Apply AI: GenAI for the public administrations

Yes, please see below a possible template, but other wording is of course possible too provided it contains the same information (funding amount & organization as well as EU funding involve"d).

To whom it may concern, In the context of the “Apply AI: GenAI for the public administrations” calls under the Digital Europe Programme (DIGITAL), we hereby confirm that [competent public body] commits to co-fund the action of the [consortium], should it be selected by the European Commission, with [amount]. [Optional] We, [the competent public body], will use funding from EU funding [name EU fund, e.g. ERDF]. We are coordinating with the relevant granting authorities to ensure synergies between the different funding sources for this grant. Y

ours sincerely, Signatory [public authority/co-funder"

As per call text, the restriction just applies to public administration. Therefore, supporting applicants can be part of different consortia.

At least 50% of the total eligible costs must be dedicated to procurement activities carried out by public administrations in the selected consortium. This reflects the core objective of the call: to enable public administrations to procure and deploy GenAI-based solutions adapted to their specific needs.

According to the call text, the procurement should cover:

• The fine-tuning of European foundation models;
• The development of tailored solutions based on these models;
• The integration of these solutions into existing platforms, systems, and operational workflows.

Additionally, the procurement may also include as additional activities:

• The technical infrastructure needed to deploy and run GenAI solutions at scale (e.g. computing resources, storage, hosting environments);
• Support services, such trainings for the employees, to help public administrations build the necessary skills and knowledge to implement and manage the deployed solutions;
• Maintenance and optimisation of the GenAI solutions during the project period.

Like with all costs under the grant, they need to respect the cost eligibility rules set out in article 6 of the grant agreement.

Yes

The European Commission encourages responsible innovation in AI.

• First, this means among others that civil society is invited to be part of the pilot projects, which is why include civil society organisations in the consortia is encouraged by this call, where relevant.
• Second, the European Commission supports an open-source approach as evidenced by the “open-source European foundational model fine-tuning” action. In fact, the chosen consortia are expected to develop close links with this action. Moreover, open-source will facilitate the expected outcome and deliverable “Replication of piloted GenAI solutions across public administrations and Member States”. A project with an open-source approach is therefore encouraged.

No, they are directly in the consortium to support with different tasks related to procurement. Supporting applicants are not expected to procure solutions themselves, but they support PA during before and after the procurement.

Before the procurement:

• Help defining use cases and translate public administrations needs into realistic scenarios
• Advise on technical requirements
• Promote ethical and trustworthy design of GenAI solutions

After the procurement:

• Help in monitoring and evaluate the impact of the deployed solutions
• Collect user feedback for KPIs

The call does not require system integrators to be part of the consortia, but allows it to support the Public Administration integrating AI solutions in their processes, workflows, etc. The proposals should justify why their consortium members will contribute to the proposal in their envisaged roles, including, if foreseen, as system integrators.

An AI integrator is typically a person, team, or company that specializes in embedding artificial intelligence (AI) technologies into existing systems, applications, or workflows to enhance their functionality, efficiency, and decision-making capabilities.

What Does an AI Integrator typically Do?

• An AI integrator helps organizations: o Identify opportunities where AI can add value (e.g., automation, prediction, personalization).
• Select appropriate AI tools (e.g., machine learning models, natural language processing, computer vision).
• Prepare and structure data for training and deployment.
• Integrate AI models into existing software or business processes.
• Monitor and optimize AI performance over time.

• According to the annotated grant agreement for beneficiaries that are ‘contracting authorities’ or ‘contracting entities’ within the meaning of the EU Public Procurement Directives (Directives 2014/24, 2014/25 and 2009/81) have to comply with the applicable national law on public procurement; these rules normally provide for special procurement procedures for the types of contracts they cover.
• All public procurement procedures in the EU are carried out on the basis of national rules. However, for higher-value contracts, these national rules are derived from and must comply with general EU public procurement directives.
• The value limits (thresholds) that mark when EU rules apply depend on the subject of the purchase, and who is making the purchase. These thresholds are revised regularly and the amounts adjusted slightly. The main current limits are:
• EUR 143 000 for most types of services and supplies purchased by central government authorities
• EUR 5 538 000 for construction contracts
• As the contract values at national level are expected to exceed these thresholds, the national procurements shall follow EU-wide procurement rules, including publication in the EU Offical Portal (TED). For contracts below these thresholds, just national rules apply, but must still respect EU principles like transparency and equal treatment. More guidance on public tendering rules available here: https://europa.eu/youreurope/business/selling-in-eu/public-contracts/public-tendering-rules/index_en.htm.

The European Commission has developed a guarantee template. The use of the guarantee approval template is recommended, but not mandatory. If the template is not used, the communication should include a sufficient level of detail and information to allow to be able to assess eligibility.

According to the call document, EU bodies (with the exception of the European Commission Joint Research Centre) can NOT be part of the consortium.

No - see explanation for article 12.6

Yes, organisations specialised in compliance with the AI Act and other regulations can be one of the supporting applicants.

No, private companies can be included in the consortium without rendering the application ineligible. It is important that the consortium includes public administration as the grant for procurement is primarily intended for them. However, the consortium may include other entities, including private companies.

A private company can be included as a technical advisor or supporting partner, to assist public authorities with needs assessment or solution evaluation for example.

A private company's role in a consoritum must not be to provide the GenAI solutions that will be procured, but to assist public administrations in preparing, implementing, and evaluating the pilots.

Supporting entities in the consortium — such as technology providers, system integrators or RTOs — can support public administrations throughout the action, for instance by:

• helping define requirements and use cases;
• advising on technical integration;
• supporting testing, monitoring or capacity building.

These roles are foreseen in the call and are eligible.

To ensure fair and open procurement, the Digital Europe Work Programme states:

“Entities that are part of a successful consortium will be ineligible to participate as suppliers in the procurement processes initiated by the public administrations within that consortium.”

This means that any entity that joins the consortium cannot compete in the procurement procedures carried out by the public administrations later on.

The call does not restrict the coordinator role to public administrations. Any eligible beneficiary in the consortium — including supporting applicants — can act as project coordinator. However, given the strategic focus of the call on supporting public administrations in procuring and deploying GenAI solutions, it is recommended that the coordinator be:

• A public administration, or
• An entity with strong ties to public administrations, and/or
• Directly involved in defining the use case, overseeing the procurement, and leading the implementation.
• Public administrations are at the core of the project objectives — as both the procurers and end users of the solutions — and therefore are often in the best position to coordinate the action. That said, consortia have the freedom to choose the coordinator, as long as it ensures effective coordination, compliance with the call requirements, and strong engagement from the public sector

i. When it comes to combining ERDF support with Digital Europe for multi-beneficiary projects, it could be possible for the ERDF Managing Authority of a specific country/region to co-fund just part of a Digital Europe project without splitting the Commission’s Digital Europe grant, i.e the combination between ERDF and Digital Europe could be done at the level of the partner. But this always has to be in line with the Managing Authority’s rules and procedures and it will need to be confirmed by them.

ii. For each case of cumulative funding, in line with the Commission Notice on synergies between Horizon Europe and ERDF programmes, the closest up front coordination between the ERDF Managing Authority and the Commission department granting the funding from directly managed instrument is recommended. In case a Managing Authority is interested to combine funding, we thus advice that the Managing Authority gets in contact with our department via CNECT-AI-IN-PUBLIC-ADMINISTRATION@ec.europa.eu

The letters of commitment should show how the remaining 50% will be covered. For example, a table summarizing the letters should be at the beginning of the annex, indicating how the 50% are covered, referring to relevant letters of commitments. This can be per Member State and/or beneficiary.

To be eligible to receive EU funding, any cost – including the procurement - have to be in line with the eligibility criteria in Article 6 of the model grant agreement, e.g. incurred during the action duration, i.e. the generating event that triggers the costs must take place during the action duration.

European Digital Innovation Hubs are not expected to be part of the consortium as such, but the consortium is expected cooperate closely with them since they act as the local gateway and onestop-shop into the wider European AI innovation ecosystem

The call requires that solutions be “based on European models (i.e. models developed by European AI companies/laboratories)”. This means the foundation model should be developed by an entity established in an eligible country such as an EU Member State. Proposals must demonstrate how they contribute to European technological sovereignty. This includes ensuring that:

• The control and development of the models lies with European companies;
• The use of infrastructure and suppliers complies with the restrictions set out in the call and Appendix 4 of the Work Programme, particularly concerning the protection of European digital infrastructure and supply chains.
• In exceptional cases, where an entity may otherwise be ineligible under Article 12(6) (e.g. due to foreign control), a guarantee may be provided by a competent or mandated national authority to support its participation. A guarantee template has been developed by the Commission; its use is recommended but not mandatory. If not used, the guarantee communication must still include sufficient detail to allow the Commission to assess eligibility.
• Please see the questions on article 12(6) for more details.

Just Switzerland and EEA countries – see explanation for article 12.6.

One of the requirements indicated in Section 6 “Eligibility” of the Call, is to have “minimum 3 independent applicants which are public administrations (beneficiaries; not affiliated entities) from 2 different eligible countries”.

No, application of article 12.6 of DEP Regulation excludes both:

• Legal entities established in a third country or DEP associated country, except: EEA countries (status equivalent to the Member States) and Switzerland
• Legal entities established in the EU territory but controlled by a third country or third country legal entities (including DEP associated countries)

Under this call, the full cost option applies. The annotated grant agreement spells this out on page 94 as follows:

“Purchases of equipment, infrastructure or other assets specifically for the action (or developed as part of the action tasks) may be declared as full capitalised costs if they fulfil the cost eligibility conditions applicable to their respective cost categories.

‘Capitalised costs’ means:

- costs incurred in the purchase or for the development of the equipment, infrastructure or other assets and

- which are recorded under a fixed asset account of the beneficiary in compliance with international accounting standards and the beneficiary’s usual cost accounting practices.

If such equipment, infrastructure or other assets are rented or leased, full costs for renting or leasing are eligible, if they do not exceed the depreciation costs of similar equipment, infrastructure or assets and do not include any financing fees.”

This means that the capital expenditure costs for already existing equipment cannot be claimed retroactively under this call.

Operational costs need to be described at wo what they would cover, e.g. maintenance costs, consumption etc, and would fall under the the corresponding category, such as personnel costs, purchase of a service etc. Those costs could be eligible provided that they fulfil all the conditions of that category and are in line with all the standard rules for eligiblity

The 50% co-funding and the at least 50% costs dedicated procurement requirements are at project-level.

The 50% co-funding requirement is implemented as follows: the project proposes a cost estimate based on every beneficiary’s activity in line with the description of action. The DEP will then fund 50% of this overall cost estimate and the project will have to find the remaining 50%. For example, the co-funding commitment letters could be at national or beneficiary level with an overview table showing how 50% of the co-funding is met through the different sources secured by the consortium. Commitment letters for national co-funding for instance can be done at national or beneficiary level.

The budget table would show how at project level, at least 50% of the project costs are dedicated to the procurement.

As per Article 6.2.E of the Model Grant Agreement, indirect costs are reimbursed as a flat-rate of 7% of the total eligible direct costs: “Indirect costs will be reimbursed at the flat-rate of 7% of the eligible direct costs (categories A-D, except volunteers costs and exempted specific cost categories, if any).”

For this call, equipment costs should be declared indeed as full costs, not depreciated costs.

According to the annotated grant agreement, “‘Capitalised costs’ means:

- costs incurred in the purchase or for the development of the equipment, infrastructure or other assets and

- which are recorded under a fixed asset account of the beneficiary in compliance with international accounting standards and the beneficiary’s usual cost accounting practices.”

Please review the relevant annotated grant agreement section on C.2 equipment costs on pg 94 to understand the difference between full costs and depreciation only: aga_en.pdfPDF

The consortium must co-finance 50% of the total project cost, which in your example would amount to €5 million.

The remaining €5 million would be covered by the European Commission grant.

In a €10 million project, at least €5 million must be allocated to procurement costs. This means that the EU will support up to €2.5 million of the procurement-related expenses, and the consortium must plan for an additional €2.5 million in co-financing for those procurement activities.

In principle, yes. However, it is important to note that this is a grant specifically supporting procurement. Therefore, at least 50% of the overall project budget must be dedicated to procurement activities. Beneficiaries are free to decide how to cover their co-financing share, but they have to make a differentiation between costs and resources.

The principal objective of the call is to procure and deploy GenAI solutions and integrate them into the existing workflows and IT systems of public administrations. Costs related to supporting infrastructure can be eligible only as additional costs necessary for the deployment and functioning of the procured GenAI solutions as well as proportionate and clearly linked to the action. These costs shall be justified in the proposal. The purchase of computing clusters is not the primary focus of the procurement.

Please, note that answer at this stage represents a guidance and not a formal validation of costs

First, we would like to recall the general eligibility conditions for costs :

The costs must comply with the eligibility conditions set out in Article 6.2.C.2,

in particular:

− for full purchase costs:

− fulfil the general conditions for actual costs to be eligible (i.e. incurred during the action duration, necessary, linked to the action, recorded in the beneficiary’s accounts, etc; see Article 6.1(a))

and

− have been purchased in accordance with Article 6.2.C

• for full development costs:

− depending on the nature of the cost items included in the development cost, fulfil the general and specific cost eligibility conditions that would apply to the individual cost item (for example, have been purchased in accordance with Article 6.2.C or fulfil the specific conditions for personnel costs to be eligible Article 6.2.A).

The cost must be recorded as capitalised costs in the accounting system of the beneficiary. Capitalised costs’ means: - costs incurred in the purchase or for the development of the equipment, infrastructure or other assets and - which are recorded under a fixed asset account of the beneficiary in compliance with international accounting standards and the beneficiary’s usual cost accounting practices

We would like to draw in particular your attention to the fact that the expenses must be necessary and linked to the activities of the action and offer best value for money.

The eligibility of the expenses will be assessed at the moment of the reporting period and will be assessed on a case-by-case basis in line with the grant agreement..

Depending on the characteristics of the action, it may also happen that some costs could be considered either direct or indirect costs but, in such cases care should be taken to define and distinguish what costs are considered direct or indirect, at all events costs cannot be taken into account twice.

If it is reasonable to expect that beneficiaries will need to rent or adjust premises in addition to their usual needs and specifically for the purpose of carrying out the action, these extra rental or upgrading costs should be 'real' and as far as possible be foreseen in the estimated budget. In such cases, while framing the conditions to avoid double financing, it is up to the Authorising Officer to foresee and approve those costs if justified as outlined above.

In short, should the rental or upgrading costs be additional, necessary, proportionate and specific to the action, they could be included as costs for the beneficiary.

In principle, yes. However, it is important to note that this is a grant specifically supporting procurement. Therefore, at least 50% of the overall project budget must be dedicated to procurement activities. Beneficiaries are free to decide how to cover their co-financing share, but they have to make a differentiation between costs and resources.

The European Commission intends to fund up to four distinct pilot projects, each led by a separate consortium. Each of these consortia would receive indicative funding in the range of EUR 5–7 million. Therefore, the total number of funded consortia will be a maximum of four, with each consortium implementing one pilot project.

No, co-financing must not come from other EU-funded grants under the DIGITAL programme. In particular, EDIHs have distinct activities.

Taking this example, in a 10 million project (50% EU contribution, i.e. 5 million), at least 5 million should be allocated to procurement costs. We will support the procurement (as any other costs) with 50%, i.e. 2.5 million EUR). This means the consortium has to plan co-financing of 2.5 million EUR for the procurement.

Yes. In this case prior coordination is necessary. Please contact A1 in CNECT (CNECT-AI-IN-PUBLIC-ADMINISTRATION@ec.europa.eu) and the relevant national authority so that the EU and national authority can coordinate the terms of the respective grants.

Yes this is possible. There is no restriction regarding the source of co-funding, just a request for a commitment.

The salary of an employee on the permanent employee payroll, but allocated to the project to provide services can be reimbursed 50% by DIGITAL funding. The co-financing in this sense falls under own resources.

In case you have in kind contribution from third parties for free, those are allowed but are cost-neutral, i.e. they cannot be declared as costs. They should be described in the relevant section of the application form and budget table (e.g. section 4.2 work packages and activities).

If you have seconded personnel which is against a payment to the third party (similar case as in H2020 under “in kind contributions against payment”), this costs can be covered by Article 6.2.A.3 seconded persons.

Independent from the activities financed, the key rule for a grant for procurement indicates that the majority of the costs consist of buying goods or services and/or subcontracting tasks (see cost categories in the budget table), i.e. more than 50% the envisaged costs should be used for procurement.

All eligible costs of the project will be funded 50% by the EU through the DIGITAL grant for procurement, and 50% from the indicated source by the consortia. Please also review the section 10 on legal and financial set-up of the grant agreements from the call document (Call document for the call "AI Continent"), notably full costs for equipment costs.

Please also note the restrictions for the protection of European digital infrastructures, communication and information systems, and related supply chains (see Appendix 4 of the Digital Europe Work Programme 2025-2027).

The budget given is indicative. A smaller, but solid project, can still be selected if sufficiently impactful and convincing.

If consortia are unable to find the suggested levels of co-funding, consortia can also propose smaller overall budgets to match the co-funding levels which they are able to achieve. This of course means a lower overall project budget as the EU-funding is at 50% co-funding rate under DEP.

Moreover, the minimum number of partners and Member States involved is precisely a minimum requirement, which means that more partners from other Member States can join the consortium, hence each beneficiary would have a smaller share. However, the geographical spread should be not considered from a purely budgetary perspective, but from how impactful it would be to have more partners and countries involved in the consortium. Also the larger the consortium the more challenging the management would be – a good balance should be maintained.

In addition, salary costs for staff already employed by the beneficiary can be considered as a cost for the project, provided they will actually work on the project, but keep in mind that the majority of the budget should be dedicated to the procurement.

Furthermore, the budget does not be dispensed at the beginning of the project duration, but can spread over the duration of the grant (36-48 months).

Importantly, the Commission encourages using funding from existing or upcoming national/regional/local policies and initiatives to which an EU dimension can be added thanks to the funding at a 50% co-funding rate from the Digital Europe Programme.

The other 50% - not financed by DEP - can be financed by own resources or financial contributions from third parties, e.g. public authorities / private entities.

It is possible to combine national and EU synergy grants/regional funds to make up the remaining 50% of eligible costs. For example, 25% could come from a regional and national funding source.

Note that since this is a grant for procurement, more than 50% of the costs has to be allocated to the planned procurement, there is a ceiling to how much can be financed by own resources, for example in the form personnel costs.

Dialogue/cooperation with them is key. Final GenAI solutions providers are not expected to be indicated in the proposals, however, to build a realistic budget preliminary discussions with potential providers/ AI integrators are encouraged. This means for instance, dialogue with potential providers and open consultations, market research and costs based on similar past projects. This is also why solution providers were invited to info-days: to help future applicants understand what’s possible and budget accordingly.

The key rule for a grant for procurement indicates that the majority of the costs consist of buying goods or services and/or subcontracting tasks (see cost categories in the budget table). The remaining budget can be distributed flexibly within other cost category such as personnel costs or travel. Beneficiaries are free to decide how to cover their co-financing share, but they have to make a differentiation between costs and resources.

For this call, 21 million euro is provided by DEP at a 50% co-funding rate. This means the remaining 50% will have to come from other sources, bringing the total budget of the call to 42 million euros. DEP will finance provide up to 5-7 million euros per project, making the total possible project budget up go up to 10 to 14 million euros.

The call has a specific focus on generative AI for public administrations and the following functional areas:

• supporting decision making;
• optimising internal processes and operations;
• tailoring interactions with citizens via advanced platforms; and/or
• making legislation more machine-readable (‘law as code’) and complicated procedures and text more understandable to citizens and businesses.

However, as long as a proposal contains these elements as a major area of its focus, the specific AI fields and techniques can go beyond generative AI if they cover the functional areas mentioned in the call text. This would include for example, agentic AI methods for decision-making support or optimizing internal processes of public administrations that are based on generative AI.

The call text requires the proposals to address at least one of the outline key functional areas: 1) supporting data-driven decision making, 2) optimizing internal processes and operations, 3) enhancing interactions with citizens, 4) simplifying legal and administrative procedures. Within those functional areas, there’s flexibility as to the thematical topics chosen. Thematical topics, if mentioned within the functional areas by the call text, are only indicative. An environmental focus of a proposal – if it falls within at least one of the 4 key functional areas – would therefore be within the scope of the call text for this specific aspect.

The answer is "no" to both questions, selection will be based on the award criteria and on the credibility and impact of the proposal

The solution will be procured only once the action has started for the costs to be eligible under the grant for procurement. It is up to the consortia to decide on how much level of detail it wants to provide in the proposal. As a good practice, to show the maturity of the proposal, it would be advisable to provide sufficient concrete information about the selected use-case and what kind of improvement and benefits are expected from the procured solutions.

Proposals should be able to adequately describe within the given page limits their project. It is up to the consortia to decide how detailed specific sections of the proposal should be. Any information given that goes beyond the page limit will not be taken into account. The page limit for this call is 70 pages for Part B. See section 5 “admissibility and documents” in the call document: Call document for the call "AI Continent".

• In each consortium/pilot project, public administrations shall come from minimum 2 Member States/eligible countries due to the requirement to replicate a pilot project in another Member State.
• The multi-level aspect is not mandatory, even if welcomed.

The type of action for this call is a “Grant for procurement”, which means that selected consortia are required to use the funding to procure the GenAI solutions. The call text reads “public administrations within these consortia will be responsible for procuring the fine-tuning of proposed foundation models, developing tailored solutions based on these models, and integrating them into their existing platforms, systems, and operational workflows. The procurement could moreover cover supporting infrastructure and implementation activities such as:

• The technical infrastructure required to deploy and run GenAI solutions at scale and across single or multiple public administrations;
• The support needed by public administrations to ensure they have the necessary skills and knowledge to effectively implement and manage the deployed GenAI solutions; and
• The maintenance and optimisation costs for the deployed GenAI solutions.”

Finetuning foundation models and developing a GenAI solutions exclusively inhouse would therefore be outside of the scope of this call. These activities will have to be covered to a certain extent in the procurement. Moreover, at least 50% of the project budget needs to be dedicated to the procurement.

How performant the AI model underpinning the GenAI solution is not a central consideration of this call, but rather how well it is integrated into the public administrations and leads to an improvement to the targeted functional areas as well as how well the proposal achieves replicability and scalability.

However, the call text does prioritise the AI model to be European, i.e. to be “developed by European AI companies/laboratories”. Please see other questions what this means in greater detail.

In general, every proposal submitted under DEP will be evaluated by the following three criteria: 1. Relevance, 2. Implementation, 3. Impact. Please check Annex 1 of the DEP Work Programme 2025-27 for more details.

There are two replication requirements in the call text: a narrow and a broad one.

The call contains among others the following KPI: “Number of public administrations successfully replicating solutions”. This means that already during the project, piloted European GenAI solution will need to be replicated, i.e. deployed by another public administration. For example, the project could procure a solution that is first piloted in one public administration and then replicated in another. There is no mention of a cross-border dimension in the KPI, so the requirement to replicate in a strict sense is not expected in a different Member State. However, it is also not discouraged since a cross-border dimension would achieve a higher impact.

The call text also requires the piloted European GenAI solutions to be “scalable and interoperable, enabling replication across different national and local contexts”. Connected to this, the call text also expects as one of the deliverables the following: “Blueprints, technical documentation, and best practices to support replication in different national and regional contexts”. This is not a strict replication requirement in terms of deploying the same GenAI solution in another public administration, but enabling others within and/or without the consortium to replicate the same or similar GenAI solution.

Every proposal will need to argue how it can achieve the most impact in meeting the narrow and broad replicability requirement on the basis of the specific use cases it’s proposing.

While proposals will need to demonstrate how they will meet the broad and narrow replicability requirement, a coordination and support action will later on support the projects in further replicating and scaling their piloted GenAI solutions.

There is no predefined limit for budget allocated to coordination or support activities. It is up to the applicants to justify in the proposal the budget distribution across these activities and ensures that at least 50% of the total project cost is dedicated to procurement, in line with the requirements of the call.

Yes, several public infodays were held to inform the community about the generative AI for public administration call under DEP. You can rewatch them under the following links:

• 14th April: youtube.com
• 22th May: 1st Digital Participatory Forum & GenAI for Public Administration Info Day | European Committee of the Regions
• 25th June: Living-in.EU Financial WG Info Session and Matchmaking: GenAI for Public Administrations Call

If other events will be organized, this will be communicated via the dedicated b2match website: Home | GenAI for Public Administration - Call for Proposals as well as the GenAI4EU website: GenAI4EU: Funding opportunities to boost Generative AI “made in Europe” | Shaping Europe’s digital future.

The call requires that solutions be “based on European models (i.e. models developed by European AI companies/laboratories)”. This means the foundation model should be developed by an entity established in an eligible country such as an EU Member State. Proposals must demonstrate how they contribute to European technological sovereignty. This includes ensuring that:

When it comes to restriction to the use of infrastructure and suppliers, applicants will need to comply with the restrictions set out in the call and Appendix 4 of the DEP Work Programme 2025/2027, particularly concerning the protection of European digital infrastructure and supply chains. These restrictions apply especially to strategic digital assets and aim to protect the integrity of European digital infrastructures and supply chains.

However, this does not translate into an obligation to use European infrastructure. This only applies to models as explained above.

How article 12.6 is implemented in general, please refer to the other FAQs on this issue.

Yes, the procurement would proceed via the respective government procurement portals.

• Selection of winning consortia: the Commission selects proposals submitted by consortia of public administrations and other eventual supporting applicants, through the standard evaluation process, which will take place by the end of the year.
• Grant Agreement preparation: the selected consortia negotiate a grant agreement with the Commission. This includes defining the procurement timeline.
• National procurement by public administrations: the public administrations in the consortium will then:
• Launch and manage procurement procedures at national level;
• Follow the applicable national public procurement rules, and if, the contract value exceeds EU thresholds, ensure compliance with the EU public procurement rules, including publication in TED.
• Implementation and reporting: the procured activities are implemented and monitored as part of the project, with regular reporting to the Commission as per the grant agreement.

The call’s expected outcomes and deliverables are notably the pilots of European GenAI solutions in public administrations and their replication across public administrations and Member States. Importantly, the project will be a grant for procurement where the “public administrations within these consortia will be responsible for procuring the fine-tuning of proposed foundation models, developing tailored solutions based on these models, and integrating them into their existing platforms, systems, and operational workflows. The procurement could moreover cover supporting infrastructure and implementation activities”. It is up to the proposals to show how they are able to achieve the expected outcomes with the grant for procurement.

How much detail given for different aspects in the proposal is a decision made by the applicants.

This may vary among single proposals as some cases require further fine-tuning on inference, while some may focus more on the use case (as the technical model is already more mature).

In addition, going too deep into detail with describing the technical model at proposal stage may cause “lock in” in terms of from whom the solution could be procured.

36/48 months

The grant for procurement is an action grant, meaning an EU grant to finance “an action intended to help achieve a Union policy objective” (art 183.2.a EU Financial Regulation 2024/20509), in this case as described in the call. It is not a loan or any other financial instrument which needs to be paid back.

However, the European Commission retains the right to reduce the budget or recover costs in case of non-compliance as set out in article 11 and chapter V of the grant agreement model.

The call expects the project to use existing generative AI models and finetune them for the use cases chosen for their pilot projects.

The consortia should include primarily public administrations, whether at national, regional or local level. However, the call specifies that the consortia “may include other entities, such as research and technology organizations (RTOs), universities, and system integrators”. AI software as a service provider can be procured, should the public administrations decide that it is necessary for “the fine-tuning of proposed foundation models, developing tailored solutions based on these models, and integrating them into their existing platforms, systems, and operational workflows” as mentioned in the call.

The model must be developed by an entity established in the EU, EEA or Switzerland (eligible countries under the call) as stated in the call: “European models (i.e. models developed by European AI companies/laboratories)”. The developing entity should be based, owned, and operated under European jurisdiction, even if it uses international partnerships. The overall goal is to ensure technological sovereignty, compliance with EU values and laws (e.g. AI Act, GDPR), and reduce dependence on non-EU tech providers.

Infrastructure is foreseen to run the solution. While "solutions" refers to the GenAI models and applications tailored for use cases (e.g. legal drafting assistant, chatbot for public services), "infrastructure" covers what is needed to support, scale, and sustain these solutions. This can include things like servers, cloud services, storage, and software tools that allow the AI to work properly and securely. However, the main focus of the call is not on building big new infrastructures, but rather on developing and piloting GenAI solutions that are useful for public administrations (e.g. chatbots, tools to simplify procedures, or help with decision-making).

This is for the consortium to decide and explain in the proposal.

• Article 12.6 is applied by the European Commission. This means that, according to the model grant agreement, whenever security conditions apply, the beneficiaries must ensure that any cooperation with entities established in countries which are not eligible countries or target countries set out in the call conditions (or are controlled by such countries or entities from such countries) does not affect the security interests or EU strategic autonomy and avoids potential negative effects over security of supply of inputs critical to the action. Also, the beneficiaries must ensure that none of the entities that participate as affiliated entities, associated partners, subcontractors or recipients of financial support to third parties are established in countries which are not eligible countries or target countries set out in the call conditions (or are controlled by such countries or entities from such countries).
• At national level, domestic procurement rules apply, however security concerns from EU and article 12.6 shall be taken into account. Member States should apply (if any) national rules that would restrict procurement for security reasons and so, in this way indirectly enforce article 12.6.
• The Commission, under the grants agreement, can only fund activities in line with the call text, including article 12.6 conditions.

Article 12(6) of the Digital Europe Programme Regulation is applied to DIGITAL-2025-AI-SUPPLY-08-Apply AI: GenAI for the public administrations, making it a restricted call.

• Appendix 3 of the Digital Europe Programme Work Programme 2025-27 sets out the procedure for implementing article 12(6).
• As a result, only legal entities that meet following conditions can apply: o are established or deemed to be established in an eligible country AND o are controlled by an eligible country, eligible country entity, or by national of eligible countries. Legal entities that are controlled by an ineligible country, ineligible country entity, or an ineligible country national may participate in actions under Article 12(6) only if they comply with specific conditions to guarantee the protection of essential security interests of the Union and the Member States.
• Please see Appendix 3 for the conditions of the guarantee for the legal entities established in an eligible country, but controlled from an ineligible country.
• Eligible countries are at the moment the EU, EEA and Switzerland.

No

Under the "grant for procurement" action, the acquisition of external experts to support public administrations in preparing or managing project activities does not fall under procurement expenses (i.e. the minimum 50% of the total budget allocated to the procurement of GenAI solutions). Such services are more appropriately reported as subcontracting. Alternatively, they could join the consortium as supporting applicants. In that case, however, they would be required to cover 50% co-funding of their eligible costs, like any other beneficiary.

All private organisations will have to undergo an ownership and control assessment.

If the agency REA – who does the ownership and control assessments for the Commission – categorises the organisation as a public organisation, it will not have to do an ownership and control assessment, regardless of its role in the consortium (beneficiary, affiliated entity etc).

Supporting applicants are not an additional category to the existing roles in a consortium (beneficiary, affiliated entity, associated partner, third parties giving in-kind contributions and subcontractor). Highlighting supporting applicants is a way to emphasise the centrality of public administrations who will be key organisations to procure GenAI and do the pilots. The roles outlined in the grant agreement still stand and it’s for the organisations themselves and the consortium to see how best they match the description according to their role and pick the best option outlined in the grant agreements. Universities are supporting applicants according to this call and can be anything from beneficiary to possibly even a subcontractor depending on their role.

It is up to the consortium partners to choose what kind of partner the in-house institution will be. The annotated grant agreement (aga_en.pdfPDF) sets out the respective responsibilities and rules from pp 11 – 16 with a summary table on pg 16.