The European Association of Innovation Consultants (EAIC) welcomes the 2025 EIC Work Programme, which enhances Europe’s ambition to foster breakthrough innovations. The increase in funding to over €1.4 billion, alongside the launch of the Strategic Technologies for Europe Platform (STEP), reflects a positive shift toward empowering deep tech and other critical technologies within Europe. However, it is unfortunate that the EIC’s overall funding has not been more dramatically increased, as many high-quality projects remain unfunded. 

Limited Support for Startups in the EIC Pathfinder programme 

One of the main issues is that the Work Programme falls short in its support for startups, which are underrepresented among beneficiaries. Of the 45 projects selected under the 2024 EIC Pathfinder Open call, only 22% of participants were SMEs, compared to 46% from higher education institutions and over 20% from research organizations. This distribution suggests a structural limitation, as a core EIC objective is to scale market-ready innovations from startups and SMEs with disruptive potential.  

Recommendation: Enhancing Early-Stage Support in FP10 

As the EAIC pointed out in its recent position paper, developing a market-access-oriented deep tech ecosystem is vital to Europe’s ambitions for industrial leadership and its net-zero transition goals. However, Europe’s funding gap for deep tech, compared to global peers, remains a challenge. Future Framework Programmes could play an essential role in addressing this by increasing early-stage funding opportunities, blending grants and equity to support innovations from inception to scale. 

While STEP’s focus on scale-ups is valuable, a more balanced approach that includes robust support for early-stage ventures would further solidify Europe’s innovation base. We encourage the European Commission to consider additional funding for startups, with clearer, sector-specific guidelines on technology readiness levels (TRLs) and expectations. This alignment would enhance the EIC’s appeal as a funding source that accommodates the unique needs of early-stage ventures, fostering growth across the innovation spectrum. 

Commitment to Ethical Standards and the Role of Consultants 

The EAIC is committed to ethical standards and effective support within the European R&I landscape. We have actively contributed to the EIC’s code of conduct and continue to promote high standards within our own. We welcome ongoing dialogue with the EIC to ensure that consultants contribute constructively to the programme’s evolution, in line with both organizations’ codes of conduct. 
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The EAIC stands ready to work with the EIC to address these challenges and advance an ecosystem where startups and SMEs are positioned to make Europe a leader in competitive, sustainable technology markets.

The EAIC (European Association of Innovation Consultants) welcomes the release of the “Align, Act, Accelerate” report, the European Commission’s Expert Group report on FP10. It offers a forward-thinking and insightful perspective on some of Europe’s key research and innovation challenges while presenting innovative proposals to address them. We are encouraged by its comprehensive approach, and we value the opportunity to contribute to the ongoing discussions on shaping the future of European research and innovation policy. 

Increasing the Budget for FP10 
One of the most significant takeaways from the report is its confirmation of what Europe’s research and innovation community has long supported: that the budget for the next Framework Programme should be dramatically increased and ringfenced to ensure the continuity of critical research initiatives. The EAIC fully supports this recommendation and stresses the need for robust investment in research, development, and innovation (RDI) to ensure that Europe remains competitive on the global stage. 

Simplification of Processes 
The EAIC strongly agrees with the report’s emphasis on simplifying the application process across funding programs. In our recently released position paper on FP10, EAIC members have put forward several concrete proposals to streamline procedures and reduce administrative burdens for applicants.  
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• Clarification of Participation Rules: We recommend extending the Annotated Grant Agreement to include more country-specific examples, particularly for personnel costs. Moreover, greater clarity is needed for lump-sum projects, where unclear guidelines often create unnecessary complexity for applicants. 

• Improving the Evaluation Process: We propose simplifying the evaluation criteria (excellence, impact, implementation) and ensuring consistent scoring across different calls and instruments to avoid confusion among applicants. Ensuring transparency and fairness in evaluations will contribute to higher confidence in the system. 

• Simplifying Lump-Sum Funding: EAIC members advocate for better training for external reviewers on lump-sum funding specifics and the inclusion of post-reporting work packages to manage cash flow and avoid project delays. 

​In this spirit, we commend the report’s focus on stimulating dialogue around simplifying future framework programs and believe these steps are necessary to make the programs more accessible and manageable for applicants of all sizes. However, we stress that simplification must not come at the expense of excellence, efficient use of resources, and appropriate reporting, which are critical for collaborative work and knowledge production. These elements remain key to ensuring the high standards of European research and innovation projects: 

AI Integration in Proposal Writing and Evaluation 
We support the report’s focus on using AI to streamline proposal writing and evaluation, as it has the potential to reduce administrative burdens and improve efficiency and consistency. However, past attempts to integrate AI, such as in the EIC Accelerator, have shown mixed results, highlighting the need to balance efficiency with avoiding algorithmic bias. AI use must remain transparent and adhere to strict ethical guidelines, as outlined in the EIC Accelerator Code of Conduct for consultants, which the EAIC contributed to. 

Likewise, the EAIC, in its paper on FP10, has welcomed the use of AI, but only with strict adherence to all relevant regulations, including GDPR. Every stakeholder involved in the EU grant and tender process must ensure that AI respects proprietary and confidential information and that no data used by AI tools can directly or indirectly identify applicants. This applies to all aspects of European RDI projects, from project design to communication and dissemination. 

Trust-First, Evaluate-Later Model 
The proposal in Section 9 of the report, which suggests moving toward a "trust-first, evaluate-later" model, has great potential to reduce administrative overhead and make the application process more user-friendly, particularly for smaller organizations. However, we believe it is crucial to implement strong oversight mechanisms to safeguard against potential mismanagement. A trust-based model can only thrive if there are checks and balances to ensure that trust is not misused. With appropriate safeguards, this approach could lead to more agile and inclusive research funding. 

The Role of Innovation Consultants 
The EAIC supports much of the report’s recommendations but believes that the discussion of transaction costs and the role of innovation consultants requires additional nuance. For instance, applicants do not rely on consultants solely due to the complexity of the application process. In reality, innovation consultants offer value for many other reasons. For example, they provide coaching and support that helps clients think through and improve the innovativeness of their projects. Consultants can also play a critical role in project management, helping to align large consortia of researchers from different countries and backgrounds. Furthermore, the external perspective they bring helps research organizations and companies sharpen their project strategies and maximize their chances of success. 

Contrary to increasing transaction costs, consultants often help reduce them. For organizations without the resources to hire full-time funding specialists, external consultants provide targeted expertise on an as-needed basis. The European Commission itself highlighted the value of consultants in its Ex post evaluation of Horizon 2020 which states: 

"The involvement of consultancies in the application process further points to economies of scale in proposal writing. Consultancies invest the hassle cost of finding relevant information and getting to know the structure of the framework programme, the rules and procedures, and may have practical experience on how to apply for it. Using this human capital adds value to the consortium for which they are compensated. Specializing certain tasks to external firms may be the most efficient way for applicants to organize themselves." 
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Conclusion 
Overall, the “Align, Act, Accelerate” report represents an important step toward addressing the various challenges within the European research and innovation landscape. While the EAIC supports the vast majority of the report's recommendations, we believe that some aspects, such as the role of innovation consultants, would benefit from further nuance. We look forward to continuing the dialogue and contributing to shaping a more innovative and competitive Europe. 
 
 Contact: Paul Walsh EAIC Secretary General 0032486744337, [email protected]