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Is there a limit to subcontracting costs in Horizon Europe?

In Horizon Europe, there is no fixed limit on subcontracting costs. The Model Grant Agreement (MGA) does not impose any numerical cap.
However, as a general guideline, it is advisable to keep subcontracting costs below 15% of the total project budget.

Key Principles for Subcontracting

Subcontracting should cover only a limited portion of the project’s activities. Beneficiaries must ensure that all subcontracts are awarded according to the “best value for money” principle (or the lowest price, when appropriate).

Importantly, core project deliverables, milestones, or outcomes cannot be subcontracted. The beneficiary remains fully responsible for the quality, timeliness, and performance of any subcontracted work.

Rules and Best Practices

When engaging in subcontracting under Horizon Europe, beneficiaries should keep the following in mind:

  1. Ensure best value for money
    Always follow fair and transparent procurement procedures and avoid any conflicts of interest.
  2. Restrictions on subcontracting relationships
    • Subcontracting between beneficiaries is not permitted.
    • Subcontracting to affiliated entities is generally not allowed.
  3. Budget identification
    All subcontracted tasks and estimated costs must be clearly described in the project budget (Annex 2) and the Description of Action (Annex 1).
  4. Simplified approval procedure
    Subcontracting can be flagged at the reporting stage using the simplified approval procedure. However, the beneficiary assumes the risk that the costs may be rejected if the subcontracting does not comply with Horizon Europe rules.
  5. Accountability
    Beneficiaries are responsible for ensuring that subcontractors deliver high-quality, timely, and compliant results.

Key Takeaway

While Horizon Europe does not set a formal ceiling on subcontracting costs, it is best practice to limit subcontracting to a small share of the total budget—typically below 15%—to maintain compliance and ensure efficient project management.

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