Participation in Horizon Europe is generally possible for EU Member States and many other countries. For more information on the eligibility of non-EU countries, please refer to our infosheet on International Cooperation in Horizon Europe and to our Country Eligibility Overview tool.

However, in Horizon Europe, some call topics (mainly in Cluster 3 & 4 work programmes) are subject to restricted participation based on article 22.5 of the Horizon Europe Regulation.

This infosheet provides a comprehensive overview of what you need to know as a Horizon Europe applicant.

What is Article 22.5?

Article 22.5 of the Horizon Europe Regulation establishes specific eligibility criteria for entities participating in certain EU-funded projects. These restrictions are designed to ensure that projects involving sensitive technologies remain under appropriate control and do not pose risks to EU strategic interests. The original scope was mainly security and quantum topics, from 2025 it expanded to include AI, Robotics, some data topics, photonics, Telecoms (SNS), and now a lot of Chips JU topics as well.

(These restrictions are similar to article 12.5/12.6 in Digital Europe – see our dedicated infosheet ‘Security restrictions in Digital Europe (art. 12.5/12.6) and ownership control’.)

Ownership and Control Assessment

The key requirement under article 22.5 is that entities must not be controlled by non-eligible countries or their entities. Here's what you need to know:

What Does "Control" Mean?

Control is assessed based on several factors:

• Ownership of more than 50% of shares or voting rights
• Ability to exercise decisive influence over strategic decisions
• Appointment rights for key management positions
• Special rights that allow blocking of important decisions

When Is the Assessment Done?

The ownership and control assessment occurs at the following moments:

• Proposal Submission: You must complete an Ownership and Control Document (OCD) template when submitting your proposal.
• Grant Agreement Preparation: The assessment is verified again before the grant agreement is signed.
• During Project Implementation: If ownership or control changes during the project, you must notify the European Commission immediately.

When is an Ownership Control Declaration (OCD) needed?

An Ownership Control Declaration (OCD) is only mandatory if the call topic explicitly mentions article 22.5 of the Horizon Europe Regulation or equivalent restrictions in other EU programmes. These restrictions are call-specific and aim to safeguard the EU’s strategic assets, interests, autonomy, or security. Calls subject to such restrictions are clearly flagged in the call conditions published on the Funding & Tenders Portal. Therefore, applicants must carefully review the call text to determine if an OCD is required.

Detailed information can be found in our infosheet on 'Ownership Control Declaration & Assessment'.

Special Requirements for Financial Support to Third Parties (FSTP)

If you are applying for a project that will provide Financial Support to Third Parties (FSTP) (in detail explained in this infosheet), there are additional considerations regarding article 22.5 compliance:

Simplified Rules for FSTP Recipients

Recognising the administrative burden of applying full article 22.5 checks to potentially hundreds of FSTP recipients, the Commission has introduced simplified rules for the 2026 work programme:

• FSTP recipients will have lighter ownership and control verification requirements compared to direct beneficiaries.
• The exact procedures will be specified in the relevant call documentation.
• FSTP managers should consult with NCPs and the Commission if questions arise about specific FSTP recipient eligibility.

Responsibility of FSTP Managers

The consortium managing the FSTP cascade funding is responsible for implementing European Commission rules and ensuring that FSTP recipients meet eligibility requirements, including article 22.5 restrictions where applicable. FSTP managers therefore should establish processes to monitor significant ownership changes among FSTP recipients during the project period, as these could affect eligibility and compliance with grant conditions.

Resources and Guidance

The European Commission has developed guidance on FSTP implementation, including the application of article 22.5. Carefully review any call-specific guidance and contact your Project Officer to obtain the relevant documents. Ensure that your FSTP open calls include clear eligibility criteria, as well as appropriate assessment procedures and templates.

Additional possible restriction: protection of European digital infrastructures, communication and information systems

An additional restriction has been recently introduced to ensure the protection of European digital infrastructures, communication and information systems, and related supply chains. It is unrelated to article 22.5 and does not entail the obligation of an Ownership Control Declaration.

This restriction relates to call topics that were identified as topics addressing strategic assets and interest of the EU or its Member States. Only when this restriction is explicitly mentioned in the call text, applicants should avoid using suppliers that the EU has identified as high-risk, as well as technologies and services considered insecure. The current restriction applies only to Huawei and ZTE, based on EU 5G cybersecurity assessments, and does not apply to all non-EU companies.

Relevant Documents

• Guidance document EU Grants: Participant in EU calls with ownership and control restrictions

• Templates of the ownership control declaration can be found under the Reference documents on the Funding & Tenders Portal.