--- title: "Funding for AI and digital projects: a practical map | Pitch" description: "Which EU programme fits which AI or digital project, from Digital Europe and Horizon Europe to InvestEU and free computing time, who can apply, what each one…" url: https://pitch.law/academy/eu-funding-ai-digital-projects --- [pitch](https://pitch.law/) [Academy](https://pitch.law/academy) [Data](https://pitch.law/academy/topics/information-technology) # Funding for AI and digital projects: a practical map Which EU programme fits which AI or digital project, from Digital Europe and Horizon Europe to InvestEU and free computing time, who can apply, what each one pays, and what the IP, ownership and security rules mean for your company. - - By [Bart Lieben](https://pitch.law/team/bart-lieben), Attorney-at-Law - 13 November 2026 - Updated 13-11-2026 ## The legal framework ### Status and the texts Three Regulations carry most EU funding for AI and digital projects in the 2021-2027 period. All three are in force and have been amended several times. Always read the latest consolidated version, which is what we cite here. - **Digital Europe Programme**: [Regulation (EU) 2021/694](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R0694) of 29 April 2021 ([consolidated version of 23 December 2025](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0694-20251223)). It funds deployment: putting digital capacity into use. - **Horizon Europe**: [Regulation (EU) 2021/695](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R0695) of 28 April 2021 ([consolidated version of 24 December 2025](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0695-20251224)). It funds research and innovation, including the European Innovation Council. - **InvestEU**: [Regulation (EU) 2021/523](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021R0523) of 24 March 2021 ([consolidated version of 24 December 2025](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0523-20251224)). It provides an EU guarantee that covers loans, guarantees, equity and other financing provided by implementing partners (Article 16). Two more routes add computing power and chip support: the EuroHPC Joint Undertaking (see [access to EU computing](https://pitch.law/academy/eu-computing-ai-factories-eurohpc)) and the Chips Act (see [Chips Act 2.0 and the Quantum Act](https://pitch.law/academy/chips-act-2-and-quantum-act)). The money itself is allocated in work programmes and calls. The Regulations set the frame: objectives, eligibility, funding rates and IP rules. Calls set the deadlines and the exact conditions. ### Which programme for which project | Your project | Where to look | Form | | --------------------------------------------------------------- | ------------------------------------------------------------------------ | ----------------------------------------------------------- | | Deploying AI, cybersecurity, HPC or semiconductors in the Union | Digital Europe, Specific Objectives 1 to 3 and 6 (Article 3(2)) | Procurement as primary form, grants, prizes (Article 14(2)) | | Digital skills | Digital Europe, Specific Objective 4 | Grants, also to natural persons | | Support from a local hub to digitise your SME | European Digital Innovation Hubs (Digital Europe, Article 16) | Services | | Research and innovation with partners | Horizon Europe calls | Grants | | A start-up or SME scaling a breakthrough innovation | EIC Accelerator (Horizon Europe, Article 48) | Grant, blended finance or equity | | Debt or equity for innovation and digitisation | InvestEU, research, innovation and digitisation window (Article 8(1)(b)) | Loans, guarantees, equity through partners | | Computing time for AI training | EuroHPC AI Factories | Access time, free in defined cases | ### Digital Europe, article by article **Objectives ([Article 3](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0694-20251223)).** Six specific objectives: high performance computing, artificial intelligence, cybersecurity and trust, advanced digital skills, deployment and interoperability, and semiconductors. **Artificial intelligence ([Article 5](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0694-20251223)).** Builds core AI capacities, including data resources and libraries of algorithms; makes them accessible to businesses, especially SMEs and start-ups; reinforces testing and experimentation facilities; and supports commercial application. AI solutions and data must respect privacy and security by design and comply with data protection law. Work programmes set ethical requirements that calls and grant agreements include, and funding can be suspended, terminated or reduced for non-compliance (Article 5(2)). **Security ([Article 12](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0694-20251223)).** Proposals may need a security self-assessment. For cybersecurity actions and actions on dual-use technologies, the work programme may exclude entities established in the Union but controlled from third countries (Article 12(5)). For HPC, AI and semiconductor actions, such entities may be admitted only if they meet security requirements (Article 12(6)). **European Digital Innovation Hubs ([Article 16](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0694-20251223)).** Hubs give businesses, in particular SMEs and mid-caps, and public bodies access to expertise, testing and experimentation, and thematic services in AI, HPC and cybersecurity (Article 16(6)). **Eligibility and grants ([Articles 18 and 19](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0694-20251223)).** Legal entities established in a Member State or associated country are eligible. Natural persons only for skills grants. Work programmes may limit participation to Member States for security or strategic autonomy reasons (Article 18(4)). Grants may cover up to 100% of eligible costs, subject to the co-financing principle (Article 19). ### Horizon Europe, article by article **Funding rates ([Article 34](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0695-20251224)).** Up to 100% of eligible costs, except innovation actions, which reimburse up to 70% for profit-making entities (100% for non-profits). The work programme fixes the rate per action. **Ownership ([Article 38](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0695-20251224)).** Beneficiaries own the results they generate. Results generated jointly, where contributions cannot be separated, are jointly owned. Joint owners must agree in writing. Unless agreed otherwise, each joint owner may grant non-exclusive licences without a right to sub-license, after advance notice and fair and reasonable compensation to the others. Beneficiaries must protect results adequately where possible and justified. **Exploitation and dissemination ([Article 39](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0695-20251224)).** Each beneficiary must use its best efforts to exploit its results. It must disseminate them as soon as feasible, subject to IP protection, security and legitimate interests. Open access to scientific publications is required, and open access to research data is the general rule, "as open as possible, as closed as necessary". Other beneficiaries get advance notice of dissemination and may object if it would significantly harm their interests (Article 39(5)). See also the open science principle in [Article 14](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0695-20251224). **Transfer and licensing ([Article 40](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0695-20251224)).** Results may be transferred or licensed, including exclusively, but obligations follow the results. Other beneficiaries get notice of transfers and may object if their access rights suffer. Where the grant agreement provides for it, the Commission may object to transfers or exclusive licences to entities in non-associated third countries that are not in line with Union interests (Article 40(4)). **Access rights ([Article 41](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0695-20251224)).** Partners get royalty-free access to each other's results and background where needed to carry out their tasks, and access on fair and reasonable terms where needed to exploit their own results. Before signing, beneficiaries must tell each other about restrictions on access to their background (Article 41(3)). Union institutions get royalty-free access to results for non-commercial policy use (Article 41(9)). **EIC Accelerator ([Article 48](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0695-20251224)).** For single beneficiaries: start-ups and SMEs and, in exceptional cases, small mid-caps, established in a Member State or associated country. It offers blended finance, grant-only support (once per beneficiary, up to EUR 2.5 million), and equity-only support. The grant component may not exceed 70% of eligible costs (Article 48(9)). Proposals that pass the excellence and impact thresholds may receive a Seal of Excellence (Article 48(7)). ### InvestEU, article by article **Policy windows ([Article 8](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0523-20251224)).** The research, innovation and digitisation window covers R\&D, technology transfer, demonstration and deployment, scaling up innovative companies and digitisation of Union industry. The SME window covers access to finance for SMEs and small mid-caps. For strategic investments in cybersecurity and other security-relevant projects, the investment guidelines set limitations for recipients controlled by a third country or third-country entities (Article 8(3)). **Advisory Hub and Portal ([Articles 25 and 26](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02021R0523-20251224)).** The Advisory Hub helps prepare and structure investment projects. The Portal lets project promoters make projects visible to investors; listing does not guarantee financing. Implementing partners also examine projects that received a Sovereignty Seal under the STEP Regulation (Article 26(5)). ## In practice **Start from the project, not the programme.** Research with partners points to Horizon Europe. Deployment of AI or cybersecurity points to Digital Europe. Scaling with debt or equity points to InvestEU or the EIC Accelerator. Computing time comes from EuroHPC. **Check control and establishment early.** Several calls exclude or condition entities controlled from outside the Union. A Belgian subsidiary of a non-EU group may be eligible in one call and excluded in the next. Map your shareholding before you invest time in a proposal. **Write the consortium agreement before the proposal.** Under Horizon Europe the default rules on ownership, joint ownership and access rights apply unless you agree otherwise. Agree on background lists, joint ownership terms, licensing and publication procedures in advance. Tell partners about restrictions on your background before signing, as Article 41(3) requires. **Protect before you publish.** Open access duties and dissemination timelines can conflict with patent filings. File first, then publish. Use the objection procedure of Article 39(5) if a partner's planned publication would harm your results. **Plan for exit.** If you may sell the company or license results outside the Union, check whether the grant agreement gives the Commission a right to object (Article 40(4)). Investors will ask. A worked example: a Flemish AI start-up and a university develop a medical imaging model. They apply under a Horizon Europe call, with the university as non-profit at 100% and the start-up in an innovation action at 70%. Their consortium agreement lists the start-up's existing software as background with access only for project tasks, gives the start-up ownership of the trained model, and lets the university publish after a 45-day review. The start-up then applies for the EIC Accelerator to scale. It uses free AI Factory time as an SME for private innovation. ## Frequently asked questions ### Can a non-EU company receive EU digital funding? Legal entities established in a Member State or associated country are generally eligible. For security-sensitive actions, work programmes may exclude or condition entities controlled from third countries (Article 12 of the Digital Europe Regulation; Article 48(2) of the Horizon Europe Regulation for certain support). ### Who owns what we develop with a Horizon Europe grant? The beneficiary that generates the results owns them. Jointly generated results that cannot be separated are jointly owned, and joint owners must agree in writing (Article 38). ### Is the EIC Accelerator a grant or an investment? Both are possible. It mainly provides blended finance (grant plus equity), but also grant-only support up to EUR 2.5 million once per beneficiary, and equity-only support. ### Does a Seal of Excellence give money? Not by itself. It recognises a high-quality proposal and can open doors elsewhere, for example free computing time on EuroHPC machines for Seal holders. ## How this connects Our [R\&D grants and subsidies](https://pitch.law/solutions/r-d-funding) team matches your project to the right call and manages the file, and our [funding](https://pitch.law/solutions/funding) team prepares you for investors. We draft consortium agreements with [Document Studio](https://pitch.law/technologies/contract-studio), our proprietary document analysis and development system, and check grant and investment terms with the [clause library and risk review](https://pitch.law/technologies/clause-library-risk-review). For Belgian incentives, read [grants and tax incentives for IP in Belgium](https://pitch.law/academy/ip-grants-tax-incentives-belgium). **Cited provisions:** Regulation (EU) 2021/694, Articles 1, 3, 5, 12, 14, 16, 18 and 19; Regulation (EU) 2021/695, Articles 14, 34, 38 to 41 and 48; Regulation (EU) 2021/523, Articles 8, 16, 25 and 26 (all as consolidated in December 2025). **Key dates:** - 24 March 2021: InvestEU Regulation adopted - 28 April 2021: Horizon Europe Regulation adopted - 29 April 2021: Digital Europe Regulation adopted - 2021 to 2027: programme period of the Digital Europe Programme (Article 1) **Related reading:** [access to EU computing](https://pitch.law/academy/eu-computing-ai-factories-eurohpc), [Chips Act 2.0 and the Quantum Act](https://pitch.law/academy/chips-act-2-and-quantum-act), [grants and tax incentives for IP in Belgium](https://pitch.law/academy/ip-grants-tax-incentives-belgium) and [technology transfer agreements](https://pitch.law/academy/technology-transfer-agreements). ## In short - Digital Europe, Horizon Europe and InvestEU side by side - Who is eligible, and when non-EU control is a problem - Funding rates and the EIC Accelerator - Ownership, access rights and open science in Horizon Europe - A checklist before you sign a grant or consortium agreement ## Related solutions - [Solutions](https://pitch.law/solutions/r-d-funding) ### [R\&D Grants and Subsidies](https://pitch.law/solutions/r-d-funding) [Grants can fund a real share of an R\&D project, but only a well-built application gets there. We match the project to EU programmes such as Horizon Europe, or to national and regional schemes, and manage the file.](https://pitch.law/solutions/r-d-funding) - [Solutions](https://pitch.law/solutions/funding) ### [Funding](https://pitch.law/solutions/funding) [Before investors put money in, they want to see clean IP, clean records and clean contracts. We get you ready for the round, then do the legal work through to closing.](https://pitch.law/solutions/funding) ## Our proprietary Legal Tech - [Technology](https://pitch.law/technologies/contract-studio) ### [Document Studio](https://pitch.law/technologies/contract-studio) [Our Document Studio drafts and analyses legal documents in a secure, on-premise environment, and keeps the documents behind your matters up to date as new data comes in and procedural steps fall due.](https://pitch.law/technologies/contract-studio) - [Technology](https://pitch.law/technologies/clause-library-risk-review) ### [Contract Review](https://pitch.law/technologies/clause-library-risk-review) [Send us the contract the other side drafted and we check it clause by clause against our playbook, with a risk ranking an attorney has verified.](https://pitch.law/technologies/clause-library-risk-review) ## More in Data - ### [Children Online: the EU KIDS Act Proposal and Age Verification](https://pitch.law/academy/children-online-kids-act-and-age-verification) [What the Digital Services Act already requires to protect minors, what the EU KIDS Act proposal of 17 September 2026 would add for social networks, video platforms, games, app stores and chatbots, and how the EU age verification framework fits in.](https://pitch.law/academy/children-online-kids-act-and-age-verification) - ### [The Cloud and AI Development Act: sovereignty rules for cloud and AI procurement](https://pitch.law/academy/cloud-and-ai-development-act) [What the Commission's proposal for a Cloud and AI Development Act would require of cloud providers that sell to the public sector, of contracting authorities, and of bidders for cloud and AI contracts, and how it sits next to the Data Act and the procurement Directive.](https://pitch.law/academy/cloud-and-ai-development-act) - ### [Cyber Resilience Act III: importers, distributors, open source and contracts](https://pitch.law/academy/cyber-resilience-act-importers-distributors-open-source) [The duties of importers, distributors and authorised representatives under Articles 18 to 23 of Regulation (EU) 2024/2847, when a reseller becomes a manufacturer, how free and open-source software and its stewards are treated, and the clauses that follow.](https://pitch.law/academy/cyber-resilience-act-importers-distributors-open-source) - ### [Cyber Resilience Act I: which products are caught, and in which class](https://pitch.law/academy/cyber-resilience-act-products-and-classes) [How to tell whether hardware or software you sell falls under Regulation (EU) 2024/2847, whether it is a default, important (class I or II) or critical product, and which conformity route follows from that, with the dates up to 11 December 2027.](https://pitch.law/academy/cyber-resilience-act-products-and-classes) - ### [Cyber Resilience Act II: vulnerability handling and reporting since 11-09-2026](https://pitch.law/academy/cyber-resilience-act-vulnerability-handling-and-reporting) [What manufacturers must report under Article 14 of Regulation (EU) 2024/2847 since 11 September 2026, within 24 hours, 72 hours, 14 days and one month, and the vulnerability handling duties of Annex I, Part II, that follow from 11 December 2027.](https://pitch.law/academy/cyber-resilience-act-vulnerability-handling-and-reporting) - ### [Cyber incidents across borders: the Cyber Solidarity Act](https://pitch.law/academy/cyber-solidarity-act) [What Regulation (EU) 2025/38 sets up, the European Cybersecurity Alert System, the Cybersecurity Emergency Mechanism with the EU Cybersecurity Reserve and the incident review mechanism, how a company hit by a major incident can benefit, and what it means for managed security service providers.](https://pitch.law/academy/cyber-solidarity-act) ## Let’s talk Tell us what you’re working on. 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