Can I charge the cost of freelance work on Horizon Europe projects?

Collaboration with freelancers is increasingly popular in many companies, especially if you need to acquire very specific skills. So at the start of your Horizon Europe project you may wonder whether these costs are eligible or not.

First, some background

In previous Framework Programme, Horizon 2020, the figure of “natural person with a direct contract” was already implemented into the Grant Agreement. Nevertheless, if you executed an H2020 project and you are familiar with the rules related to freelancers, you should be careful. Horizon Europe has implemented some small changes which could make a big difference to your project.

General idea

As in the previous programme, the freelance work performed by natural persons (not companies) contracted directly by the beneficiary in a non-employment regime is an eligible personnel cost. This scheme remains unchanged in Horizon Europe compared to H2020.

Main difference

The main difference in terms of budgeting is that contracting a person through his or her own company is now also possible. The only conditions are that a freelancer fully owns the legal entity that he works for and there is no other staff hired by this company. In short, it must be a one-person company.


To correctly claim freelance work as personnel cost, the following rules apply:

  • The work performed must meet general conditions for eligible costs e.g., be incurred/used during action duration, necessary or linked to the action, etc.
  • There must be a direct contract between the natural person and the beneficiary.
  • The person must work under the beneficiary’s instructions.
  • The result(s) of the work must belong to the beneficiary.
  • The cost must not be significantly different from that of personnel performing similar tasks under an employment contract with the beneficiary.
  • The person must work under similar conditions to an employee.

So don’t forget to check twice if your freelance collaborators fulfil these rules before charging their costs to the project as personnel costs. Otherwise, they could very well be rejected later in case of an audit.

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