A Gender Equality Plan (GEP) is an institutional policy that sets out how an organisation will advance gender equality through concrete measures, resources, training and monitoring. Under Horizon Europe, certain organisations must have a GEP that meets four process-related requirements to be eligible for funding. The obligation applies at organisational level, not just to the team preparing a proposal.
For universities, research organisations and public bodies, understanding the requirement early can prevent avoidable difficulties during grant preparation. More importantly, a well-designed GEP can help an institution identify persistent inequalities and improve its policies over time.
This guide explains who is covered, what the mandatory requirements mean in practice, how they differ from the recommended thematic areas, and how to build a plan that can be implemented and monitored.
Which organisations need a Gender Equality Plan for Horizon Europe?
Public bodies, research organisations and higher education institutions established in EU Member States or Horizon Europe Associated Countries are generally subject to the GEP eligibility criterion. The requirement applies to both public and private research organisations and higher education institutions. It is important to assess an entity's actual legal and organisational classification rather than relying on its everyday description.
| Organisation | General position under the GEP eligibility criterion |
|---|---|
| Public university | GEP required |
| Private higher education institution | GEP required |
| Public or private research organisation | GEP required |
| Public authority or other public body | GEP required |
| Private for-profit company that is not otherwise a covered research or higher education organisation | Generally outside the GEP criterion |
| NGO that is not otherwise a covered organisation | Generally outside the GEP criterion |
The criterion concerns covered organisations participating as beneficiaries and, where applicable, affiliated entities. It does not automatically extend to subcontractors simply because they provide services to a funded project. For the distinction between beneficiary tasks and external services, see Grant 360's guide to subcontracting in Horizon Europe.
When must the GEP be in place? The requirement is generally checked at grant agreement signature rather than at proposal submission. Nevertheless, preparing it only after a proposal is selected creates unnecessary risk: approval, publication, governance arrangements and monitoring systems may take time. Always check the applicable call conditions and current Horizon Europe General Annexes.
A national equality plan may provide a strong starting point, but national compliance does not automatically establish Horizon Europe compliance. Check the EU's four mandatory process requirements individually.
What are the four mandatory GEP requirements?
A Horizon Europe-compliant GEP must satisfy four process-related building blocks: publication, dedicated resources, data collection and monitoring, and training and capacity building. These are eligibility requirements; they are distinct from the five thematic areas recommended by the European Commission.
| Mandatory requirement | What to establish | Evidence to retain |
|---|---|---|
| Public document | A formal GEP published on the institution's website and endorsed by top management | Published plan, approval record, stable URL |
| Dedicated resources | Named people and appropriate expertise, time and/or budget for implementation | Responsibilities, staffing allocation, governance decisions |
| Data collection and monitoring | Sex/gender-disaggregated personnel data and relevant indicators, with regular reporting | Baseline, indicator definitions, monitoring reports |
| Training and capacity building | Awareness-raising and training on gender equality and unconscious bias for relevant staff and decision-makers | Training plan, materials, attendance and feedback |
1. What counts as a public GEP document?
The GEP must be an official, publicly accessible institutional document, endorsed by senior management. It should identify the organisation, state its commitments and measures, and be easy to locate on the institution's website. A private working document or an unapproved draft is not a substitute.
For practical transparency, include a date, responsible body, period of application, contact point and review arrangements. These elements also make the document easier to maintain and verify.
2. What resources should be allocated?
The organisation must demonstrate that implementing gender equality measures is someone's responsibility and that appropriate resources are available. This does not necessarily mean creating a large new department. A smaller institution may assign a coordinator, a cross-functional working group and time within existing roles.
The essential point is operational ownership: who will deliver the actions, who can make decisions, and how implementation will be supported.
3. What data should be collected and monitored?
A GEP needs an evidence base and a mechanism for tracking progress. Institutions should collect and report relevant sex/gender-disaggregated personnel data and use indicators to assess inequalities and the effects of their actions.
Depending on the organisation, useful measures include representation across career stages, recruitment and promotion outcomes, leadership composition, pay differences, contract types and participation in training. Data collection should respect applicable data protection rules, especially where small groups might be identifiable.
Begin with a baseline. Then specify the indicator owner, source, frequency and method of interpretation. Monitoring should inform decisions rather than become an annual reporting exercise with no follow-up.
4. What training is expected?
The GEP must include awareness-raising and training on gender equality and unconscious bias, including for staff and decision-makers. The content should match the institution's needs: for example, recruitment panels may need practical guidance on fair assessment, while managers may need training on inclusive leadership and responding to harassment.
Record what was delivered and assess whether participants can apply it. A single generic presentation is unlikely to be an effective long-term training strategy.
Which five thematic areas does the European Commission recommend?
The Commission recommends addressing five thematic areas, but they are not the same as the four mandatory eligibility building blocks. Institutions should select measures based on their context and evidence, rather than copying a universal checklist.
| Recommended area | Possible institutional action | Example indicator |
|---|---|---|
| Work-life balance and organisational culture | Review meeting schedules, flexible work and parental-leave practices | Uptake of flexible arrangements by staff group |
| Gender balance in leadership and decision-making | Improve transparency of appointments and leadership development | Representation in decision-making bodies |
| Gender equality in recruitment and career progression | Standardise selection criteria and train panels | Recruitment and promotion outcomes by gender |
| Integration of the gender dimension into research and teaching | Support researchers and educators in assessing relevant sex/gender dimensions | Share of relevant projects using documented sex/gender analysis |
| Measures against gender-based violence, including sexual harassment | Establish confidential reporting, support and response procedures | Staff awareness of reporting and support channels |
An institution can prioritise different measures across these areas, but should explain its choices and regularly assess their effectiveness.
How is an institutional GEP different from gender analysis in a research proposal?
A GEP concerns the organisation's policies and working environment; gender analysis in research concerns the scientific content of a project. They are related but separate Horizon Europe considerations.
For example, a university's GEP may address equitable recruitment and promotion. A health research proposal submitted by that university may also need to examine whether biological sex or sociocultural gender factors influence study design, data collection and interpretation.
Having a GEP does not automatically mean a proposal has adequately integrated the gender dimension into its methodology. Conversely, a proposal with excellent gender analysis does not replace an institutional GEP where the eligibility criterion applies. The topic conditions and proposal template determine how research-content requirements must be addressed. Grant 360's complete Horizon Europe proposal guide provides the wider proposal context.
How can an organisation develop a practical GEP?
The most reliable approach is to audit existing policies, identify gaps, agree measurable actions and assign accountability before publication. A GEP should be proportional to the institution's size and capacity, but specific enough to guide decisions.
Step 1: Map existing policies and obligations
Gather equality plans, human-resources policies, recruitment procedures, anti-harassment mechanisms and relevant national requirements. Map each against the four Horizon Europe building blocks and identify missing evidence or processes.
Step 2: Establish a baseline
Review available personnel and governance data, consult staff and identify areas where unequal outcomes or barriers may exist. Document data limitations rather than drawing strong conclusions from incomplete figures.
Step 3: Agree priorities and measurable actions
For each priority, describe the problem, intended change, action, responsible person, timeframe and indicator. Avoid vague commitments such as "promote inclusion" without a concrete implementation mechanism.
Illustrative action plan (example, not a prescribed EU template):
| Objective | Action | Owner | Timing | Monitoring |
|---|---|---|---|---|
| Improve fairness in recruitment | Introduce structured scoring criteria and panel training | HR director | Within 6 months | Panel training coverage and selection outcomes |
| Strengthen leadership representation | Review appointment processes and create mentoring opportunities | Executive team | Within 12 months | Representation by leadership level |
| Improve reporting confidence | Publish accessible reporting and support procedures | Equality officer | Within 6 months | Awareness survey and process review |
Step 4: Secure senior-level endorsement and resources
Confirm decision-making authority, staff time, budget where necessary, and reporting lines. Involve researchers, administrative staff, management and, where relevant, students so that measures reflect actual working conditions.
Step 5: Publish and communicate the plan
Approve the document, make it accessible on the institution's website, and explain internally how staff can participate or seek support. Publication is the beginning of implementation, not its conclusion.
Step 6: Monitor, report and revise
Review indicators and implementation progress at defined intervals. Where an action has not produced the intended result, examine the causes and adapt the approach. Maintain a record of decisions and changes. The same ownership-and-evidence approach is central to effective Horizon Europe project management.
What should coordinators check when building a Horizon Europe consortium?
Coordinators should identify potentially covered organisations early and ask them to confirm their GEP readiness before grant preparation reaches its final stages. A practical partner-onboarding check can include:
- The organisation's legal type and country of establishment.
- Whether the Horizon Europe GEP eligibility criterion applies.
- Whether an endorsed GEP is publicly available and where it can be found.
- Whether the organisation has assigned resources, monitoring and training arrangements.
- Whether any gaps could prevent compliance by grant agreement signature.
A coordinator can support partner readiness, but each organisation remains responsible for its own eligibility and declarations. Avoid treating the presence of a website PDF as proof that every mandatory requirement is met. Include this check alongside capability, eligibility and role allocation when building a Horizon Europe consortium.
What are the most common mistakes when preparing a GEP?
The biggest risk is confusing a published statement of intent with an implemented institutional plan. Watch for these problems:
| Common mistake | Better approach |
|---|---|
| Assuming a national plan automatically meets EU requirements | Check all four Horizon Europe building blocks |
| Publishing an unsigned or purely aspirational document | Obtain senior endorsement and specify actionable measures |
| Naming no responsible staff or resources | Allocate ownership, time and appropriate support |
| Collecting data without reviewing it | Define reporting cycles and decisions linked to findings |
| Offering training without a strategy | Target relevant roles and document delivery |
| Treating the five thematic areas as the four eligibility criteria | Distinguish mandatory processes from recommended policy themes |
| Waiting until grant agreement preparation | Start the compliance review during consortium formation |
Frequently asked questions about GEPs in Horizon Europe
Is a Gender Equality Plan mandatory for every Horizon Europe applicant?
No. The eligibility criterion generally applies to public bodies, research organisations and higher education institutions established in EU Member States or Associated Countries. Other applicants may fall outside its scope. Check the legal classification of the entity and the relevant call conditions.
Does a private university need a GEP?
Yes, if it qualifies as a higher education institution established in an EU Member State or Associated Country and the relevant Horizon Europe conditions apply. Private ownership does not itself remove the requirement.
Must the GEP exist before proposal submission?
The criterion is generally required by the time of grant agreement signature, rather than proposal submission. Institutions should nevertheless prepare early and verify the precise conditions for their call.
Can an existing national equality plan serve as the GEP?
Yes, potentially. An existing plan can be used if it meets the Horizon Europe requirements, including publication, resources, monitoring and training. Its title is less important than its substance and implementation.
Are the five thematic areas mandatory for eligibility?
No. They are recommended areas for the content of a GEP. The four mandatory process-related requirements determine the baseline GEP eligibility criterion.
Does having a GEP satisfy the gender dimension requirement in Part B?
No. Organisational gender equality planning and the integration of sex/gender analysis into research content are separate considerations. A proposal must address the relevant research-content requirements on their own terms.
Conclusion: How can a GEP become more than a compliance exercise?
A Gender Equality Plan is both an eligibility instrument and an opportunity to improve how an institution works. The minimum is clear: publish an endorsed plan, dedicate resources, monitor relevant data and provide training. The longer-term value comes from using those foundations to identify barriers, implement targeted measures and assess whether conditions are improving.
For Horizon Europe applicants, early preparation reduces eligibility risk. For institutions, meaningful implementation can turn a formal requirement into a sustained programme of organisational improvement.
Official resources and further reading
- European Commission - Gender equality in research and innovation
- European Commission - Horizon Europe programme
- EU Funding & Tenders Portal - Reference documents - consult the General Annexes and the applicable call conditions for the authoritative eligibility rules.
Editorial note: This article is general guidance. The applicable work programme, call conditions and official European Commission guidance take precedence.