Last updated: October 4, 2026
All Horizon Europe applications must comply with applicable ethical principles, rules and regulations. Proposals are first assessed through the scientific evaluation process and, for proposals above threshold and considered for funding, this is followed by an Ethics Review carried out by independent ethics experts.
From the applicants’ point of view, ethics is sometimes treated as one of the final administrative steps in preparing a Horizon Europe proposal: dealing with the “main” parts of the application, and only reaching the ethics when the deadline is around the corner. Treating ethics this way can create avoidable problems later in the project.
Ethics requirements can influence the project methodology, consortium composition, timetable, resources, data-management procedures and, importantly, the feasibility of certain activities. Addressing them properly is therefore not only a matter of compliance. It is part of designing a credible and executable project.
During scientific evaluation, expert evaluators may pick up on proposals which do not convincingly demonstrate that ethical considerations were integrated in their methodology and design, which may compromise evaluation outcome. Even if such issues are not raised at this stage, they may be raised during the subsequent Ethics Review by ethics experts, either leading to significant delays in project start or ultimately leading to rejection on ethical grounds.
Even more so, moving from evaluation to execution, a well-designed ethics approach during the proposal phase can make the later execution of the project considerably smoother. By contrast, ethics issues that are identified too late may result in delayed activities, missing approvals, missing budget for mandatory ethics-related activities, unsuitable procedures or responsibilities that no partner is prepared to take on, and more.
The ethics self-assessment is more than a checklist
The Horizon Europe ethics self-assessment helps applicants identify the ethics issues raised by their proposed activities and explain how these will be addressed.
When an ethics issue is relevant, applicants are expected to declare and describe the issue, the measures that will ensure compliance and the documents or approvals that are already available. When an approval cannot yet be obtained, the proposal should explain when and how it will be secured. A clear assessment can support a more efficient ethics-clearance and grant-preparation process.
This is important because the ethics self-assessment does not disappear after the proposal is evaluated. Relevant ethics commitments and ethics requirements may become part of your Grant Agreement. They can therefore become binding obligations and may later be examined during ethics checks, reviews or audits.
In practical terms, do not write something in the ethics section simply because it sounds reassuring. Make sure that the consortium can actually implement every procedure, safeguard and monitoring mechanism it promises.
Start by Identifying What Is Relevant
The ethics self-assessment guidance covers a broad range of categories:
- human Embryonic Stems Cells (hESCs) or human Embryos (hE)
- activities involving human participants, cells or tissues;
- personal data;
- animals;
- activities in non-EU countries;
- environmental, health and safety concerns;
- artificial intelligence;
- other ethics issues and the potential misuse of results.
Each proposal should determine which categories are relevant and address them.
For some scientific fields, ethics-related issues may be obvious: A clinical project will have to deal with patients, personal data, informed consent and ethics approvals. However, ethics issues are not always obvious. Interviews, surveys, observations, social-media research, behavioural experiments, environmental activities, security-related research and the development or deployment of AI may also raise significant concerns.
A common error is to decide too quickly that an ethics category is irrelevant. For example, a project may not initially appear to involve human participants, but its pilots could include end users. A technical project may process personal data indirectly. An AI system may create risks related to bias, transparency, human oversight or vulnerable groups.
Read each question in relation to the activities you are actually proposing, not only in relation to the project’s general scientific field.
Ethics by design means starting early
The right time to address ethics is while the project is being designed.
At this stage, the consortium can still adapt the methodology, introduce appropriate safeguards, allocate responsibilities and even recruit partners to include the expertise needed to implement the work correctly. The European Commission guidance explicitly recommends thinking about ethics during proposal design rather than waiting until the final stages of preparation.
Start by mapping the planned methodology and activities. Ask practical questions:
Who will interact with participants? Who will obtain informed consent? Who will control access to personal data? Which partner will apply for local approvals? What happens when several countries have different procedures? Who will monitor compliance throughout the project?
The answers should be reflected consistently across the proposal. The ethics section, methodology, work plan, risk table, deliverables, milestones, budget and consortium description should tell the same story.
Involve the right partners
Ethics cannot always be handled centrally by the coordinator. The partners conducting the relevant activities must contribute to the ethics assessment and plan the suggested measures.
A partner recruiting participants should help define recruitment and consent procedures. A partner processing personal data should involve its data protection specialists. Technology developers should contribute to the assessment of AI, safety or misuse risks. Partners working outside the EU should clarify the applicable local legal and ethics frameworks.
This may also affect consortium building. When an ethics-sensitive activity is essential to the project, the consortium should consider including a partner with the expertise, infrastructure and institutional capacity to conduct it responsibly.
It is recommended to seek advice from relevant institutional experts, including ethics and compliance departments, ethics committees, company ethics advisers and data protection officers. For projects with a significant or complex ethics dimension, appointing an independent ethics adviser or an ethics advisory board may also be considered.
Do not assume that you must solve every question alone. External ethics experts with experience in EU-funded projects can often be found through professional networks, specialist organisations and platforms such as LinkedIn. The important point is to approach them early enough for their advice to influence the proposal, not only to review a nearly finished ethics table before submission.
Ethics is part of project quality
A strong ethics self-assessment does not try to convince evaluators that the project has no risks. It demonstrates that the consortium understands its activities, has identified the relevant concerns and has designed realistic procedures to manage them.
This is the principle that will guide our Horizon Europe ethics article series. In the upcoming articles, we will examine individual categories of the ethics self-assessment, the questions applicants should ask and the information that should be prepared during proposal development.
The central message is simple: do not neglect ethics, do not leave it until the last minute and do not treat it as a generic section.
Identify what is relevant to your specific project, involve the right partners and seek specialist advice where needed. The effort invested during the proposal phase will support both a stronger application and a project that is easier to execute responsibly.