At a time when think tanks and civil society organizations committed to democracy and European integration face mounting pressure, the European Commission's latest interpretation of the current Horizon Europe funding guidelines, intended to support the institution's simplification objectives, risks producing the opposite result.
In the name of administrative administration, the Commission's interpretation makes participation in European research financially riskier for these actors.
At the center of the issue is a technical change in how indirect costs are reimbursed under Horizon projects.
Previously, organizations could recover indirect costs based on their documented overheads generated by research activities. Now, under the simplified system, these costs are reimbursed at a fixed rate, agreed at the outset of the project.
Such simplification in itself is not necessarily problematic. Many participants welcomed the prospect of reducing administrative burdens and avoiding endless accounting exercises. Yet the Commission's latest interpretation creates a serious and potentially damaging contradiction.
Double funding where none exists
According to the new interpretation, organizations receiving an operating grant under programmes such as the Citizens, Equality, Rights and Values Programme, or CERV, can no longer have indirect costs in Horizon lump-sum budgets. Doing so is deemed to constitute potential double funding.
This applies even where organizations can clearly demonstrate, as they have in the past, that the costs covered under Horizon are different from those financed through the operating grant. In other words, even where there is no actual double funding, the simplified mechanism treats the situation as if there were.
The problem becomes even more acute because this interpretation is now being applied retrospectively to projects already underway.
Organizations that entered into grant agreements in good faith, based on the agreed financial assumptions and implementation practices in place at the start of the project, now face a revised interpretation applied to ongoing projects after costs have already been incurred.
Some are only now realizing this, leaving a gap in their budgets that will have consequences for their operational capacity.
An uneven burden
This raises fundamental concerns about legal certainty and trust. European research funding depends on long-term planning.
Organizations commit staff, infrastructure and financial resources based on contracts agreed with the Commission. If operational interpretations of funding rules shift over the lifetime of projects in ways that materially alter their financial viability, participation in Horizon becomes riskier.
The Commission risks sending a damaging message: that it is not a reliable funding partner.
The consequences are particularly severe for smaller entities, non-profits and think tanks. Large universities and major research institutions may have the financial reserves to absorb unexpected shortfalls. Smaller civil society organizations do not.
Ironically, a reform presented as simplification disproportionately disadvantages precisely those actors with the least administrative and financial capacity.
The long-term implications could be profound.
If participants are effectively forced to choose between applying for an operating grant and participating in Horizon research projects, many will conclude that combining the two is financially impossible.
The likely result is a narrowing of participation in European research ecosystems, with fewer civil society actors and independent think tanks able to contribute.
That would weaken European research and policymaking alike. Horizon has always aimed not only to fund scientific excellence but also to foster broad societal participation and interdisciplinary collaboration.
Civil society organizations and think tanks play a critical role in connecting research with policy, democratic debate and societal impact. Pushing them out of the system would impoverish the quality and diversity of European research networks.
The Commission should urgently reconsider this interpretation and, at the very least, ensure that retrospective application is halted.
Preventing genuine double funding is legitimate and necessary. But where organizations can transparently evidence distinct cost bases, treating them as if they were claiming the same costs twice serves neither accountability nor simplification.
Whatever the underlying motivation, the result risks reducing civil society's contribution to European research and weakening the link between research, policymaking and democratic debate.
With research funding being cut in the U.S. and elsewhere, the EU should strengthen, not weaken, the research ecosystem that has long underpinned European innovation and evidence-based policymaking.
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