Gender Equality Plan: the Horizon Europe eligibility rule

A Ukrainian team clears the Horizon Europe evaluation, scores above threshold and lands on the funding list. Then the project office opens a message from grant preparation: please confirm that your institution has a Gender Equality Plan. Nobody wrote one, so the signature of the grant agreement stops there.

The Gender Equality Plan, or GEP, has been an eligibility criterion in Horizon Europe since 2022. It covers public bodies, research organisations and higher education establishments from EU Member States and Associated Countries. Because Ukraine joined that list in 2022, the rule applies to Ukrainian institutions in full.

So this guide walks through what the Commission asks for in the 2026-2027 work programme, when officials actually check, which organisations the rule skips, and where Ukrainian institutions slip up most often.

What the Commission asks for and when officials check

The rule sits in section B (Eligibility) of the General Annexes to the Horizon Europe work programme 2026-2027, adopted by Commission Decision C(2025) 8493 of 11 December 2025. The subsection carries the title Gender equality plans and gender mainstreaming and runs across pages 18 and 19.

So the wording leaves little room. Legal entities from Member States and Associated Countries that are public bodies, research organisations or higher education establishments, including private ones, must hold a Gender Equality Plan at the moment of grant signature and throughout the duration of the grant. The rule reaches both beneficiaries and affiliated entities.

The moment of the check

Here is where most people get it wrong. A missing GEP does not block submission, and it does not affect the score. Evaluators will read the proposal and grade it against the three award criteria as usual. The document matters later, during grant preparation, and without it nobody signs the agreement. The National Research Foundation of Ukraine reminded Ukrainian applicants of exactly this point when it relayed the Commission guidance.

In practice an institution has roughly 5 to 8 months between the call deadline and signature, so in theory it can adopt a GEP within that window. However, internal approval inside a university eats more time than anyone expects, and a stalled grant preparation damages the relationship with the consortium coordinator.

Who signs the declaration

Confirmation does not go into the proposal text. Instead, the institution fills in a self-declaration in the Participant Register on the Funding and Tenders Portal, and the Legal Entity Appointed Representative (LEAR) does it. The declaration covers the whole framework programme, so the institution files it once. Therefore one correct procedure settles the question for every future call it enters.

Four mandatory requirements

The General Annexes list the minimum process-related requirements. There are exactly four of them, and an institution has to meet all four, because partial compliance counts for nothing.

1. A public document

The GEP must be a formal document published on the institution website and signed or adopted by top management. Two words carry the weight here: published and signed. An internal order sitting in the registry office fails the test. So the page needs to load without a login, and ideally it carries an English version too, since a Commission officer or an auditor may open it.

2. Dedicated resources

The institution commits resources and expertise in gender equality to implement the plan. In practice that means named people and a named budget: a responsible officer or working group appointed by order, plus a spending line or at least ring-fenced working time. A sentence promising that the university will make every effort does nothing here.

3. Data collection and monitoring

The plan needs sex and gender disaggregated data on personnel, and for education establishments on students as well. Reporting runs at least every two years and rests on indicators. So the plan itself has to carry those indicators: share of women among academic staff, among heads of departments, among academic council members, the pay gap, and the spread across career stages.

4. Training

Awareness raising or training for staff and decision-makers on gender equality. The Commission names one example directly: unconscious gender bias. One webinar a year with a recorded attendance list covers this better than a statement of intent inside the plan.

If another strategic document already covers all four requirements, for example a development plan or an inclusion and diversity strategy, the Commission accepts it as equivalent. Several separate documents endorsed by top management also count together.

Who the criterion covers and who it skips

On this point the Commission gives an exhaustive list, which is a rare case where nobody has to guess.

• Covered: public bodies, research organisations, higher education establishments. Private research organisations and private higher education establishments fall in as well.
• Not covered: private for-profit companies including SMEs, non-governmental and civil society organisations.
• Roles: the criterion reaches beneficiaries and affiliated entities. Associated partners, who receive no funding and sign nothing, stay outside it.

The Ukrainian setting produces a common trap. Institutes of the National Academy of Sciences, sectoral research institutions, regional authorities and municipal healthcare facilities joining clinical projects all match the definition of a research organisation or a public body. An NGO inside the same consortium needs no GEP at all.

Separate parts of the programme

The General Annexes do not cover calls run by the European Research Council (ERC), the European Innovation Council (EIC), the EIT, partnerships under Articles 185 and 187, Euratom or the Joint Research Centre. Those have their own work programmes, although the GEP requirement lives there too, just in a different place. For ERC 2026 calls Annex 5 of the ERC work programme sets it out: at submission the host institution ticks yes or no, that answer carries no weight in the evaluation, and the plan becomes necessary once a proposal is selected for funding.

Five recommended areas and three requirements people confuse

Beyond the four mandatory blocks, the Commission recommends filling the plan with concrete measures and targets across five areas:

• work-life balance and organisational culture;
• gender balance in leadership and decision-making;
• gender equality in recruitment and career progression;
• integration of the gender dimension into research and teaching content;
• measures against gender-based violence, including sexual harassment.

Formally these are recommendations, while in practice they set the yardstick for plan quality once an audit opens, or when a consortium coordinator screens partners before submission.

Three requirements that blur together

Gender enters a Horizon Europe proposal from three directions, and each one carries different weight.

• The GEP is an eligibility criterion at institution level. It decides whether the agreement can be signed.
• The gender dimension in research content belongs to the Excellence award criterion for RIA, IA and CoFund actions. It decides points.
• Gender balance among researchers in leading roles is the third prioritisation factor for proposals sitting on the same total score. It decides ranking when everything else ties.

So an institution can hold a flawless GEP and still score poorly on Excellence, because the methodology never explained how sex and gender shape the research subject. These are separate obligations, and each one needs separate work.

Where Ukrainian institutions slip and how to build the plan

Ukrainian universities first started adopting GEPs around 2023. The Ministry of Education and Science also ran a dedicated webinar with the Estonian agency HARNO under the UKRKORG project. So the experience exists, and with it a familiar set of failures.

The plan exists but nobody can find it

So this is the most frequent case. An academic council adopted the document, and the file now sits in a news post from two years ago or inside an archive of orders. The requirement speaks about publication on the institution website. Fixing it takes an hour: a dedicated page under international cooperation or quality assurance, a permanent link, and a PDF in Ukrainian and English.

No disaggregated data

The plan describes intentions and carries no figures about current staff composition. Without baseline data an institution cannot show movement two years later, and reporting every two years is exactly what the requirement asks for. Therefore the first step is a simple table: distribution by sex across job categories and governing bodies on a stated date.

No reporting mechanism

A plan covers 2024 to 2027 and not a single interim report has appeared. So formally that breaks the requirement. A short report of 3 or 4 pages every two years, posted next to the plan itself, settles it.

The GEP was copied from another website

A copy of another university plan with the name swapped collapses at the first check, since the indicators do not match the real structure and the responsible units simply do not exist there. Looking at what colleagues published helps. So the data and the named owners have to be your own.

Where to start

A sequence that works: collect staff data by sex, draft the plan with indicators and named owners, adopt it by academic council or rector order, publish it under a permanent link, run the first training session and record who attended, then ask the LEAR to update the self-declaration in the Participant Register. For detailed explanations of each requirement with examples, use the official Commission guidance, and for step-by-step tools see the GEAR toolkit from EIGE.

After signature the gender obligations move into delivery. Article 14 of the grant agreement asks beneficiaries to promote equal opportunities while running the action and to reach gender balance across all levels of personnel, including supervisory and managerial roles. That is project administration territory, where consortia usually bring in a separate tool such as KanriFlow.