthly declaration on days spent for the action (template) OR
• use another paper- or computer-based reliable time recording system, to record (at least) all the time (days/hours) worked in the action

It means that there is no need to use parallel time recording systems - you may use only one. It is recommended to explore the simplification potential of using monthly declarations on days spent for the action. This limits record-keeping burden and avoids the need for conversion of hours into day-equivalents.

If you keep parallel time record systems, e.g. weekly time-sheets of hours and monthly declarations of days, they must be consistent. In case of significant discrepancies discovered e.g. during checks, reviews and audits, only the set of documents recording the lower amount of days will be accepted

In the case of monthly declarations, rounding up or down to the nearest half-day is required when reporting the total number of day-equivalents worked during the reporting period (at the end of the reporting period). That being said, it is possible to declare non-rounded day-equivalents in the monthly declaration.

For more details please consult Annotated Model Grant Agreement, notably annotations to article 20.

Kind regards,                     
The Research Enquiry Service

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Sonderzahlungen

In the Horizon Europe AGA, art. 6.1(a)(ii) states: “eligible costs must be incurred in the period set out in Article 4”. This is the same wording as in the H2020 AGA, art 6.1.

However, as we understand it, concerning eligible costs and the calculation of the hourly rate there has been a change from H2020 to HE. In H2020, some costs had to be “apportioned” to be eligible.

For instance, the 13th salary or special holiday allowance had to be apportioned with 1/12 of the cost to be allocated and recorded on a monthly basis.

This was a rather time consuming and manual procedure that often led to errors.

Horizon Europe introduces a new methodology for the calculation of the Daily Rate.

If the reporting period is 12 months, all the salary costs recorded for the person during this period have to be summarized and divided by 215.

As we understand it, this could also include costs generated before the 12 months period if these costs are recorded and booked in line with the beneficiary´s normal internal procedures. Please confirm if this is correctly understood?

If so, the HE AGA art.6.1(a)(ii) might need a short explanation concerning the meaning of “incurred in the period”.

An example might illustrate the challenge:                           
A beneficiary has recently had an audit of an EIT Health KIC project following the new HE rules.                           
In this case, the auditor insisted that eligible costs could not include any costs generated outside the reporting period – even if these costs are recorded and booked in line with the beneficiary´s normal internal procedure.

Antwort vom 21.3.2022:                           
In Horizon Europe, the total eligible personnel costs incurred over the reporting period duration (numerator of the daily rate formula) will have to be calculated on the basis of the usual cost accounting practices of the beneficiary. This means that for the cases of 13th salary entitlement (or similar entitlement), the beneficiary will apply its usual accounting practice, i.e.:

1. Either include the accrued amounts over the reporting period duration (as this would be the case you seem to refer to in your query),
2. Or include the full amount paid in a given month covered by the reporting period.

In this respect, the ‘generating event’ will depend on the beneficiary’s usual practices: being either each monthly accrued amount or being the full amount paid of the 13th salary.                          

Kind regards,                           
Legal and financial helpdesk

Folgefrage der österreichischen R&F NCPs

I kindly ask for clarification of the following question: Payments such as 13th and 14th salaries are only eligible

1. concerning the part of it that refers to the months within the reporting period during which the person worked for the project (which is evident) and
2. only concerning amounts that are accrued in the accounts of the beneficiary (i.e. only 13th/14th salaries actually paid are eligible, even if the person has a legal entitlement to the respective part of it already before the actual payment),

is that correct?

Antwort vom 28.7.2023:                           
We understand that your question refers to eligibility conditions for 13th salary entitlement.

First of all, in order to be considered eligible, costs must fulfil all the general and specific eligibility conditions set out in Article 6.1(a) and Article 6.2.A.1 of the Horizon Europe Model Grant Agreement (‘HE MGA’ available here: general-mga_horizon-euratom_en.pdf (europa.eu)).

Concerning your question on the 13th salary entitlement, please be reminded that the actual personnel costs are those eligible cost recorded in accordance with the beneficiaries’ usual cost accounting practices in their statutory accounts until the end of the reporting period for which they are calculating the daily rate.

This means that for the cases of 13th salary entitlement (or similar entitlement), the beneficiary will apply its usual accounting practice, i.e.:

Either include the accrued amounts over the reporting period duration;

Or include the full amount paid in a given month covered by the reporting period.

Therefore, if the beneficiary’s usual cost accounting practise is to accrue in its accounts a percentage of the eligible 13th salary each month, the beneficiary can include the amounts accrued during the reporting period. If the beneficiary uses cash based accounting, then it can include only the 13th salary payments recorded in its account’s during the reporting period.

However, as said above, we are not in a position to validate individual cases and we can only provide guidance on the general rules applicable in Horizon Europe.

For additional information, you may consult the annotations to the abovementioned Articles in the Annotated Grant Agreement.

Kind regards,                            
Legal and financial helpdesk

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Zeiten der Elternkarenz

In H2020, the AMGA stated that for beneficiaries using the monthly hourly rate: “Beneficiaries may declare personnel costs incurred in periods of parental leave in proportion to the time the person worked on the action in that financial year.

”However, in Horizon Europe the reference to “in proportion to the time” seems to have been abandoned.Instead, the Horizon Europe AMGA states: “The actual time spent on parental leave by a person assigned to the action may be deducted from the 215 days indicated in the above formula”.

This is indeed a simplification, but several beneficiaries have doubts how this will work in practice.An example might illustrate the challenge.

Assume a Horizon Europe project starts 1 of Jan. 2023 and the first reporting period is 12 months.Ms. X starts working on the project as of 1 of Jan. 2023.

However, as of 1 of Feb. 2023 Ms. X goes on 11 months parental leave.Assuming Ms. X has a normal salary of 2000 €/month and during her parental leave the beneficiary incurs a parental leave cost of 1000 €/month.

In that case, the total annual salary costs for Ms. X would be (2000 + 11 x 1000) = 13.000 €. However, Ms. X only worked for one month = 18 days on the action during 2023.

This would mean that for 2023 the daily rate for Ms. X would be 13.000 €/ 18 days = 722€/day.

Please confirm if this calculation is correct?

Antwort vom 10.6.2022:                           
As a first remark, the reference to ‘beneficiaries may declare personnel costs incurred in periods of parental leave in proportion to the time the person worked on the action in that financial year’ was indeed relevant for the monthly calculation option in H2020. Otherwise, without this specific/side calculation, it would not have been possible to declare such costs for the beneficiaries.

Then, both in H2020 for the annual daily rate calculation and in HE for the daily rate over the reporting period, the formulas for deducting parental leave are similar (i.e. they both refer to the possibility to deduct actual time spent on parental leave).

In accordance with Article 6.2.A.1 of the Horizon Europe Model Grant Agreement (HE MGA), the costs incurred during periods of parental leave which are not fully covered by other sources can be charged to the grant and the actual time spent on parental leave by a given individual may be deducted from the denominator of the daily rate formula and for the calculation of the maximum declarable days. In other words, the maximum declarable day-equivalents may be reduced by the number of day-equivalents spent on parental leave.

Against that background, the correct methodology according to Article 6.2.A.1 and based on the information you provided would be the following:

• Daily rate                           
  = {annual personnel costs for the person divided by 215 minus day-equivalents spent on parental leave}                           
  = (2000+11*1000) / [215 - (215/12*11)]                           
  = 13.000 / [215 – 197]                           
  = 13.000 / 18                           
  = 722 € per day                           
   
• Personnel costs                           
  = {daily rate for the person multiplied by number of day-equivalents worked on the action (rounded up or down to the nearest half-day) capped at the maximum declarable day- equivalents resulting from the deduction}                           
  = 722 * 18                           
  = 13.000€

Although the result of your calculation is correct, please note that the step 13.000/18 could be source of confusion. In this regard we underline the importance of subtracting the number of day- equivalents spent on parental leave for the calculation of themaximum declarable days and the daily rate.

Kind Regards                           
Legal and financial helpdesk

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Papamonat

The AGA states that "Parental leave is any leave directly related to the birth or adoption of a child.". In Austria we have a so-called "Papamonat" which is a legal entitlement for fathers to take a leave without payment related to the birth of their child. I assume that this type of leave is considered as "parental leave" as defined above, i.e. this leave is deductible for the calculation of the maximum declarable days as stated in the (A)MGA?

Antwort vom 10.7.2023:                           
For the calculation of actual personnel costs under Horizon Europe, the actual time spent on parental leave by a given individual during the reporting period may be deducted for the calculation of the maximum declarable days and the calculation of the daily rate (i.e. by reducing the maximum declarable day-equivalents in the formulas by the number of day-equivalents spent on parental leave).

As explained in the annotations under Article 6.2.A.1 of the Horizon Europe Model Grant Agreement (see version 1.0 of 01 April 2023 available at https://ec.europa.eu/info/funding- tenders/opportunities/docs/2021-2027/common/guidance/aga_en.pdf p. 52), parental leave is any leave directly related to the birth or adoption of a child. This covers leaves to which parents are entitled due directly to the birth/adoption of a child. On the contrary, leaves not only related to the birth or adoption of a child but also to other circumstances (e.g. leave to take care of a sick child, breastfeeding leave) are not considered as parental leave under Horizon Europe.

Against this background, if according to the national law, a person is entitled to parental leave and this parental leave is directly related to the birth or adoption of a child, the days spent on parental leave during the reporting period may be deducted from the calculation of the maximum declarable days and the calculation of the daily rate. 

Kind Regards                           
Legal and financial helpdesk

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Freistellung in der Kündigungsfrist

Frage der zypriotischen R&F NCPs

A researcher, working full time on a HE project, was dismissed with immediate effect and asked to stay home for the time of his notice period (‘Garden leave’). Following the national law, the researcher was paid during that period (two weeks).

• Is the personnel cost related to the ‘Garden leave’ eligible for funding?
• If yes, practically how the employer/beneficiary will justify the cost, taking into consideration that the researcher did not actually work on the project and therefore he did not fill in the time sheets for the period of the ‘Garden leave’.

Antwort vom 3.7.2023:                          
We understand that your question relates to whether, it can be charged to the project the costs of an employee during the notice period or “Garden leave”.

The “Garden leave” is a practice deriving from a decision of the employer whereby the employer decides that a person leaving a job (either because of resignation or having an employment relationship terminated) does not work during the notice period while the person still remains on the payroll. Accordingly,the “garden leave” is considered as normal working time. Since the person is not working in the EU action, it cannot be eligible for funding.

Kind Regards                           
Legal and financial helpdesk

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Horizontale Obergrenze und Aliquotierung

This request refers to the horizontal ceiling in HE: The AGA states that the actual number of day-equivalents declared in all EU and Euratom grants for one person cannot exceed 215 days per calendar year. As the 215 days refer to a full-time equivalent, a pro-rata calculation has to be done for persons employed part-time.

Question 1) Does this pro-rata calculation also apply to (full-time) persons employed for only part of the calendar year (e.g. person is employed from 01/03 to 31/10 of that calendar year; i.e. pro-rata calculation of 215/12*8)?

Question 2) Does this pro-rata calculation also apply to the case in which the reporting period ends on 31/03 (i.e. pro-rata calculation of 215/12*3 or does the ceiling of 215 days also apply fully to these 3 months, assuming that the person only worked for one project in that calendar year, resulting in a ceiling of maximum 215 days for 01/01-31/03)?

Antwort vom 28.8.2023:                           
The “horizontal ceiling” definition is provided in Article 6.2.A.1 of the Horizon Europe Model Grant Agreement (‘HE MGA’), namely the actual number of day-equivalents declared across EU and Euratom grants cannot be higher than 215 per person per calendar year. It is part of the specific eligibility conditions for the costs for employees (or equivalent). Therefore, it must be respected in order for the costs declared to be eligible, provided that all other general and specific eligibility conditions are complied with.

In answer to your first question, we confirm that the pro-rata of 215 for the horizontal ceiling has to be calculated in case of part-time employment of the personnel at the beneficiary and in case of employment of the personnel at the beneficiary for only part of the calendar year.

In order to reply to your second question, we wish to underline distinctions between the notions of “horizontal ceiling” and “maximum declarable day-equivalents. The horizontal ceiling applies per calendar year. Differently, the “maximum declarable day-equivalents” (i.e. “reporting period ceiling”) is the maximum number of days the person can work in the reporting period, taking into account the working time factor and the length of employment of the person during the reporting period. It is normally calculated per reporting according to the following formula:{((215 / 12) multiplied by the number of months within the reporting period) multiplied by the working time factor}Regarding the example provided in the second question, as the idea of horizontal ceiling is to be checked at the level of the calendar year only, there is no need to check the horizontal ceiling at the end of March.

Please note that both ceilings (i.e. horizontal ceiling and reporting period ceiling) have to be taken into account when calculating the personnel costs. This means that, in any case you will have to consider that the number of day-equivalents declared across EU and Euratom grants for the researcher is not higher than the 215 days per calendar year, while at the same time ensuring that the number of days-equivalents to be declared is capped at the maximum declarable day-equivalents per reporting period​.

Kind regards,                      
Legal and financial helpdesk

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Horizontale Obergrenze: Berechnung

A full-time employee worked in 2022 on the implementation of two Horizon Europe projects. According to his monthly declarations, he devoted 205.3 Day-equivalents to the implementation of Project 1 and 15.5 Day-equivalents to Project 2.

The total day-equivalents of the specific employee for 2022 is 220.8 which exceeds the Horizontal Ceiling (215 Day-equivalents) by 5.8 Days. The question raised is how the horizontal ceiling – in this case, the reduction of the 5.8 days - will be applied?

Is it OK the 5.8 days be taken off from one project. i.e to claim          
- 199.5 day-equivalents in Project 1 and 15.5 day-equivalents in Project 2          
OR          
  - 205.3≈205.5 day-equivalents in Project 1 and 9.7≈9.5 day-equivalents in Project 2

OR the reduction should be proportional to the day-equivalent of each project ie [205.3 - (5.8/220.8)*205.3=199.9≈200] for project 1 and [15.5 - (5.8/220.8)*15.5=15.1≈15 days] for project 2?

Similarly, how the horizontal ceiling is applied if the employee works during a calendar year in 3 or more projects.

Finally, when the rounding to the closest 0.5 Days is applied?

Antwort vom 28.8.2023:                           
The “horizontal ceiling” definition is provided in Article 6.2.A.1 of the Horizon Europe Model Grant Agreement (‘HE MGA’), namely that beneficiary must ensure that the total number of day-equivalents declared across EU and Euratom grants for a researcher does not exceed 215 days per calendar year.

In practice, the element to be taken into account is the chronological aspect of the EU and Euratom projects in which the person is involved and for which project you have already reported personnel costs. In this respect, as it would be unlikely that projects have the same reporting period end date, the beneficiary should declare all the day-equivalents in the project with the reporting period that comes first. Then, for the second project, the beneficiary can adjust the number of day-equivalents to respect the horizontal ceiling rule for the year at stake covered by the reporting period.

In any case, the number of projects a person works on in a year is not relevant; you must still adhere to the horizontal ceiling, even for employees dedicated to only one project or several. The logic explained above, for complying with the horizontal ceiling rule, would also apply where more than two EU/Euratom projects are running in parallel.

The rounding should be done only for the calculation of the total maximum declarable day equivalents and total number of day-equivalents worked on the action while calculating the total personnel cost of a person during reporting. You should not make the rounding for calculation of horizontal ceiling.

For more details please consult Annotated Model Grant Agreement, notably annotations to Article 6.2.A.1 and Article 20.

Kind regards,          
Legal and financial helpdesk

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Aliquotierung der 215 Tage

Frage der tschechischen R&F NCPs

Pro-rata calculation takes into the consideration part time work (e.g. 0,5 FTE). Is pro rata-rata calculation relevant also for e.g. 1,2 FTE (if allowed by national legislation)?

Antwort vom 1.7.2022:                           
In the specific case where an employee would represent more than 1 Full-Time Equivalent (FTE), and provided this is in compliance with the applicable national labour legislation, this can be reflected in the corresponding pro-rata calculation for both:

1. the maximum declarable day-equivalent in the daily rate calculation and
2. the horizontal capping of 215 per calendar year. 

Kind Regards                           
The Research Enquiry Back-Office

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Überlassene Personen

Frage der tschechischen R&F NCPs

Are there any differences concerning the calculation of eligible costs of seconded persons in H2020 and HE?

According to the H2020 AGA: “Costs for persons seconded by a third party may be declared ONLY as actual costs. There is no specific calculation method; the costs must correspond to the price paid by the beneficiary — up to the costs actually incurred by the third party (see Article 11.1). For the calculation of the upper limit (i.e. the third party’s actual costs), the same calculation rules apply as in point 1.1.4.”.

According to the HE AGA: “Costs of seconded persons against payment must be calculated as follows: {amount per unit (daily rate)} Mulitiplied by {number of day-equivalents worked on the action}. The daily rate must be calculated as follows: - if the contract specifies a daily rate: this daily rate must be used … For seconded persons, if the resulting daily rate is higher than the daily rate actually paid by the third party to the seconded person (applying the calculation rules of the Grant Agreement) the 16 cost could NOT be declared as personnel costs. They may be eligible instead as purchase of services (see Article 6.2.C.3) or subcontracting (see Article 6.2.B). The reason is that the payment made by the beneficiary to the third party would be higher than the actual remuneration of the person, which implies that a commercial margin or other non-personnel costs are charged by the third party to the beneficiary.“

According to our understanding, in H2020 to identify eligible amount of cost, actual personnel costs of seconded personnel must be calculated (the same formulas as for employees). Is it the same for Horizon Europe or not? Are there any differences? Is it sufficient in Horizon Europe to take the rate specified in the contract (a secondment agreement with the employer of the natural person) without doing any calculations of real costs? Or is it necessary to do to calculations of actual personnel costs (the same formulas as for the employees) to identify eligible amount of personnel costs plus include extra cost in the secondment agreement which will be considered as eligible in other cost categories?

Antwort vom 15.11.2022:                           
In Horizon Europe, as explained in the AGA: if the resulting daily rate is higher than the daily rate actually paid by the third party to the seconded person (applying the calculation rules of the Grant Agreement) the cost could NOT be declared as personnel costs.

They may be eligible instead as purchase of services (see Article 6.2.C.3) or subcontracting (see Article 6.2.B). The reason is that the payment made by the beneficiary to the third party would be higher than the actual remuneration of the person, which implies that a commercial margin or other non personnel costs are charged by the third party to the beneficiary.

Kind Regards                           
The Research Enquiry Back-Office

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Übliche Reisepraxis

The internal rules (= usual practice) of an organisation concerning travel state that besides economic efficiency also (environmental) sustainability is a criterion that needs to be respected. This could lead to situations where a train ticket is preferred to a flight ticket due to its higher sustainability, even though it is more expensive than the flight ticket. Will a more expensive train ticket be accepted by the European Commission in Horizon 2020 and Horizon Europe projects?

Antwort vom 13.10.2022:                           
As regards Horizon 2020, Art 6.2.D.1 of the Horizon 2020 Model Grant Agreement establishes that travel costs and related subsistence allowances (including related duties, taxes and charges such as non-deductible value added tax (VAT) paid by the beneficiary) are eligible if they are in line with the 17 beneficiary’s usual practices on travel.

In this respect, according to annotations in the Horizon 2020 AMGA on costs eligibility conditions (pg 80), costs must fulfil the general conditions for actual costs to be eligible according to Art. 6.1 of the MGA amongst which that “ they must be reasonable, justified and must comply with the principle of sound financial management, in particular regarding economy and efficiency”, and they must also “be in line with the beneficiary’s usual practices on travel”.

Therefore, assuming that the conditions of Art. 6.1 of the MGA are complied with and that the incurred costs are in line with the beneficiary’s practices, these costs would be accepted. As regards Horizon Europe, the same principle would apply. The costs must comply with the general and specific eligibility conditions set out in Article 6.1 and 6.2.C.1 of the Horizon Europe Model Grant Agreement (available here: general-mga_horizon-euratom_en.pdf (europa.eu)) and in particular, be in line with the beneficiary’s usual practices on travel.

Therefore, if it is the usual practice of the beneficiary to pay for such travels, in view of sustainability reasons, the costs could be deemed eligible if in line with the above conditions. For further information, please consult the related explanations in the Annotated Grant Agreement.

Kind Regards                           
Legal and financial helpdesk

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Anteilsmäßige Verrechnung von Reisekosten und Konferenzgebühren

I have a following question concenring the travel costs in Horizon Europe: Project ends on 31st August 2023. The project leader intends to attend an international conference (necessary for the action) taking place from 29th August to 1st September.

Is it possible to allocate the travel expenses and per diems proportionally and charge a portion to the project? How should we categorize the conference fee? Can it also be divided proportionally? Thank you in advance for your reply.

Antwort vom 10.8.2023:                            
As preliminary remark we would like to recall that the any cost must fulfill the general eligibility conditions set out in Article 6.1 of the Model Grant Agreement. In this regard andamong others, the costs must be incurred in connection with the action and necessary for its implementation and be incurred during the action duration. In that regard, the AGA (see version 1.0 of 1 April 2023 page 38) stresses that ‘i.e. the generating eventthat triggers the costs must take place during the action duration set out in the Data Sheet’.

From your question we understand that you refer to participation in an international conference that ‘is necessary for the action’ (assumingly to present project-related results) andthat takes place during the action implementation (i.e. 29 August till 31 August). In that respect, the corresponding travel costs (including the costs for the return journey) related to this period can be declared as eligible but provided that the international conferenceis indeed necessary for the action and that other applicable general cost eligibility conditions set out in article 6.1 and 6.2 are also complied with (notably that travel costs must reflect the beneficiary’s usual practice on travel).

Concerning the conference fee, and assuming that you refer to a fee associated with the participation in a scientific conference for presenting project-related results, such conferencefees are mentioned in the Annotated Model Grant Agreement as an example of dissemination costs and they typically fall into the cost category for “other goods works and services" under Article 6.2.C.3. As regards the allocation of the costs, beneficiariesshould follow their usual cost accounting practices.

Kind Regards                            
Legal and financial helpdesk

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Reisekosten Assoziierter Partner:innen

Frage der estnischen R&F NCPs

My question about the eligibility of the associated partner's staff travel costs if covered by the beneficiary's budget is: Is it generally possible and allowed in principle?

Antwort vom 2.2.2023:                            
Associated partners are entities which implement action tasks but without receiving EU funding and without becoming party to the Grant Agreement (i.e. they do not sign the Grant Agreement). According to Article 9.1 of the Horizon Europe Model Grant Agreement, they may not charge costs or contributions to the action and the costs for their tasks are not eligible.

Therefore, costs for the travels undertaken by personnel of associated partners in the context of the performance of their actions tasks are not eligible under Horizon Europe, regardless whether the costs are incurred by the beneficiaries or by the associated partners themselves. Otherwise, it could be seen as a way of circumventing the rules.

Kind Regards                           
Legal and financial helpdesk

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Vorfinanzierung

As I understood from the AMGA, the prefinancing is calculated as follows: "it will normally be (depending on the availability of EU budget credits) 100 % of the average EU funding per reporting period (i.e. maximum grant amount set out in Article 5.1 / number of periods)."

However, different clients with Horizon Europe projects have received a pre- financing of around 53% of the Maximum Grant Amount, even if their projects have three or more reporting periods.

What is the rule to calculate the prefinancing in Horizon Europe and is there any special calculation method for lump sum projects?

Antwort vom 17.10.2021:                           
In Horizon Europe, after the grant has been signed, the consortium will normally receive a float to start working on the project (normally, pre-financing of 160% of the average EU funding per reporting period (i.e. maximum grant amount/number of periods); exceptionally, less or no pre-financing). For actions with only one reporting period, it will be less, since 100% would mean the totality of the grant amount.

Note that payments will be automatically lowered if one of the consortium members has outstanding debts towards the EU (granting authority or other EU bodies). Such debts will be offsetby the granting authority, in line with the conditions set out in the grant agreement (see Article 22). Also note that at the moment of the prefinancing payment, an amount ranging from 5% to 8% of the maximum grant amount will be deducted from the prefinancingpayment and transferred to the mutual insurance mechanism. This mechanism covers the risks associated with non-recovery of sums due from the beneficiaries. 

This also applies to Lump Sum projects.

Kind Regards                           
The Research Enquiry Back-Office

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Gender Equality Plan

Does the GEP also apply to private non-profit organisations as obligatory for being eligible in Horizon Europe?

Antwort vom 18.5.2021:                           
For the GEP eligibility criterion, there are three categories of legal entities used in EU programmes that are concerned by this requirement:

• public bodies (including e.g. ministries, research funding organisations, municipalities, as well as public-for-profit organisations such as certain museums)
• research organisations (both public and private)
• higher education establishments (both public and private).

Other categories of legal entities, such as private-for-profit organisations, including small and medium-sized enterprises (SMEs), or non-governmental organisations (NGOs) and civil society organisations (CSOs), are not concerned. This requirement concerns legal entities applying as beneficiaries as well as affiliated entities.

Regarding countries, the requirement concerns organisations established in EU Member States and Associated Countries. Non-associated third countries are not concerned.

Kind Regards                           
Legal and financial helpdesk

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Mehrere Certificates on the Financial Statements pro Projekt

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Berechnung des Schwellenwerts

Frage der spanischen R&F NCPs

Should we take into account the "SME Owners Unit Costs" when calculating the threshold for the CFS?

Antwort vom 21.5.2024:                            
It should be noted that according to the Article 24.2 of the Horizon Europe Model Grant Agreement (MGA p. 65), “If required by the granting authority (see Data Sheet, Point4.3), the beneficiaries must provide certificates on their financial statements (CFS), in accordance with the schedule, threshold and conditions set out in the Data Sheet”    
The CFS threshold is to be calculated separately per beneficiary or affiliated entity for whom financial statements are submitted.     
As indicated in the data sheet (section “4.3 Certificates” of the MGA for HE actions), the CFS is scheduled only at the final payment (except for HE EIT KIC actions with interim CFS), if the threshold is reached.    
The standard threshold for issuing a CFS in the HE is: when the requested EU contribution to costs is equal or higher than the amount of EUR 430 000 (or EUR 725 000 for the specific case of beneficiarywith a low risk SPA beneficiaries see art. 24.4 of the MGA).

Best regards,    
Certification and Audit matters Helpdesk             

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Einnahmen

Frage der tschechischen R&F NCPs

If a for-profit organization opts to deposit a pre-financing payment into a savings account, what becomes of the interest accrued? Does the no-profit rule apply to this interest, potentially reducing the total grant amount during the final payment? I think this should not be the case, as the interest is generated by the payment rather than the action itself. Could you please confirm my understanding?

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Nachweise für Personalkosten in Lump Sum-Projekten                            

Frage der tschechischen R&F NCPs

In lump sum projects „beneficiaries do not need to keep records of their actual costs (e.g. timesheets or invoices). There is no financial reporting, and no checks or audits of the costs incurred“ (see FAQ on the F&T Portal). To clarify it: in lump sum projects neither timesheets nor monthly declaration on days spent for the action are needed (unless required under national law or in internal procedures), correct??

Kind Regards                           
The Research Enquiry Back-Office

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Lump Sum-Budget in 2-stufigen Calls                            

Frage der norwegischen R&F NCPs

Is the detailed budget only requested in stage two? If so, what is the level of budget detail expected in stage one?

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Begründung für höhere Personalkosten

• Provide a concise justification in the “Any comments” tab. If applicable, this should point out the part in the proposal where more information is available.
• The circumstances that lead to particularly high personnel costs should be clear in the proposal (e.g., the need for senior staff should be justified in and by the work plan).

Kind regards,        
The Research Enquiry Service back-office

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Antragsformular

A client is preparing a proposal for a topic under lump sum scheme. Under lump sum scheme, they are providing the detailed budget table (Excel document). So they ask if they should also include in Part B of the proposal the following detailed information:

• table 3.1h ‘purchase costs’ for participants where those costs exceed 15% of the personnel costs (according to the budget table in proposal part A)
• table 3.1i ‘other costs categories’
• table 3.1j in-kind contributions from third parties

Kind regards,       
Research Enquiry Service - Back Office

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