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Horizon Europe Article 7: Gender Equality Plan (GEP)

Article 7 of the Horizon Europe framework regulation (Regulation (EU) 2021/695) makes gender equality a cross-cutting priority of the programme and is the legal basis for the Gender Equality Plan (GEP) eligibility criterion: for Horizon Europe calls with submission deadlines from 2022 onward, public bodies, higher education establishments, and research organisations established in an EU Member State or an Associated Country must have a GEP (or an equivalent gender equality strategy) in place to be eligible to receive funding. It is a legal entity-level eligibility check, not a proposal-evaluation criterion -- an applicant either has a qualifying GEP on file or it does not, and non-compliant public-body, HEI, or research-organisation applicants are ineligible for that call regardless of the scientific merit of their proposal. Private, for-profit entities (companies, including SMEs) are exempt from the requirement.

ByCASRAI Editorial Board
· Last updated 18 Jul 2026

Examples

Worked examples

  • Is an instance

    A public university applying as coordinator or beneficiary on a Horizon Europe Research and Innovation Action confirms, via its Legal Entity Appointed Representative (LEAR) in the Funding & Tenders Portal, that it has a GEP meeting the four mandatory process-related requirements: the plan is a formal document published on the institution's website; it is signed off and actively communicated by senior management; it commits dedicated resources and expertise to implementation; and it includes sex-disaggregated data collection with monitoring against targets. This self-declaration, made once per Framework Programme (unless the entity's status changes), is what satisfies Article 7 for every subsequent Horizon Europe application from that entity.

  • Is an instance

    A national research funding agency (a public body) applying as a partner on a coordination-and-support action likewise confirms it holds a qualifying GEP or an equivalent strategy -- the requirement reaches funding bodies and ministries, not only universities and research performers.

Counter-examples

Looks similar, but isn't

  • Not an instance

    A privately held SME applying to a Horizon Europe innovation call is exempt from the Article 7 GEP requirement entirely -- the criterion applies only to public bodies, higher education establishments, and research organisations, not to companies. The SME's eligibility is unaffected by whether it has a gender equality plan.

  • Not an instance

    An institution that has a general diversity-and-inclusion statement, but nothing that is a standalone, published, management-endorsed document with dedicated resourcing and sex-disaggregated monitoring, does not satisfy Article 7 as written -- the Commission's criterion specifies four mandatory process-related building blocks, and a broader but less formal EDI commitment does not automatically substitute for them.

Editorial commentary

Article 7 of the Horizon Europe framework regulation, Regulation (EU) 2021/695, establishes gender equality as a cross-cutting priority of the programme. Its practical, funding-eligibility consequence is the Gender Equality Plan (GEP) eligibility criterion: since calls with submission deadlines in 2022 onward, public bodies, higher education establishments, and research organisations from EU Member States and Horizon Europe Associated Countries must have a GEP, or an equivalent gender equality strategy, in place in order to be eligible to apply. This entry covers the eligibility requirement itself, distinct from CASRAI’s existing entries on institutional gender-equality accreditation schemes such as Athena SWAN.

Who the requirement applies to

The criterion reaches three categories of legal entity established in an EU Member State or Associated Country: public bodies (including research funding agencies and ministries), higher education establishments (public and private), and research organisations (public and private). Companies, including SMEs and other private for-profit entities, are exempt. The check is made once per applicant legal entity for the life of the Framework Programme — an institution’s Legal Entity Appointed Representative (LEAR) confirms GEP status in the EU Funding & Tenders Portal, and that confirmation then applies across that entity’s subsequent Horizon Europe applications unless its legal status changes.

The four mandatory process-related requirements

The European Commission’s guidance sets out four mandatory building blocks a qualifying GEP must satisfy:

  • Public document. The GEP is a formal, standalone document published on the organisation’s website.
  • Management endorsement and communication. It is signed off by senior/top management and actively communicated within the organisation.
  • Dedicated resources. The organisation commits specific resources and gender-equality expertise to implementing it.
  • Data collection and monitoring. The plan is supported by sex-disaggregated data on personnel and students, with monitoring and annual progress reporting against defined indicators.

Alongside the four mandatory elements, the Commission also lists five recommended (not mandatory) thematic areas a GEP is encouraged to address: 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; and measures against gender-based violence, including sexual harassment.

What Article 7 does not require

It is a binary eligibility gate, not a scored evaluation criterion — proposals are not ranked or awarded points on the quality of an applicant’s GEP, and Article 7 does not itself mandate specific gender-balance quotas in project teams or evaluation panels (those are addressed elsewhere in Horizon Europe’s broader gender-equality strategy). A general diversity statement, an equal-opportunities policy embedded in an HR handbook, or an unpublished internal commitment does not, on its own, satisfy the criterion — the Commission’s guidance is specific about the document being a standalone, published, endorsed, resourced, and monitored plan.

Distinct from institutional equality charter marks

Article 7’s GEP criterion is sometimes conflated with the UK-originated equality charter marks that many of the same institutions also hold, but the two are legally and structurally distinct. Athena SWAN is a voluntary, awards-based accreditation scheme (Bronze/Silver/Gold) run by Advance HE, historically tied by some UK funders to specific award eligibility for certain funding streams. The Race Equality Charter (REC), also run by Advance HE, applies the same self-assessment model to race equality rather than gender. Neither Athena SWAN nor REC accreditation automatically satisfies Article 7, and a Horizon Europe GEP does not automatically satisfy Athena SWAN’s award criteria — an institution operating across both UK funding and Horizon Europe funding may need to maintain both a Horizon Europe-compliant GEP and, separately, whichever charter marks its UK funders or REF submissions expect. The Commission’s own GEP guidance acknowledges that an existing Athena SWAN action plan can often be adapted to help meet the four mandatory Horizon Europe building blocks, but the two remain formally separate obligations with separate governing bodies (European Commission vs. Advance HE) and separate compliance checks.

Related terms

Machine-readable encodings

Use in your systems

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