04 Mar 2026
German Helmholtz Association publishes position papers on Horizon Europe proposal
The Helmholtz Association, Germany's largest research organisation, published position papers on the Commission's proposal for the Horizon Europe (2028-2034) Regulation and the Specific Programme, including its interaction with the proposed European Competitiveness Fund Regulation. The positions were prepared by the Helmholtz Brussels Office, in collaboration with the 18 Helmholtz Centres.
The Helmholtz position to the proposed HE 2028-2034 Regulation highlights the following issues, amongst others:
- The association calls for a ring-fenced budget for Horizon Europe, and a prioritisation of low-TRL research activities, as financing of high-TRL acitivities will be funded by the ECF. A coherent value chain perspective is required also for the ECF, including an identifiable budget to bridge the gap between frontier research and innovation via mid-range TRL research and development activities.
- The budget for fundamental research should not be channelled into "moonshot" projects. Existing missions should be completed.
- Horizon Europe needs to retain its distinctive research-driven identity alongside industrial policy focused instruments. It needs to remain open to bottom-up ideas and continue to address urgent societal challenges.
- European researchers and innovators should have access to the research infrastructures needed for world class science.
- There is concern about the proposed “financing not linked to costs” as default for the ECF and and as an instrument for grants of Horizon Europe, as this is regarded as not suitable for research and innovation.
- For reasons of simplification, the association proposes a new approach that accepts full personnel costs, as long as they are paid in accordance with collective labour agreements and are recorded in the beneficiary’s accounts. This approach should be used throughout for personnel cost renumeration and also as basis for lump sum budget calculations.
- The proposed single set of rules should harmonise rules and procedures and provide simplification measures.
- To reduce over-subscription and enhance simplification for applicants and evaluators, a two-step submission process should apply, especially in bottom-up calls.
- Potential dual-use applications should not increase the likelihood of receiving funding .
- The number of EU Partnerships should be reduced, so that the most important receive an increased budget allocation.
- The majority of EIC calls and funding should be dedicated to bottomup civil research, whereas a top-down (D)ARPA approach should be applied selectively and only where duly justified by the nature of the topic.
- Ensuring adequate scale, long-term planning, and coordinated governance of research infrastructures at European level is crucial.
- Open access should still be defined as online access to scholarly publications, provided free of charge and, as far as possible, free of technical and legal barriers.
- The association welcomes the idea of a risk assessments at European level for international collaboration, which may, where necessary and proportionate, lead to restrictions regarding the association of non-EU countries to certain parts of the programme or the participation of specific entities.
The Helmholtz Association's position on the Horizon Europe Specific Programme contains a number of technical considerations to the implementation of the next Framework Programme. These include amongst others:
- Implementation details for pillars and programme parts along the proposed decision;
- pre-deployment grants in ECF or transition projects from previous Horizon Europe projects, as well as research as a service for the interaction ECF – Horizon Europe;
- research areas to be covered by the policy windows in pillar II to secure Europe’s technological sovereignty.
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