Security Scrutiny

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  • The European Commission is changing the way security-related issues are checked in Horizon Europe. In Horizon 2020, proposals submitted only to topics flagged as ‘security-sensitive’ were checked. 
  • In order to ensure that classified information is protected also in the context of EU grants, some EU programmes (including Horizon Europe) will systematically be subject to a security scrutiny procedure for applications that operate in security relevant contexts. Security issues will therefore be checked systematically across all Horizon Europe proposals based on a self-assessment included in a submitted proposal which will ascertain:
    • Whether the proposal uses or generates EU classified information; 
    • Potential of misuse of results (that could be channelled into crime or terrorism), and
    • Whether activities involve information or materials subject to national security restrictions.
  • The self-assessment checks may in turn trigger an in-depth security scrutiny for those project deemed to include classified or security sensitive information. In this scenario, proposals must be cleared by the Security Scrutiny Working Group (composed of experts from the national security agencies (NSAs). The Security Scrutiny Working Group will undergo a Security Appraisal Process to determine the level of sensitivity of the proposal and check whether all security aspects are being handled appropriately. 
  • If the outcome of this process leads to requirements to be implemented before grant signature, the beneficiary will need to take immediate action to comply. If the outcome leads to classification and additional requirements to be fulfilled during the project, this will be automatically reflected in the system (classification of existing deliverables, Security Aspect Letter (SAL), Security Classification Guide (SCG), additional security deliverables and a dedicated work package). Finally, if the Appraisal process shows that the project is too security sensitive, funding may have to be refused.
  • In Horizon Europe, some calls related to security-sensitive issues may limit the participation of Associated Countries or Third Country entities on the basis of national security restrictions or EU classified information, known as duly justified exclusions. 
  • Article 13 of the draft Model Grant Agreement also provides additional information on security-related issues: 
    • "If EU classified information is used or generated by the action, it must be treated in accordance with the security classification guide (SCG) and security aspect letter (SAL) set out in Annex 1 and Commission Decision (EU, Euratom) 2015/44441 and its implementing rules — until it is declassified. Deliverables which contain EU classified information must be submitted according to special procedures agreed with the granting authority. Action tasks involving EU classified information may be subcontracted only with prior explicit written approval from the granting authority and only to entities established in an EU Member State or in a non-EU country with a security of information agreement with the EU (or an administrative arrangement with the Commission). EU classified information may not be released to any third party (including participants involved in the action".