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About the Author: Alberto Álvarez

Alberto holds the title of forestry engineering from the Polytechnic University of Madrid (ES) with a specialisation in forest management, during which he enjoyed an ERASMUS stay at Czech University of Life Sciences Prague (CZ). Regarding his experience, he started working as a research and innovation consultant, specialising in proposal writing with a primary focus on EU projects. After that, he developed his career at IMDEA Materials research centre as a project manager, working in all kinds of proposals and projects (regional, national, European and USA projects), some of them as the leader coordinator. He was involved also in the technology transfer of the research lines’ different results, including patent application and software registration.

First of all, let’s start by explaining what an ‘amendment’ is. In the framework of Horizon Europe, an ‘amendment’ is the modification of the Grant Agreement of the project under implementation.

The amendment is a process that is launched from the project page within the Funding & Tenders portal, and the only authorised partner of the consortium to do so is the project coordinator. Sometimes the Funding Entity can also initiate this process if it detects an error that needs to be corrected.

The reasons why an amendment may be necessary are explained in more detail below.

Objective and subjective assumptions

It is important to know that there are cases in which we can be sure that we will have to make an amendment, but in other cases the line between the flexibility allowed by the project and the need for an amendment to the Subsidy Agreement is more blurred, and the subjectivity of the person in charge of the project on behalf of the Funding Agency (Project officer) comes into play.

Objective assumptions

But let us first see what are those objective assumptions, for which we know we will have to launch a 100% secure amendment process.

  • Inclusion of a new beneficiary, affiliated entity or partner entity.
  • Termination of the participation of a beneficiary, affiliated entity or partner entity during the implementation of the project.
  • Change in the coordinating partner of the project.
  • Change in the bank account of the coordinator (where he/she receives payments from the European Commission).
  • Changes in Annex 1, Description of Action (DoA): only when they are significant changes, including the addition or deletion of new tasks, as well as the addition or deletion of Deliverables. We will show changes to Annex 1 below that are not necessarily grounds for Amendment.
  • Changes to the project start date, project duration (usually because the project needs to be extended), as well as changes to reporting periods.
  • Changes in Annex 2, Budget: an amendment is mandatory if the change of budget between beneficiaries or between categories of expenditure is due to a significant change in the implementation of the action. It will also be necessary if a beneficiary has to use part of its budget in a category that was not foreseen. For example, if according to the Grant Agreement it had € 0 in the subcontracting category, but finally needs a certain amount by transferring part of its staff funds, an amendment is necessary. Changes between items that have different % of funding will also require amendment.

Subjective assumptions

In many cases, the concept of significant change in Annex 1 and 2 is difficult to interpret, as there are no pre-established scales, so the best advice we can give is to consult the project officer (PO) through the F&T portal. Some project officers are stricter than others when requesting the coordinator to release an amendment.

In this sense, changes in the budget, both between partners and between categories within the same beneficiary could be subject to Amendment if the OP considers them to be of sufficient substance in terms of amounts and changes in the purpose of the action.

Otherwise, in general, the principle of budgetary flexibility applies (Article 5.5 of the AMGA), which states that the distribution of the budget can be adjusted without amendment between categories and participants, as long as it does not imply a substantive or major change in the description of the action in Annex 1.

Some examples

Example #1

In a Horizon Europe IA project, one of our work packages dealt with characterising, selecting and testing the use of a product, while the next work package focused on the commercialisation of this product. However, this product did not prove to be effective and therefore no commercialisation work will be carried out in the project.

  • This necessarily leads to an amendment in which the affected tasks will be changed, the marketing related deliverables will be removed or refocused. The budget related to these tasks will have to be significantly restructured, with emphasis on other tasks if expanded.

Example #2

We are approaching the end of an RIA project, and one of the beneficiaries expects to justify 10% less Person Month than it was allocated, which added to the fact that its day cost was finally lower than expected, means that it will be left with a remaining budget, which despite the fact that its travel expenses were higher than expected, is not compensated. On the other hand, another partner is going to spend more budget on the implementation of the project than it was allocated, because it has used more Person Month and spent more money on laboratory equipment than foreseen.

  • In this case an amendment is not necessary, and at the end of the project this redistribution can be made, justifying it appropriately in section 5.2 ‘Use of resources’ of the Technical Report. In any case, if the deviation of Person Months is considerable, and is already foreseen before the end of the project, it is advisable to consult the PO.

Example #3

In Annex 1 of the Grant Agreement of a Horizon Europe project, a number of KPIs are set out, including attending 10 conferences and publishing 20 scientific papers (having established a budget for travel and publication of papers). However, as assessed in one of the consortium meetings, it is expected that eventually approximately 10 scientific papers will be published and 5 conferences will be attended in person. Instead, although not foreseen, 4 articles will now be published in industrial journals. Is it necessary to update Annex 1 and 2 of the Grant Agreement to adjust the KPIs to the new plan?

  • No, in cases like this, it is in the periodic reports where the progress and, in this case, deviation from the initial plan is reported, presenting contingency measures if necessary.

Useful links

  1. Annotated Model Grant Agreement (AMGA) 2021-2027: Articles 39, 40 and 41. https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/common/guidance/aga_en.pdf
  2. Amendment Guide 2021-2027: https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/common/guidance/amendment-guide_en.pdf
  3. Horizon Implementation Day: Grant Management in Horizon Europe (24 October 2023) https://www.youtube.com/watch?v=BWIjLBZnrDI