Is subcontracting between partners allowed in Horizon Europe?

Is subcontracting between partners allowed in Horizon Europe?

No, subcontracting between partners is not allowed in Horizon Europe nor in Horizon 2020 projects. According to the Annotated Model Grant Agreement of Horizon 2020, subcontracting between beneficiaries is not considered eligible as their is the risk of double funding or charging commercial profit margins. There is not explicit reference to subcontracting between partners in Horizon Europe’ General Model Grant Agreement but we can confidently assume that this rule will not change due to the inherent risks it entails.

Other article of interest: Is subcontracting between partners allowed in Horizon Europe?


Annotated Model Grant Agreement (AMGA) Article 13 – Implementation of Action Tasks by Subcontractors

13.1 Rules for subcontracting action tasks: Subcontracting may cover only a limited part of the action. The beneficiaries must award the subcontracts ensuring the best value for money or, if appropriate, the lowest price. In doing so, they must avoid any conflict of interests (see Article 35).

7. Other obligation: Compliance with national procurement rules: Subcontracting between beneficiaries is not allowed in the same GA. All beneficiaries contribute to and are interested in the action; if one beneficiary needs the services of another in order to perform its part of the work it is the second beneficiary who should declare the costs for that work.

AMGA Article 35.1 – Obligation to avoid a conflict of interests

The beneficiaries must take all measures to prevent any situation where the impartial and objective implementation of the action is compromised for reasons involving economic interest, political or national affinity, family or emotional ties or any other shared interest (‘conflict of interests’). These interests may be: economic interests (e.g. unjustified and preferential contracts or subcontracts with connected companies (not based on best value for money, technical merit, etc.)