Deutsche Forschungsgemeinschaft
DFG
The DFG is the central self-governing research funding organisation in Germany.
ID: 760465913924-94
Lobbying Activity
Response to European Framework for Science Diplomacy
3 Nov 2025
The EU currently lacks a comprehensive policy addressing activities in the field of science diplomacy. The European Framework for Science Diplomacy could make a helpful contribution in this regard. From the perspective of the German Research Foundation (DFG), the central self-governing research funding organisation in Germany operating at various international levels, the following conditions need to be met: (1) The Framework should clearly define and delimit the scope of activities which science diplomacy entails. The DFG recommends using the AAAS definition of science diplomacy, differentiating between "science impacting diplomacy" and "diplomacy im-pacting science". This would be sufficient to cover the decisive ways in which science and diplomacy interact, while at the same time avoiding a too broad conception, which runs the risk of depriving the concept of any meaning. (2) Throughout the last decades, the outcomes of science diplomacy efforts have shown how beneficial research cooperation can be for diplomacy if political relations are strained and cooperation is difficult to achieve in other sectors and channels. But this will only be the case if research collaborations continue to be based on scientific criteria such as the promotion of research excellence in particular fields and if they respect scientific values such as academic freedom, research integrity and ethical standards. Political utility must never be the only reason for promoting research cooperation in order for science diplomacy to work. The integration of science into diplomatic strategies of the EU and its Member States therefore needs to be carefully initiated and appropriate. (3) At the same time, it is important that diplomacy also considers the specific scientific perspective when severing political ties with other countries. Sudden diplomatic shifts such as breaking off diplomatic relations with a particular country should not automatically lead to breaking off scientific relations at the same time in order for science diplomacy to fulfil its purpose. This will enhance the resilience of international research systems, which is both beneficial for the scientific enterprise and the political relationship in the long run. (4) The continued interactions between science and diplomacy require an overarching strategy, guidelines and transparent rules. The Framework could serve this purpose by establishing a code of conduct on science diplomacy for research cooperation in a geopolitically challenged world. This code of conduct should provide guidance on how to enhance synergies between the scientific strive to foster excellent research collaborations and political interests with regard to the relationship with particular countries. This guidance could provide real and practical added value. However, it should be ensured that the Framework does not impose any new bureaucratic burden on researchers. (5) The implementation of the Framework and its code of conduct requires overarching coordination of science and diplomacy stakeholders. The Framework should therefore contribute to the establishment of platforms for regular exchanges between the European Commission, national ministries and research organisations on topics related to science diplomacy. The Commission should also explore ways of how to incentivise the implementation of the Framework by financial means. (6) The Framework should also incentivise capacity-building instruments such as scientific trainings of diplomats and diplomatic trainings for researchers. Moreover, it should encourage the EU and its Member States to post science attachés in their embassies around the world. These positions could also provide intersectoral mobility in order for persons from the scientific community to act as science attachés of their countries for a restricted period of time and vice versa. Please find the full statement of the DFG attached for more details.
Read full responseResponse to European Research Area (ERA) Act
10 Sept 2025
The German Research Foundation (DFG), as the central self-governing research funding organisation in Germany, very much welcomes the European Commissions initiative to address the remaining challenges for the full implementation of the European Research Area. While a legal act on the ERA can make a real difference in overcoming existing structural barriers, it also contains a number of risks that must be carefully addressed. The DFG would therefore like to make the following proposals regarding the design of the ERA Act: (1) To accommodate national particularities and ensure flexibility in the design, the ERA Act should take the form of a directive. (2) The ERA Act should target those fields in which the ERA Policy Agenda and other non-legislative measures have had only limited impact so far, including investment targets in the Member States, a uniform visa regime for researchers, common standards for employment and working conditions, facilitated portability of social security entitlements and simplified recognition of qualifications. (3) The ERA Act should clearly separate political from science-driven framework conditions for research and ensure that the latter remain subject to academic self-governance in order to avoid overregulation of key science-driven processes. Such framework conditions should only be referenced as key enabling conditions for the European Research Area, referring to the responsibility of the research community in defining and shaping them. (4) With respect to open science, the ERA Act should establish a legal framework that guarantees researchers digital sovereignty and establishes science-led governance, financing and operation of research infrastructures for data, publications and software. (5) Legislation on the freedom of scientific research should be designed solely as a defensive right for researchers and their institutions against state intervention. It must not lead to administrative hurdles for scientific work, particularly in the area of international cooperation with researchers outside the EU. It should introduce EU-level academic freedom checks in the impact assessments of any new legislative proposal. As the freedom of scientific research is a fundamental prerequisite for the existence of the European Research Area, it should be regulated through a separate legal act, also taking the form of a directive. (6) The ERA Act should establish a harmonised legal framework for international cooperation of academic stakeholders. (7) Overall, the drafting processes for both the ERA Act and a legal act on the freedom of scientific research should not impose any new bureaucratic burdens on researchers. Please find the full statement of the DFG attached for more details.
Read full responseResponse to EU Life sciences strategy
11 Apr 2025
The European life sciences sector is facing increasing systemic pressures resulting from excessive regulatory complexity. While robust regulation remains necessary given the sensitivity of topics such as patient data, animal experimentation, and genetic resources, recent developments suggest a clear trend toward overregulation. This has led to disproportionate administrative burdens, reduced research activity in certain fields combined with a decline in academic career choices, particularly within Higher Education Institutions (HEIs). The repercussions are multifaceted: educational structures are being dismantled, innovation pipelines are weakening, and industry is challenged to experience both regulatory obstacles and a dwindling supply of qualified graduates. Of particular urgency is the need to reform regulatory processes in areas such as research ethics, data protection, animal welfare and access benefit sharing. These domains are increasingly characterised by fragmented and bureaucratically onerous frameworks that complicate both fundamental research and translational efforts. Animal research, while already tightly regulated, must be better differentiated in policy discourse: alternative methods, while promising for standardised safety testing, cannot yet replace animal use in hypothesis-driven basic research. Preserving scientific freedom including ethical and methodological autonomy is essential for sustaining Europes competitiveness. Furthermore, the legal uncertainties arising from the heterogeneous implementation of the Nagoya Protocol continue to obstruct international academic collaboration, particularly in biodiversity research. Harmonised definitions of key legal terms such as "genetic resources" and "utilisation", as well as the development of EU-level standard agreements with provider states, would significantly enhance legal clarity and facilitate access and benefit-sharing (ABS) compliance. The recent CBD COP 16 decision on establishing a multilateral mechanism for Digital Sequence Information (DSI) presents an opportunity to streamline ABS governance across agreements, which is urgently needed to prevent further regulatory fragmentation. In addition, a revised and science-compatible regulatory framework for plants obtained by New Genomic Techniques (NGTs) is required to enable the practical cultivation of NGT-derived crops within the EU. The proposed NGT-1/NGT-2 classification, while not perfect, represents a pragmatic foundation for progress and should not be undermined by scientifically unfeasible measures, such as mandatory labelling where detection methods are lacking. Lastly, addressing these structural challenges will also require renewed financial commitment. With many EU member states falling short of the 3% GDP R&D investment target, a well-resourced and targeted EU Framework Programme for Research is essential. For further details please find attached the DFG's full feedback to the initiative of the European Commission regarding an EU life sciences strategy.
Read full responseResponse to Commission Roadmap to phase out animal testing
14 Oct 2024
It is the perspective of the DFG's Senate Commission for the Investigation of Health Hazards of Chemical Compounds in the Work Area (MAK Commission) that the numerous methods grouped under the term NAMs, short for New Approach Methods (e.g. in vitro methods using cell cultures or modelling) are very useful for determining the hazards of substances and for group assessments (so-called "read across"). However, living model organisms will continue to be necessary to determine quantitative risk assessment and limit derivation (risk) in relation to human health (e.g. at the workplace) and to develop the safe handling of a substance. What is more, we still need to combine findings from differing, complementary methodological approaches. The MAK Commission has been commissioned by the DFG to merge the existing knowledge relating to important hazardous substances at the workplace, to develop recommendations for limit values based on this knowledge, and to describe measurement methods for complying with these limit values. In this way, the Commission provides an independent scientific basis for the regulatory determination of limit values in Germany and beyond. In doing so, it draws on all available data from studies on human, animal or in-vitro, in-silico models as well as epidemiology studies. All available data undergo a thorough quality control based on recognised scientific standards. Models or methods in general are subject to limitations. This applies equally to methods to study hazardous substances that do not involve animal testing. NAMs have been used for a very long time to study hazardous substances and their effects. It is a firmly established principle in research that methods obviating the use of living organisms are to be systematically advanced as a central aspect of research ethics. Standardisation and validation are likewise important scientific principles, as is the identification of the limitations of models and methods. For further information please find attached the full statement of the MAK Commission on the current and future role of NAMs in the science-based derivation of limit values.
Read full responseResponse to Communication on the European Research Area Implementation
30 Sept 2024
The DFG very much welcomes the proposed communication of the EU Commission on the European Research Area (ERA). Overall, the DFG is of the opinion that the introduced changes have contributed to revamping the ERA: The establishment of a more structured and systemic governance structure has contributed to keeping the ERA on the agenda of all actors involved on both national and EU level. The inclusion of non-EU countries associated to the EU Framework Programmes in the ERA governance has also been very positive. Moreover, the inclusion of stakeholders from the research community through the ERA Forum has improved considerably since its establishment. Major steps in the implementation of the new ERA have already been taken in some policy realms with real European value. At the same time, the DFG would like to underline a number of challenges for the ERA that still remain: The new governance structure has not been able to clarify the roles and responsibilities of the involved actors with regard to implementing the ERA in a satisfactory manner. Making national research investments and reforms a priority in the Pact for Research and Innovation has overall not contributed to increased investments by member states. The selection of actions for the first ERA Policy Agenda 20222024 has not followed the logic of the Pact priorities so that nine actions have focused on the deepening of the internal market for knowledge, whereas the establishment of a monitoring system has remained the only action to be implemented under the pact priority research investments and reforms. The intervention level of the different actions has also been too diverse. The establishment of a number of monitoring mechanisms has placed another layer of bureaucracy on top of the national monitoring mechanisms already in place. The DFG would therefore like to make the following proposals as to how the ERA could be strengthened further in the coming years: The priorities of the Pact for Research and Innovation in Europe should be reassessed so that they actually reflect the needs of the research community. For example, Enrico Lettas proposal for a 5th freedom to enhance research, innovation and education in the single market will only become a reality when the future ERA also includes those framework conditions for research that are negotiated in other sectors, e.g. with regard to mobility of researchers or data access. Future ERA policy agendas should dare to set priorities. A policy agenda for three years does not need to cover all relevant research policy themes. It should focus on those areas whose inclusion in the ERA can provide real added value. The DFG therefore welcomes the attempts to differentiate between long-term structural policies and short-term policy actions in the second ERA Policy Agenda 20252027. Actions falling under these categories need to be treated differently with regard to their expected outcomes and deliverables. Future ERA policy agendas also need a more flexible approach with regard to the inclusion of stakeholders from the research community in order to become more inclusive and to avoid duplication of efforts done at other levels of the research system. Resources should not only focus on what is feasible, but where they provide real added value. The time intervals for the various monitoring mechanisms should therefore be extended so that, for example, country reports are only published every third year. Additional data should only be collected if it is not already provided by existing datasets on a national level. So far, the EUs approach for a new ERA has presented research policy primarily as an implementation tool for other EU policies and priorities. While this is certainly true, it would help to establish a truly functioning European Research Area if the significance of research and the needs of the research community were taken as a starting point. Please find the full statement of the DFG attached.
Read full responseResponse to Options for support for R&D of dual-use technologies
30 Apr 2024
The DFG welcomes the possibility to provide comments on the European Commission's White Paper about its future approach to research with dual-use potential. The DFG funds primarily basic research. When it comes to research with dual-use potential, the DFG therefore focuses on making applicants aware of the risks of research with dual-use potential and ensures that these risks are dealt with adequately. It is not its primary objective to enhance research with dual-use potential and strengthen synergies between civil and defence research. The DFG's risk-based and case-by-case approach on research with dual-use potential involves the following steps: (1) First, all applicants need to confirm that they comply with good scientific practice. According to guideline 10 of the DFG Code of Conduct Guidelines for Safeguarding Good Research Practice, this includes both compliance with legal requirements relevant for dual-use research (e.g. the provisions of EU regulation 2021/821 on the control of exports of dual-use items and technology) and maintaining a continued awareness of the risks associated with the misuse of research results in general, paying particular attention to aspects associated with dual use. (2) Second, all applicants are asked to self-assess whether their research projects fall under the category of research with dual-use potential. (3) Those applicants, whose research projects according to their own assessment fall under the category of research with dual-use potential, are required to perform a risk-benefit-analysis in order to confirm that the potential benefits of the research results outweigh the possible risks of abuse. Moreover, the project description should include measures for risk minimisation. (4) If these conditions are met, proposals for research projects with dual-use potential can be funded by the DFG. In the DFG's view, a flexible, risk-based and, wherever possible, case-by-case approach for research projects with dual-use potential would also be beneficial on EU level irrespective of the choice for one of the three suggested options to enhance support for research with dual-use potential in the White Paper. The DFG further suggests the following guidelines for EU support for research with dual-use potential: (1) Civil research should continue to be clearly distinguished from defence research in the relevant legal texts and in the evaluation process of submitted proposals for EU funding also after enhancing synergies between both forms of research. Enhancing synergies also means funding civil applications of defence research with dual-use potential by means of the European Defence Fund. (2) The Commission should provide guidance for applicants to help them assess whether their projects are to be categorized as research with dual-use-potential. The ultimate decision whether their research should be categorized as research with dual-use potential should lie with the researcher(s) who submit(s) a proposal. (3) Applicants whose research projects have a dual-use potential should be asked to devise and implement adequate and project-specific security measures in order to protect their research from a possible abuse. These could entail delayed publishing of research results or restriction of access to research results that are particularly sensitive. (4) If option 2 of the White Paper is chosen, the exclusion of third countries from parts of the framework programme should be limited to the necessary minimum, and a case-by-case approach for relevant project proposals should be preferred, in order not to discourage international cooperation. Finally, while the debate about enhancing research with dual-use potential has to be pursued, measures taken must not come at the expense of sufficient and adequate funding for basic research. This principle should apply for the negotiations on the next EU Framework Programme for Research and Innovation as well as for those on the next Multiannual Financial Framework.
Read full responseResponse to Report on the application of the General Data Protection Regulation
7 Feb 2024
Die Deutsche Forschungsgemeinschaft (DFG) finanziert als nationale Forschungsförderorganisation gemeinsame Forschungsprojekte mit Partnern aus verschiedenen Ländern innerhalb und außerhalb der Europäischen Union. Dies schließt in der Regel die Verarbeitung personenbezogener Daten ein. Infolgedessen hat die Datenschutz-Grundverordnung (DSGVO) einen starken Einfluss auf die Art und Weise, wie Forschung - und Forschungskooperationen - implementiert und durchgeführt werden. Forschungsfördereinrichtungen haben Strukturen, Instrumente und Strategien entwickelt, um sicherzustellen, dass ihre Aktivitäten mit der DSGVO übereinstimmen. Die Leitlinien 07/2020 des Europäischen Datenschutzausschusses haben zwar dringend benötigte Klarstellungen gebracht. Dennoch bleiben viele Herausforderungen in der Praxis bestehen. Die DFG fordert die EU-Kommission, den EU-Rat und den Europäischen Datenschutzausschuss insbesondere dazu auf, (1) die verfügbaren Leitlinien zu überprüfen und gegebenenfalls zu aktualisieren, (2) klare Hinweise darauf zu geben, welche Formen von schriftlichen Vereinbarungen verwendet werden können, um die Einhaltung der DSGVO zu gewährleisten, und wann diese Vereinbarungen abgeschlossen werden müssen, (3) die Entwicklung sektorspezifischer Verhaltenskodizes, die den Bedürfnissen der Forschungsförderung, Forschung und Innovation im Rahmen der internationalen Zusammenarbeit Rechnung tragen, zu unterstützen, (4) Organisationen bei der Durchführung von Transfer Impact Assessments (TIAs) zu unterstützen, (5) Standardvertragsklauseln (SCC) zu überprüfen und ihre Verwendung - einschließlich ihrer Aktualisierung, falls erforderlich - zu klären, (6) die Sensibilisierung für Fragen im Zusammenhang mit der DSGVO in ihre politischen und politischen Diskussionen mit internationalen Partnern einzubeziehen, insbesondere im Zusammenhang mit Forschung und Innovation, sowie (7) Leitlinien für die wirksame Kommunikation der Anforderungen der DSGVO und die Notwendigkeit und Relevanz ihrer Umsetzung in internationalen Abkommen bereitzustellen. Weiterführende Hintergründe zu den einzelnen Aspekten können der Stellungnahme anbei entnommen werden.
Read full responseResponse to Enhancing research security in Europe
19 Dec 2023
The DFG welcomes the initiative to establish guiding principles for responsible internationalisation at EU level. The best research is produced when researchers work together across national boundaries. However, the potential risks of such cooperation need to be taken seriously and carefully reflected. Responsible internationalisation should be guided by the following principles: (1) Risk assessments in research projects involving international cooperation should not focus exclusively on the adherence to legal regulations. Instead, the potential risks of a project should be assessed in a comprehensive way creating the possibility to balance them against the anticipated benefits of the planned research cooperation. (2) The need for a risk assessment should not discourage researchers from engaging in international cooperation at all. Therefore, an informed case-by-case risk assessment is preferable to a general and too rigid and detailed assessment framework for research projects. The more serious a projects risks, the more important it should be for the proposal to address them. Conversely, if it is evident that there are no discernible risks, a brief explanation in the proposal should be sufficient. (3) In line with academic freedom and institutional autonomy, it should be the researchers and research institutions themselves to make the final decision whether or not to engage in international cooperation. In September 2023, the DFG has published recommendations for its applicants and reviewers how to deal with risks in international research cooperation in funding applications (https://www.dfg.de/resource/blob/289704/585cb3b48bb8e9f5b6e57e0e0a0d700e/risiken-int-kooperationen-en-data.pdf). They include eight questions in order to support applicants in their assessment of risks and benefits of their international cooperation. Applicants for funding are requested to present this risk assessment in their funding proposals as part of the accompanying information. Reviewers and decision-makers are asked to assess the plausibility of the applicants risk-assessment and proposed measures in dealing with identified risks as laid down in the proposal. While cooperative ventures should generally be pursued if the risks identified are handled responsibly, it may be appropriate in individual cases to refrain from cooperating with certain individuals or institutions, from implementing certain projects, or from funding them.
Read full responseMeeting with Karsten Lucke (Member of the European Parliament)
5 Dec 2023 · NGTs
Meeting with Christian Ehler (Member of the European Parliament) and Helmholtz-Gemeinschaft Deutscher Forschungszentren e.V. and
29 Nov 2022 · European Research Area
Meeting with Günther Oettinger (Commissioner) and Max-Planck-Gesellschaft zur Förderung der Wissenschaften and Hochschulrektorenkonferenz
5 Apr 2016 · education/research