1. If there are two micro enterprise partners how is their annual turnover taken into account when determining total eligible cost of the application.
Just the applicant turnover or sum or applicant and partner turnover?
Is partner without 1 FTE in previous year acceptable partner? New employees would be employed if the grant is won.
The eligibility of each applicant and partner is assessed separately, in accordance with the eligibility requirements set out in the Call documentation. The eligibility conditions are not applied cumulatively across the consortium unless explicitly stated otherwise in the Call.
Accordingly, the eligibility of the applicant and each partner should be assessed individually against the relevant requirements applicable to their respective role in the project.
However, please note that the Ministry cannot provide an interpretation or assessment of the eligibility of a specific applicant, partner, or project proposal without reviewing the complete project documentation. Eligibility can only be determined during the formal evaluation process based on all information and evidence submitted with the project proposal.
Condition regarded employment of at least one person (1 FTE) based on recorded working hours, as reflected in the annual financial statement of the enterprise (or another equivalent document) is applicable to both applicant and partner.
2. Regarding the Technology Readiness Level (TRL), what range is applicable under the referenced call, specifically from which TRL level to which TRL level projects are expected to be developed and supported?
The eligible activities under the Call, as defined in the Guidelines for Applicants, refer to experimental development activities to further refine and adapt the proposed innovation, including prototypes, service delivery models, methodologies, applications, or platforms, contributing to development of innovative digital and green technologies, products, and processes.
Applicants must in their project proposal also include mandatory indicators, one of which is Number of innovative solutions developed which measures the number of innovative solutions in the pre-commercial phase, developed by the supported entities involved in the project implementation. The solution is considered developed when it is sufficiently advanced to be considered for implementation or deployment in a target market or operational environment. This must be demonstrated during project implementation through the development and testing of a functional prototype, the piloting of a service or process, or equivalent validation of the solution in a real-life or simulated setting.
3. We kindly request clarification regarding the calculation of personnel costs under the unit‑cost methodology described in Section 10 of the Call SPARK, specifically for research organisations that do not submit a standard GFI form.
Faculties and public research organisations report their annual financial data through the PR‑RAS form. In this form, staff‑related expenditure is presented under:
• 31 – Staff costs (311 + 312 + 313),
which includes:
– 311: Gross salaries,
– 312: Other staff‑related expenditures,
– 313: Employer contributions.
Could you please confirm whether, for the purpose of calculating the “Total staff costs of the organisation in the last closed full financial year”, applicants should use the full amount reported under item 31 (Rashodi za zaposlene) in the PR‑RAS form?
Additionally, we kindly ask you to confirm that this amount should be treated as the total employer cost (gross II + employer contributions + allowances), in line with the definition provided in the Call.
Total staff costs includes gross salary level 2, which encompasses the total employee costs for the organization, including all contributions and taxes that the employer must cover to ensure the net amount is paid to the employee, including transport allowances and non-taxable costs, increased by 20% to account for projected staff expenditure growth in the coming years.
The calculation of the daily rate is subject to cost eligibility verification and budget cleaning, during which applicants will be requested to provide supporting documentation used as the basis for the calculation as defined in Table 6.of Gfa: Documentation related to salary calculation – Acceptable documents that can be submitted are: Annual financial statement, or equivalent report of the applicant for the last approved accounting period, with clear indication of the salary expenditure amounts used for the calculation of the daily rate.
4. We kindly request clarification regarding the scoring methodology used in the quality assessment, Annex 1 of the Call SPARK, specifically the notation “5 × 2” applied to several sub‑criteria in Table 4.
Sub‑criteria 1.3, 2.1, 3.1 and 4.1 are each described as having a maximum score of 5 × 2 = 10 points.
We would appreciate clarification on the following points:
a) What exactly does the notation “5 × 2” represent?
Does it mean that evaluators award a score from 0 to 5, which is then multiplied by 2 as a weighting factor to reach the final score for that sub‑criterion?
b) Does the multiplication factor apply only to the sub‑criterion itself, or is it linked in any way to the number of partners, the number of enterprises in the consortium, or the applicant/partner structure?
Yes, it means that for each sub-criteria evaluators use scores from 0 to 5 with possibility of using half scores like 0.5, 1.5, etc. For selected criteria these scores are multiplied by two to reach the final score for that sub-criteria.
Multiplication factor applies to that sub-criterion which has its own description. The score for each sub-criterion reflects how the project proposal fits to the description of the criteria and the generic description of each score range (0, 0.5 – 1.0 – Poor, 1.5 – 2.0 – Fair, 2.5 – 3.0 – Good, 3.5 – 4.0 – Very Good., 4.5 – 5.0 – Excellent).
5. The Call SPARK, chapter 6 states that each applicant may submit one (1) project proposal, and that each enterprise or research organisation may participate as a partner in up to three (3) project proposals.
Could you please confirm whether this limitation applies strictly to each individual legal entity, or whether it is applied at the level of a group of linked enterprises?
Specifically, is it acceptable for two linked enterprises (within the meaning of the SME definition and ownership/control criteria) to each submit one project proposal as separate applicants, resulting in two proposals in total?
The limitation set out in Chapter 6 of the Call applies at the level of each individual legal entity (identified by its own registration and tax identification number). Accordingly, two linked enterprises may each submit one project proposal as separate applicants, provided that each entity independently meets all eligibility requirements set out in the Call documentation.
In addition, enterprises belonging to the same group as the applicant may participate in the project as partners (i.e. group partners). However, such cooperation is not considered effective collaboration, therefore, the applicant cannot benefit from an increased aid intensity.
6. The Call provides funding for the experimental development of highly innovative solutions. Upon reviewing the application form, we do not find any requirement to describe the current technology readiness level (TRL), nor any results of prior research (laboratory environment) on which this application would logically build. Could you please clarify whether such an explanation is expected, and if so, where in the application it should be provided?
We also note that it does not appear possible to attach any supporting documents beyond those prescribed by the Call (e.g. letters of interest and similar). Will this change?
There are 3 criteria where information related to current stage and prior results are used in different context for evaluation purpose. These are:
- subcriteria 1.1. Clarity and ambition of objectives where among others the evaluation considers whether the objectives are appropriately aligned with the current stage of development of the solution (e.g. prototype, pilot, validation phase)
- subcriteria 3.1. Feasibility of implementation plan including project and risk management where the evaluation considers the extent to which the proposed activities are logically sequenced and aligned with the project’s development stage and build logically on prior work
- subcriteria 3.2. Resources and budget were the evaluation the expertise, experience, and capacity of the applicant team, as well as access to necessary infrastructure, equipment, and technical know-how.
Additionally relevance of proposed activities to expected TRLs covered under experimental development is evaluated in:
- subcriteria 1.2. Soundness of methodology and development approach were sub-criterion evaluates the appropriateness, coherence, and robustness of the proposed approach for experimental development. It considers whether the proposal clearly defines the development pathway, including design, prototyping, testing, validation, and iteration processes
Explanations to these topics should be covered in parts of application form that follow relevant criteria. Attachment of other documents not prescribed within the call is not envisaged. Any proofs that applicant considers relevant can be cited were considered appropriate.
7. We kindly request clarification regarding the eligibility and funding intensity of personnel costs for partners classified as research and knowledge dissemination organisations, in accordance with the Communication from the Commission – Framework for State Aid for Research and Development and Innovation (2022/C 414/01), Chapter 1.3, point 16 (ff).
As indicated in the call documentation, grants awarded to such organisations do not constitute State aid, and therefore funding intensity for eligible project costs may reach up to 100%, provided that activities are of a non-economic nature.
Based on this, our understanding is that personnel costs of research organisations — including both existing staff (employed prior to the project) and newly hired staff — are eligible for funding up to 100%, provided that:
– activities are non-economic in nature,
– the organisation meets the definition under point 16 (ff), and
– no selective economic advantage is granted.
We kindly ask you to confirm whether this interpretation is correct, and in particular whether existing staff are equally eligible for up to 100% co-financing, without a differentiated or reduced funding intensity (e.g. 0%) compared to newly hired personnel.
As stated in Call documentation, grants awarded to partners that meet the definition of a research organization as defined in the Communication from the Commission – Framework for State Aid for Research and Development and Innovation (2022/C 414/01), Chapter 1.3, point 16. (ff), are not considered state aid. In such circumstances, the grant intensity for eligible project costs may reach up to 100%. As stated in GfA, eligible costs are personnel cost: researchers, technicians and other supporting staff to the extent employed on the project (salaries for new recruitment and engagement of xisting staff). The calculation of personnel costs must comply with the methodology specified in Section 10 of this document). Applicants and beneficiaries must ensure that there is no double funding of the costs. Applicants must ensure that the project does not result in double financing and that the same eligible costs are not financed from multiple sources of public funding.
8. According to the Guidelines, research organisations may receive funding of up to 100% for non-economic activities, while the overall project aid intensity is limited to 60%.
In addition, the budget template allows ONLY a single aid intensity per partner, which limits the possibility of differentiating intensities across cost categories (e.g. newly employed and existing staff of RO).
In this context, we kindly ask for confirmation whether it is acceptable to apply:
A) a single uniform aid intensity for all cost categories within the same partner (60%), for example:
60% for personnel costs (existing staff),
60% for personnel costs (newly employed staff),
60% for other eligible costs (e.g. equipment),
or
B) different funding intensities across cost categories within the same partner, for example:
-0% for personnel costs (existing staff), and
-up to 100% for other eligible costs (e.g. newly employed personnel and equipment),
while ensuring that the total project funding does not exceed the 60% overall aid intensity limit, and that a single resulting intensity (e.g. 60%) is entered in the budget form. In such case, an additional calculation supporting the budget would be necessary to provide, demonstrating the application of different funding intensities across cost categories, resulting in compliance with the overall project aid intensity of 60%.
Please confirm whether option A or option B is the correct interpretation of the call provisions and does the choice between options A and B has any impact on the evaluation of the proposal or could affect its eligibility during project assessment.
The same aid intensity must be applied to all eligible costs of each individual partner.
9. Could you please confirm that the Annual Work Units (AWU) should be taken from the “Number of employees based on hours worked” figure (“Broj zaposlenika prema satima rada”) in the applicant’s annual financial statements (GFI-POD) for the last closed financial year?
AWU should be taken from the “Number of employees based on hours worked”, as reflected in the annual financial statement of the enterprise (or another equivalent document).
10. Under the SPARK Call, the exclusion criteria (Annex I) state that a grant cannot be awarded to an applicant that “does not employ at least one person (1 FTE) based on recorded working hours, as reflected in the annual financial statement of the enterprise (or another equivalent document).”
At the same time, the Guidelines for Applicants foresee the case where “the applicant did not have any employees in the previous financial year,” providing that in such cases the daily personnel rate is calculated based on the payroll for the month preceding the submission of the project proposal.
The provision in the Guidelines for Applicants referring to cases where the applicant had no employees in the previous financial year relates exclusively to the methodology for calculating personnel costs (daily rate) and does not modify or replace the eligibility requirements defined under the exclusion criteria in Annex I. An applicant that had no employees in 2025 (the last closed financial year) but employs at least one person (1 FTE) in the month preceding the month of project submission evidenced by an equivalent document such as the payroll/JOPPD rather than the annual financial statement is not considered an eligible applicant under this Call.
11. 1) Calculation of private sector co‑financing
Could you please confirm whether the share of private co‑financing in Private sector commitment, Sub-criteria 4.1. Private sector co-financing in Annex I is assessed:
– per individual partner (each partner evaluated based on its own share of private funds within its own total budget cost), or
– at the consortium level (total project value and total private contribution combined for all partners)?
This distinction directly affects the scoring (0–5 points × 2).
2) Verification of ineligible costs during evaluation and implementation phase
Please describe how the verification of ineligible costs will be carried out both during the evaluation of the application and later in the implementation phase.
Specifically, what documentation is required or any at submission of application, and what sort of documentation will be requested during verification and implementation phase?
Additionally, please indicate whether cost quotations, calculations or similar supporting documents must be provided upfront or only if requested during evaluation or implementation?
1. The share of private co-financing under sub-criterion 4.1 is assessed at the project (consortium) level. In accordance with Annex I, points are awarded based on the share of private sector own funds in the total project value, whereby the total project value represents the sum of eligible and ineligible project costs of all project participants, excluding ineligible VAT. The private contribution corresponds to the difference between the total project value and the public funding (the requested grant and other contributions from public sources, if applicable).
2. The adequacy and relevance of ineligible costs and associated activities will be assessed during the evaluation under sub-criteria 3.1 (Feasibility of the implementation plan, including project and risk management) and 3.2 (Resources and budget). The verification of such costs and related supporting documentation may be carried out on a sampling basis both during the evaluation process and during project implementation.
Any relevant documentation may be requested during evaluation process, however reference to existing documentation should be made within the application.
12. Are there any elements in the evaluation process that assess the applicant’s previous experience in implementing research and development (R&D) projects, or is the assessment based solely on the quality and feasibility of the proposed project?
The qualitative assessment criteria are defined in Table 4 of Annex I to the Call. Previous experience is not assessed as a separate criterion; however, relevant elements are taken into account under sub-criterion 3.2. (Resources and budget), which assesses the expertise, experience and capacities of the applicant’s team, as well as access to the necessary infrastructure, equipment and technical knowledge. Relevant aspects are also considered under sub-criterion 3.1., which assesses whether the proposed activities are logically linked to the current stage of development and build upon previous work. Please, also see answer to Q#6.
13. The proposed project builds on a previously developed and field-tested prototype of a related technical solution. Under the SPARK project, a new demonstration prototype, tailored to specific research objectives and testing conditions, would be further developed and validated. Is such an approach considered eligible within the scope of experimental development envisaged under the Call?
Eligible activities are defined in Section 8.2. of the Applicants’ Guidelines and refer to experimental development, which may include the development of prototypes, demonstration, piloting, testing and validation of new or improved products, processes or services in environments representative of real operating conditions. Routine or periodic modifications to existing products and processes are not eligible. The objective of this Call is to support the development of innovative digital and green technologies, products, and processes. Also novelty of proposed solution is assessed within criterion 1.3.
The Ministry cannot assess the eligibility of a specific project proposal in advance; the assessment is carried out exclusively during the evaluation process, based on the complete project documentation.
14. Can the demonstration and validation of the technology be carried out at a facility or site owned by a third party that is not a project partner, provided that an appropriate contractual arrangement is in place allowing the applicant to perform the testing activities?
The Call documentation stipulates that projects must be implemented at an eligible location (Republic of Croatia). The Call documentation does not explicitly regulate the implementation of demonstration and validation activities at a location owned by a third party that is not a project partner. Provided that project activities are carried out by the applicant and partner(s), that all eligible costs relate to the applicant and partner(s), and that the applicant has a contractual arrangement ensuring access to the location for testing purposes, such an approach is not excluded by the Call documentation. Please note that third parties cannot be beneficiaries of grant funding and the results of this work shall remain the property of the Applicant/Partner, including any prototypes developed as a result of the activities.
15. Are there any additional interpretations or recommendations regarding the expected initial and final Technology Readiness Levels (TRLs) beyond those specified in the Call documentation?
Apart from the information provided in the Call documentation, there are no additional official interpretations. Eligible activities should aim to advance the solution from initial validation or early-stage development towards pilot implementation and demonstration in real-life conditions. Furthermore, the mandatory indicator “Number of innovative solutions developed” requires that the solution is sufficiently developed to be considered for application in the target market or operational environment. This should be demonstrated through the development and testing of a functional prototype, piloting of a service or process, or equivalent validation activities. Please also see answers to Q# 2 and 6.
16. Apart from the formal eligibility conditions set out in the Call documentation, are there any additional criteria or expectations related to the applicant (for example, previous development projects, research capacities, team experience, or other factors) that may be taken into consideration during the project evaluation process?
The applicant eligibility criteria are exhaustively defined in the Call documentation (Sections 4 and 5 of the Applicants’ Guidelines and Annex I), and there are no additional informal requirements. Elements such as the capacities and experience of the project team are assessed within the qualitative evaluation, as described in the first response.
17. Given that the innovation combines an existing, scientifically validated psychometric instrument with a newly developed predictive algorithm, is it sufficient that one part of the solution (the algorithm) meets the definition of experimental development under Article 2 of the GBER, or is the entire solution assessed as a package, whereby the existing instrument “dilutes” the assessment of innovativeness?
According to the definition of experimental development set out in Article 2, point 86 of Commission Regulation (EU) No 651/2014 (GBER), which is also incorporated in the Guidelines for Applicants, experimental development means acquiring, combining, shaping and using existing scientific, technological, business and other relevant knowledge and skills with the aim of developing new or improved products, processes or services. The use of an existing, scientifically validated instrument as a component of the solution does not, in itself, exclude the project from the category of experimental development — the combination of existing knowledge with newly developed elements is explicitly covered by the definition.
Two distinct levels of assessment should be noted in this respect:
- Eligibility of the project and activities — In accordance with Annex I of the Call, aid to enterprises is granted as aid for research and development (experimental development) pursuant to Article 25 of the GBER, and full compliance with the applicable provisions of Article 25 of the GBER is one of the eligibility criteria. The project activities to be financed must therefore qualify as experimental development. Activities constituting routine or periodic changes to existing products, processes or services are not covered, even if those changes represent improvements. The application should therefore clearly identify which activities constitute the developmental (non-routine) part of the project, and describe the technical uncertainty involved and the developmental contribution.
- Assessment of the innovativeness of the solution — In the quality assessment, the solution is evaluated as a whole, against the current state of the art, under sub-criterion 1.3. Novelty of the proposed solution (Annex I, Table 4), which assesses the degree of innovation and technological advancement, originality, added value, and differentiation from existing solutions on the market or in development. The presence of an already validated component does not automatically “dilute” the assessment; the score depends on the extent to which the solution as a whole — including the newly developed predictive algorithm and the manner of its integration with the existing instrument — represents an advancement beyond available solutions, which the applicant must substantiate in the application. The development approach (design, prototyping, testing, validation and iteration) is additionally assessed under sub-criterion 1.2. Soundness of methodology and development approach.
Please note that the assessment of the eligibility of activities and of the innovativeness of a specific project is carried out exclusively during the evaluation process, based on the content of the submitted application, and no prior confirmation of the classification or assessment of an individual solution can be provided in response to enquiries.
18. Is it mandatory for a partner to participate in all project activities, or may a partner be involved in only one activity – for example, only in research activities or only in dissemination?
The Call documentation does not require a partner to participate in all project activities. The distribution of activities is defined by the project and formalized in the Partnership Agreement, while partners are expected to contribute expertise or resources that enhance the project’s capacity to meet its objectives (Section 5 of the Guidelines for Applicants). The partner’s involvement must comply with the budget allocation and State aid rules. The role of each partner is also assessed in the quality evaluation and should be clearly justified in relation to the project objectives.
19. Annex I states that an applicant is not eligible if it does not employ at least one person / 1 FTE based on recorded working hours, as reflected in the annual financial statement of the enterprise or another equivalent document. Does “one person / 1 FTE” condition must be fulfilled by one natural person employed at 1 FTE, or whether it can also be fulfilled by two natural persons whose working time together equals 1 FTE, for example 0.5 FTE + 0.5 FTE? In case of partial employment – e.g. only 6 months in 2025 for 1 FTE, is this condition met or not? Is voluntary worked hours acceptable?
Could an entity registered as “obrt za proizvodnju i usluge” be eligible to apply under the DIGIT SPARK call?
The condition is verified against the figure “Number of employees based on hours worked” (annual work unit — AWU), as reflected in the annual financial statement (or an equivalent document). This figure is derived from the total recorded working hours of all employees; accordingly, the relevant benchmark is whether it amounts to at least 1.
The condition refers to employed persons based on recorded working hours; voluntary work is not employment and is not reflected as such in the annual financial statement, and therefore cannot be taken into account. Please note that the eligibility of a specific applicant can only be determined during the formal evaluation process, based on the complete submitted documentation. Obrt/trade is not eligible applicant to this Call.
20. Table 3 of the Guidelines lists “administrative staff costs” as eligible only for Activity 5, while for Activities 2, 3, and 4 only external consultancy/service costs are mentioned. Could you confirm whether internal staff work on Activities 2–4 is eligible under the 20% indirect cost flat rate, or only external service costs are covered? If internal staff work on these activities is not eligible, should its value be separately reported as an ineligible project cost, or simply omitted from the budget?
Under this Call, direct eligible costs may be budgeted only for Activity 1 (Research activities). Activities 2–5 are covered only through the indirect costs, calculated for each applicant/partner at a flat rate of 20% of the total direct eligible project costs allocated to Activity 1 for the same applicant/partner (Table 3 of the Guidelines for Applicants).
The costs are entered as the 20% flat rate, with a description of the costs they cover and are not individually budgeted. Admin staff is not eligible cost for Activities 2-4, it can be entered as an ineligible cost as well as omitted.
21. Could you confirm the following logic for allocating staff between the two tables?
Staff working on Activity 1 → listed under “Research team members”.
Staff working on Activities 2–5 → listed under “Project team members”.
Is this allocation correct, or should some staff on Activities 2–4 also appear under “Research team members”?
If the Project Leader is also the main/lead researcher on Activity 1, should they be listed under “Research team members” (as leading researcher), under “Project team members” (as project leader), or under both tables?
Should this allocation also correlate with the budget structure — i.e., Research team members’ costs are reported as direct staff costs under Activity 1, while Project team members’ costs are either covered within the 20% flat rate, ineligible, or not reported as project costs at all (Act 2-5)?
Staff working on Activity 1 should be listed under “Research team members”, while staff working on Activities 2–5 should be listed under “Project team members”. When planning staff costs in the budget, Applicants should take into account the eligibility of costs under the respective activities. Please also refer to the answer to Question 20.
22. To enable follow-on private investment (as measured by mandatory indicator A1 — private investment of beneficiaries and/or external investors in further development, scaling-up or commercialization of project results), the beneficiary may need to transfer the project — results, IP, team, and the rights and obligations under the Grant Agreement — to a newly established company wholly owned by the beneficiary or by its owners in identical proportions. Ultimate beneficial ownership, project objectives, activities, indicators and all Grant Agreement obligations (including durability, reporting and record-keeping under Articles 7 and 8 of the Conditions) would remain unchanged and be fully assumed by the successor; investors as a rule require such a dedicated single-product vehicle.
Is such a transfer permissible (a) during project implementation and (b) during the post-completion durability/reporting period, subject to prior approval and an addendum to the Grant Agreement? Would private investment into the successor company be recognised under indicator A1?
The Ministry cannot determine in advance the conditions and implications of such a transfer without having insight into the specific details and circumstances of the proposed transfer. Therefore, the Ministry is not in a position to provide a definitive assessment without reviewing the relevant information, including the nature of the transfer, the rights and obligations involved, and compliance with the applicable legal and contractual framework.
23. Annex I, Section 1.1, lists the following exclusion criterion:
“An applicant whose business revenue in the year prior to the submission of the project proposal (based on the latest available official data) is less than 50% of the total eligible project costs allocated to the applicant.”
Could you please confirm that the term “business revenue” refers to operating revenue, i.e., the position “Poslovni prihodi” (AOP 128) in the applicant’s annual financial statement (GFI-POD)?
Revenues include total operating income recorded in the financial statements of the applicant.
ATTENTION: Correction to the answer to Question 1:
The eligibility of each applicant and partner is assessed separately, in accordance with the eligibility requirements set out in the Call documentation. The eligibility conditions are not applied cumulatively across the consortium unless explicitly stated otherwise in the Call. Accordingly, the eligibility of the applicant and each partner should be assessed individually against the relevant requirements applicable to their respective role in the project. However, please note that the Ministry cannot provide an interpretation or assessment of the eligibility of a specific applicant, partner, or project proposal without reviewing the complete project documentation. Eligibility can only be determined during the formal evaluation process based on all information and evidence submitted with the project proposal.
A partner that did not have at least 1 FTE in the previous year is still an eligible partner, as this eligibility requirement applies exclusively to the Applicant.
24. Are trademark application costs (administrative fees payable to SIPO, EUIPO or WIPO) considered eligible costs under this Call?
Costs related to intellectual property protection are covered under Activity 2 – Innovation cycle management: costs of consultancy and equivalent services used exclusively for the project. These costs are eligible only for the duration of project implementation. However, administrative fees and charges related to trademark applications payable to SIPO, EUIPO, WIPO, or other relevant authorities are not eligible costs under this Call.
25. Does the reference in the ESMF Section 2.3 and Section 7.3 to “activities involving children (or other persons unable to give consent)” means that all activities involving persons under 18 are automatically considered substantial/high risk and therefore ineligible, irrespective of parental consent and the non-invasive nature of the activities.
The reference in the DIGIT Environmental and Social Management Framework (ESMF) to “activities involving children (or other persons unable to give consent)” does not mean that all activities involving persons under 18 years of age are automatically classified as substantial/high E&S risk or are automatically ineligible.
The E&S risk classification depends on the specific nature of the proposed activities, including the type of intervention, procedures involved, data collected, level of vulnerability and safeguards applied. Activities involving minors must undergo an appropriate E&S screening to determine the applicable risk level and eligibility.
Activities involving children or other persons unable to provide legally valid consent may represent increased E&S risks, particularly where they include medical interventions, collection of human samples or tissues, genetic procedures, invasive techniques, or other activities explicitly identified as high or substantial risk under the DIGIT exclusion criteria.
Where activities involving minors are considered eligible, appropriate safeguards must be ensured, including informed consent from parents/legal guardians where applicable, participant assent, ethics approval where required, protection of personal and health-related data, and implementation of relevant safeguarding measures.
26. Is there an obligation to submit additional documentation on compliance with the EU AI Act (e.g. a risk self-assessment) as part of the ESSQ (Environmental and Social Screening Questionnaire), or is this expected only at the implementation stage?
The ESSQ does not require submission of a separate EU AI Act compliance assessment or AI Act risk self-assessment as part of the application documentation.
However, applicants developing or using artificial intelligence systems should identify relevant AI-related aspects within the ESSQ and ensure that potential risks related to responsible AI use, data protection, transparency, cybersecurity and human oversight are appropriately considered.
Where applicable, compliance with the EU Artificial Intelligence Act and any related obligations (including risk classification, documentation, governance measures and conformity requirements) should be addressed during project implementation and before deployment or placing an AI system on the market.
27.
How must wide dissemination be described and demonstrated in the project application and during project implementation? May an applicant independently fulfil this requirement by publishing the research methodology, aggregated testing results or a technical report in an open-access repository, and by organizing a public webinar, workshop or presentation of project results? Is participation in an external conference, scientific conference or similar public event mandatory, or is it only one of the possible methods of wide dissemination? Is there a prescribed minimum number of dissemination activities, mandatory dissemination channels or a minimum required public reach? Which documents or other evidence will be accepted as proof that wide dissemination activities have been properly implemented, for example published materials, repository links, conference programs, certificates of participation, webinar recordings or participant lists? May the applicant protect the source code, commercial algorithms, licensed data, intellectual property and business secrets, while publicly disseminating the research methodology, aggregated results, validation procedures and conclusions? Please confirm whether an applicant applying independently, without project partners, may qualify for the increased aid intensity of up to 60% by independently implementing appropriate wide dissemination activities and providing evidence of their completion.
Wide dissemination of project results must be envisaged and described in the Application form as part of the project proposal (Project activities – Activity 3; Feasibility of implementation plan including project and risk management). During implementation, dissemination activities and their results are reported through the semi-annual (progress) reports and the final report, in accordance with Annex I of the Call. Where the increased aid intensity is based on wide dissemination, the fulfilment of this condition constitutes an obligation under the Grant Agreement.
In line with Article 25 of the GBER and Annex I of the Call, the results of the project must be widely disseminated through conferences, publications, open-access repositories, or free or open-source software. Participation in a conference is one of the possible methods, not a mandatory one. An applicant may therefore fulfil the condition independently, for example by publishing results in an open-access repository or through publications.
The requirement is that the project results are widely disseminated through the channels referred to above (set out in Article 25 of the GBER and Annex E of Annex I). The adequacy of the planned and implemented dissemination will be assessed based on the content of the application and the reports submitted during implementation. No minimum number of dissemination activities is prescribed.
Appropriate supporting evidence includes, for example, published materials, links to open-access repositories, conference programs and confirmations of participation, or equivalent records, submitted as part of the progress and final reports. Additionally, any public presentation of the project and its results in the media must be reported in the semi-annual and final reports.
The requirement for wide dissemination of project results does not prevent Applicants from protecting source code, algorithms, or other intellectual property. In that case Applicants should follow the procedures of the relevant authorities — for example, publishing only after filing a patent application — so that protection is secured before the relevant results are publicly disseminated. Applicants should note, however, that the increased aid intensity rests on the dissemination condition being met. If the results are withheld to an extent that the condition is not fulfilled during implementation, the basis for the increased intensity falls away. Applicants are therefore responsible for ensuring that what is disseminated is sufficient to satisfy the requirement.
In accordance with Annex I of the Call, the aid intensity for experimental development may be increased by 15 percentage points, up to a maximum of 60% of eligible costs, if the project involves effective collaboration or wide dissemination of results. The claim must be indicated in Annex X, “Consortium and budget structure” sheet, by selecting wide dissemination of results as the rationale for increased aid intensity. An applicant implementing the project independently may therefore qualify for increased intensity based on wide dissemination (e.g. up to 60% for micro and small enterprises, up to 50% for medium-sized enterprises). Please note that where wide dissemination is the basis for the increased aid intensity, dissemination costs are not eligible for enterprises, in line with applicable State aid rules and should be added to ineligible costs.
28. Are trademark application costs (administrative fees payable to SIPO, EUIPO or WIPO) considered eligible costs under this Call?
Costs related to intellectual property protection are covered under Activity 2 – Innovation cycle management: costs of consultancy and equivalent services used exclusively for the project. These costs are eligible only for the duration of project implementation. However, administrative fees and charges payable to SIPO, EUIPO, WIPO, or other relevant authorities are not eligible costs under this Call.
29. In line with the Guidelines, the project team members will be named/identified in the project application itself (e.g., through the Application Form and Annex VI. Curriculum Vitae). For the Excel budget (Annex X. Project Budget), in the ‘Cost name’ column for personnel costs, should we enter only the role/position of the team member (e.g., ‘Project Manager’, ‘Researcher’), or also the full name and surname of the employee? Alternatively, should the name and surname be entered under the ‘Cost description’ column instead?
Personnel costs are not budgeted per individual employee. In accordance with Section 10 of the Guidelines for Applicants, personnel costs must be allocated collectively for all individuals working on a specific activity, and each personnel cost item must specify the total number of daily rates required, without detailing the number of working days of each individual staff member where several persons work on the same item. The daily rate is calculated at the level of the organization and is fixed, and is therefore the same for all employees of that applicant or partner.
Accordingly, the full name and surname of employees should not be entered either in the “Cost name” or in the “Cost description” column of Annex X. The “Cost name” column should identify the personnel cost item collectively, by reference to the work it covers within Activity 1 (for example, “Personnel – prototype development and testing”). In the “Cost description” column, applicants should describe the purpose of the cost and its relevance to the project activities, and specify the basis for the estimation, in line with the instructions given in the Detailed Budget table. The “Unit cost” is the applicant’s or partner’s daily rate, and the “Quantity” is the total number of day-equivalents required for that cost item.
The identification of individual team members, their roles and the description of each person’s engagement in the project activities are provided in the Application form, not in the budget. Please also refer to the answers to Questions 3 and 19.
30. How to substantiate the Annual Work Units (AWU) figure required under Section 10.1 of the Guidelines for Applicants (GfA), in cases where the actual calculated AWU value differs from the whole-number figure shown on the Annual Financial Form (GFI), as answered in Q&A section (Question 9). Specifically, the GFI form only accepts whole numbers in the “Number of employees based on hours worked” field. This can result in situations where the actual AWU, calculated per the Section 10.1 methodology, is a fractional value lower than the whole number shown on the GFI form.
As indicated in the answer to Question 9, the Annual Work Units (AWU) figure is taken from the “Number of employees based on hours worked” as reflected in the annual financial statement of the enterprise (or another equivalent document), and the daily rate is calculated in accordance with the methodology set out in Section 10.1 of the Guidelines for Applicants.
The methodology is applied as defined in the Call. The calculation of the daily rate, including the AWU value used, is subject to cost eligibility verification and budget cleaning.
31. Will it be possible to engage newly hired staff during project implementation under a supplementary employment contract (dopunski rad)?
The Call documentation does not prescribe a specific type of employment contract for persons working on the project. In accordance with Table 3 and Section 10 of the Guidelines for Applicants, eligible personnel costs cover salaries for both newly recruited and existing staff engaged on the project. Personnel costs are eligible provided that the engagement complies with applicable national labour legislation and that the costs are supported by employment contracts, payroll records, and monthly timesheets signed by the employee and the project manager. The personnel-cost methodology, including the daily rate, is applied in accordance with Section 10 of the Guidelines for Applicants.
Please note that, in the project proposal, the applicant should plan the capacities and workload of the project team in accordance with the planned project activities. The engagement of each person in the project activities must be specified and described in the Application form, and the adequacy of the project team’s capacity to implement the planned activities is subject to quality assessment. Any planned engagement arrangement, including supplementary employment (dopunski rad), must therefore be realistic and consistent with the workload foreseen for the respective project activities.
The Ministry cannot provide a prior assessment of the eligibility of a specific engagement arrangement; compliance will be verified during project implementation based on the submitted supporting documentation.
32. We kindly request clarification regarding the interpretation of Annex I, Section 1.2, Part B (Other ineligible activities related to the DIGIT Project).
Our potential project under Group A: Digital R&D concerns the development of a device intended for scientific research in zoology, designed to collect data on the movement, behaviour and other parameters of wild animals. As part of the product development process, it would be necessary to conduct field validation and functional testing of the device on the target animal species.
Such testing would be entirely non-invasive and would not cause any harm to or adversely affect the welfare of the animals. It would be carried out only after obtaining all required approvals from the competent authorities and in accordance with internationally recognised and widely accepted scientific research methodologies for wildlife studies.
Could you please clarify whether the above-described activity would be considered “testing on animals” within the meaning of Annex I, Section 1.2, Part B, and therefore constitute grounds for the project’s ineligibility, even though the testing is non-invasive and does not cause harm to or compromise the welfare of the animals?
According to Annex I, Section 1.2, Part B of the Exclusion List, activities involving testing on animals are eligible only in relation to the animal groups explicitly listed therein, namely certain invertebrates, small rodents (mice and rats), and fish, provided that they are not endangered or protected species. All other animals are explicitly excluded.
The fact that the proposed testing is non-invasive, does not cause harm or adversely affect animal welfare, and would be conducted in accordance with applicable permits and recognised scientific methodologies does not, in itself, determine whether the activity falls outside the scope of the Exclusion List.
Based on the general information provided, it is not possible at this stage to determine whether the proposed activity would constitute “testing on animals” within the meaning of the Exclusion List. This will depend on the target animal species and the manner in which the device would be tested and validated.
For example, field validation consisting solely of passive observation or data collection in the natural environment, without animals serving as test subjects, would generally not be considered “testing on animals”. However, testing or validation of a device directly on individual animals may fall within the scope of the exclusion, depending on the specific circumstances.
Therefore, should a project proposal be submitted, the proposed activities will be assessed as part of the environmental and social (E&S) screening procedure to determine whether they fall within the scope of the Exclusion List and are eligible for financing under the DIGIT Project. The application should clearly describe the target animal species, the proposed field validation methodology and any direct interaction with animals.
33. Could you clarify whether activities involving protected species are considered eligible or ineligible? The species in question (soft-mouthed trout) is protected at all levels.
The Exclusion List in Annex I regarding the testing on animals has been corrected due to an identified error. An amendment to the document has been published.
According to the Exclusion List, testing on animals is an ineligible activity, except for testing on explicitly stated groups including fish, under the condition that they are not an endangered or protected species.
If the species mentioned is protected, activities that include testing or experiments on living organisms of that species are ineligible for financing under the DIGIT Project.
However, a project focused on the conservation and restoration of a protected species population may be eligible for financing under the DIGIT Project, provided that the primary objective of the proposed activities is to support the conservation of the species, enhance its population, or deliver another direct benefit to the species concerned. Prior to the implementation of any activities involving protected species, all required permits, consents, and other approvals from the competent authorities must be obtained in accordance with the applicable national legislation.
The project’s eligibility, as well as the environmental and social (E&S) risks associated with the proposed activities, will be assessed as part of the E&S screening process. Where necessary, appropriate mitigation and management measures will be identified and implemented to address any risks and impacts identified during the assessment.