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The Association has as non-profit purpose to: Promote the collective interests of the research funding and research performing organisations of Europe. It supports its members in their efforts to foster European research. It will strengthen the European research area through its direct engagement with key partners. In doing so, it will be informed by the scientific community in its reflections on policies, priorities and strategies. To this end, and provided that it is not contrary to the rules applicable to its members, the Association will conduct the following activities for the benefit of its members: • Support the work of its members and promote co-operation between them at both the policy and activity level. • Strengthen the scientific community as a third voice in the European research area, together with national governments and the European Commission. • Act to maximize the input of the members in the development of the European research area.

Lobbying Activity

Response to European Innovation Act

3 Oct 2025

Research and Innovation are strongly interlinked. The Innovation Act should enable the effective valorisation of research into innovation, with excellence as a key criterion for research assessment. Therefore, the objectives of this act should be built build on the foundation of supporting excellent research activities and sound ethical values. For this reason, it is crucial that the Innovation Act links closely with the upcoming ERA Act. The attached recommendations contribute to this call from the perspective of public, national European Research Performing Organisations and Research Funding organisations. Science Europe calls for applicant focused simplification, that do not compromise key European or academic values nor high ethical, sustainability, and inclusivity standards. It highlights that coordination should not be detrimental to R&I, and recommends that when a projects primary focus is R&I, its governance should remain under the remit of Horizon Europe, with policies tailored for R&I, rather than a 'one size fits all' single rulebook or non R&I-related competitiveness priorities. With regards to access to finance, funds should provide stability, but not limit innovation potential because of over-prescriptiveness by political objectives. With regards to private investment, it is important to coordinate with other instruments, de-risking, and to focus on sustainable growth. An autonomous Horizon Europe with links to the European Competitiveness fund, but not subjugated to it is key for innovation. It should support excellent fundamental research as the foundation of innovation, equitable collaboration within and beyond the EU, and blue-sky approaches, which serve as a catalyst for breakthrough innovation. Its high-risk, high-gain projects the introduction of which is welcome - should be de-risked using public funds. The act should continue to support the scaling up of innovative businesses and processes. In coordination with the Startup and Scaleup strategy. Talent attraction and retention is critical for innovation. Mobility-related barriers should be addressed with administrative simplification and incentivising better careers. From an R&I perspective, dedicated programmes for talent retention and attraction such as Choose Europe - are needed. This should not disadvantage other countries: instead of brain drain, brain circulation should be the goal. The provisions of the Innovation Act on talent attraction and retention should also be implemented in close coordination with the ERA Act. Talent retention can benefit from dedicated support for young/early career professionals and researchers. In addition to international talent circulation, the act should also foster mobility between academia and industry. Funds supporting stronger links, and the flow of talent between universities, research organisations and industry can support valorisation and commercialisation efforts. The impact of Research and Technology Infrastructures (RTIs) on Innovation should be maximised. The Innovation Act should link with the EU RTI strategy. RTIs should be aligned, and not compete against each other. Access to RTIs could be improved via trans-national and inclusive means. The one-stop-shop approach outlined in the strategy is a good direction. Access could be operationalised by involving RTIs in development, testing, validation and certification. SMEs, startups, and cross-border users, especially in less-developed regions, should have simple access. RIs should develop stronger connections with broader R&I priorities, such as research assessment and open science. The Innovation Act can align research and innovation policies. In doing so, it should support the entire pipeline that leads from fundamental research to innovation and valorisation of scientific knowledge. Linked to the ERA Act, the Innovation Act should contribute to the establishment of a balanced, holistic, open and collaborative European R&I ecosystem.
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Response to European Research Area (ERA) Act

10 Sept 2025

The new ERA governance has been characterised by more open and inclusive exchanges, including with stakeholders. This has led to increased ownership over EU policy and a successful Policy Agenda 202224. The ERA Act should build on the major developments driven by these policy interventions and the EUs Framework Programmes, as well as on support from the European Commission and Council, to further develop a coherent and holistic framework for European research. Major challenges still hinder progress towards realising a true, single, borderless market for research and innovation that fosters excellent science across Europe. The current policy instruments have not sufficiently addressed these structural challenges: Research and innovation investments still fall short of two key targets: dedicating 3% of GDP to R&I, set by the European Council in March 2002, and increasing public R&I funding to 1.25% of GDP, as set out in the Pact. Recent Eurostat data indicate slow progress in investments by EU Member States, with an average of 2.08% of GDP in 2013 increasing to 2.22% in 2023. However, significant differences exist between countries, with investments ranging from 0.5% to 3.6% of GDP. Additionally, most investment comes from the business sector. The cardinal values of the European Union, including those protected in its primary law, increasingly face challenges. Recent proposals to weaken Gender Equality Plans (GEPs) have raised alarm, and there is currently no action or structural policy that addresses sustainability in research in the ERA Policy Agendas. Other examples are: equality, diversity, and inclusion (EDI); academic freedom; and environmental sustainability. The ERA Act can be an opportunity to address these challenges and create a single market for excellent research, enabling the free movement of people, knowledge, and ideas. This process should follow an evidence- and needs-based approach to avoid mis- or overregulation. To that end, dedicated dialogues with the scientific community and its representative organisations should be held. Science Europe considers that the ERA Act should, first and foremost, aim to support research excellence and create a level playing field for the European Research Area. An ERA Act should strengthen the legal foundation for the full deployment of a single borderless market for research and the realisation of the fifth freedom outlined in the report by Enrico Letta Much More Than a Market. We consider that the ERA Act needs to foster and incentivise policies and initiatives that uphold and promote values that are core to research and that promote excellent research across Europe. Similarly, the ERA Act proposal should incentivise increased investments in research, including by supporting underperforming countries to strengthen their capacity. Such an approach would be better suited to driving progress than exclusively focusing on setting hard targets and obligations. Furthermore, the ERA Act must tackle the following sub-objectives: Enhance the protection of academic freedom in the European Research Area, without compromising the EU acquis or the rights established by the Council of Europe and the United Nations frameworks. Support international collaboration (both within the ERA and with international partners) and the free flow of people and knowledge. Improve inclusiveness and the accessibility of research, with a particular focus on promoting equality, diversity, and inclusion and open science. Support and reinforce the EU R&I ecosystem by creating opportunities for, and strengthening, the co-operation between universities, research centres, and businesses. Contribute to reducing the gap between European countries where large disparities in investment levels exist. Adopt a minimum standards approach, allowing national governments and stakeholders to implement more protective or ambitious policies or initiatives.
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Response to A European Strategy for AI in science – paving the way for a European AI research council

5 Jun 2025

Science Europe, representing national European research funding and research performing organisations, is providing input to the European Commissions Call for Evidence through the attached document. It recognises the need for a European Strategy for AI in Science that will remain relevant in the face of the rapidly evolving field of artificial intelligence, and looks forward to further contributing to the process, based on the expertise and experience of its Member Organisations.
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Response to European strategy on research and technology infrastructures

21 May 2025

Research Infrastructures (RIs) are of fundamental and strategic importance to the European Research Area. They are a vital component of both European and global research ecosystems, offering unique facilities and resources to the research community, supporting fundamental research on the basis of excellence and knowledge advancement. Strategically, they provide services that attract talent and boost competitiveness whilst also acting as a basis for international collaboration and cooperation. Connections between research infrastructures and other research-oriented facilities and resources can create added-value to research communities when funded, managed, and operated optimally. In this way, Technology Infrastructures (TIs) are also a key element of well-functioning and impactful R&I systems, often building upon fundamental research (including the advances made at RIs), scaling them for myriad potential applications. Excellence in research and innovation, therefore, requires top infrastructures of both categories, and necessitates collaboration and cooperation. As such, the initiative to reinforce and strengthen a European-wide strategy for RIs and TIs is timely and important, and Science Europe emphasizes the following key considerations: - Whilst strengthening links between RIs and TIs, it is vital that funding for RIs that enables fundamental research across all disciplines is ring-fenced and is not forced to compete with the support provided to TIs. - Investments in the facilities, resources, and services categorised as RIs must be adequate to develop new infrastructures according to the needs of research communities, whilst also allowing for the continued optimal use of existing infrastructures (including repurposing or decommissioning, where needed). - A life-cycle approach to RI planning, construction, and operation is essential. Guidelines to reduce environmental footprint and the promotion of openness and shared use of RIs, including through the promotion of secondary data use, are crucial, as highlighted in Science Europes Framework for the Environmental Sustainability of Research Organisations. - Optimising the management and use of infrastructures not only provides better value for investments but can also be a driver of more environmentally sustainable practices. Similarly, it is important that RIs have a funded pipeline of R&I activities such that facilities and resources are engaged on an on-going basis in R&I activities, ensuring they stay at the forefront of knowledge advancement and innovation. - Innovative access mechanisms such as clustered access, virtual access, and secondary data use should be considered as part of continued strategic approaches to the European RI landscape. - Greater synergies to be established between funding sources (national and international, public and private) to better serve research communities. The integration of contributions from private industrial partners into RI networks should be encouraged, as they not only bring valuable resources, but also expertise and innovation that can benefit publicly funded fundamental and applied research. - Stronger connections between research infrastructure strategies and other R&I policy priorities, including open science (through open access to research infrastructure processes and outputs, as an example) and the research assessment reform movement (by updating the evaluation processes used in merit-based access procedures in line with the current state-of-the-art). - A clearer and more coordinated approach to international cooperation towards a global RI and TI ecosystem that encourages collaboration wherever beneficial whilst also promoting strategic autonomy when necessary. Moreover, regional and national RIs should receive adequate support and recognition, in order to contribute to a truly continent-wide effective and efficient ecosystem, while always remaining capable of providing benefit to local communities and enterprises.
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Meeting with Signe Ratso (Deputy Director-General Research and Innovation)

16 Apr 2025 · Reflections on current state of the EU–US cooperation in research & innovation; importance to maintain an open, constructive dialogue with US partners; upcoming steps for ERA Act; FP10 perspectives.

Response to Evaluation of the Public Procurement Directives

7 Mar 2025

Science Europe (SE) represents 40 major public organisations that fund and/or perform excellent, ground-breaking research in Europe. As bodies governed by public law, the directives on public procurement are of direct relevance to our members operations. This response addresses one specific aspect of public procurement: green and circular public procurement, linked to SE's strategic priority of "Strengthening the role and contribution of science in tackling societal challenges", and the goal, stated in our Framework for the Environmental Sustainability of Research Organisations, to "promote environmental sustainability of research and research-related activities on the systemic level in Europe." As mentioned in the call for evidence, a revision of the directives on public procurement is an opportunity for the EU to promote its policy goals and objectives. The directives already state as one of their objectives "making the EU a more green, social and innovative economy." At the moment, according to the European Commission, "55% of procurement procedures use lowest price as the only award criterion for public contracts." Public procurement procedures that use environmental criteria would promote procurement of sustainable services, works, and supplies supporting the progression to sustainable practices as a key public policy objective. In the case of research and research-related activities, public procurement can be used to advance environmental sustainability in research organisations' operations. The Framework for the Environmental Sustainability of Research Organisations (2024) supports the use of green public procurement in research organisations. One of the suggested medium-term actions for research organisations is to "Include environmental criteria in the management practices of research organisations. In particular, promote sustainable procurement practices, circular and sharing economy of equipment and services linked to research and research-related activities, energy savings and use of renewable energy sources." In addition to achieving the objectives of the European Green Deal, green public procurement can have positive co-benefits for research organisations, such as: - Financial savings, e.g. linked to energy savings or shared facility models, - Increased resilience, e.g. to supply chain risks in cases of circular procurement, - Reputational benefits. On the systemic level, use of green public procurement practices can also increase awareness in the respective supply chains. Examples from several SE member organisations demonstrate successful implementation of green and circular procurement practices in research organisations (Survey Report: Appraising Greenhouse Gas Emissions of Research Organisations, 2024). Based on the above, we support mandatory consideration of environmental criteria in public procurement whenever feasible (also considering cost efficiency and current sectoral conditions), as well as the use of circular public procurement. Life-cycle costing, considering quality of performance and planned obsolescence, are tools that enable contracting authorities to determine the true cost of procured services, works and supplies over their lifetime (including their effects on the environment), and promote economic savings alongside greater environmental sustainability. For instance, environmentally responsible procurement practices can contribute positively to environmental protection and human well-being, reduce the need for adaptation measures, and may offer greater cost efficiency over the entire product life cycle. Environmental sustainability must also be considered in innovation partnerships. The impact of sustainable procurement practices should be thoroughly evaluated and communicated, considering the full life-cycle cost of products and services. Technical assistance and capacity-building measures for setting up sustainable procurement procedures need to be provided as necessary.
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Meeting with Philippe Froissard (Head of Unit Research and Innovation)

16 Jan 2025 · Exchange of view on the environmental sustainability of research and research-related activities and their possible reflection in policies of the next Framework Programme for Research and Innovation.

Response to Communication on the European Research Area Implementation

30 Sept 2024

A new and successful governance for the ERA With the updated approach to the European Research Area came substantially improved governance. In contrast to the previous period, during which stakeholder involvement was limited, the European Commission promoted openness to the active participation of pan-European organisations in the ERA Forum from the start. The Pact for Research and Innovation called on including the relevant civil society organisations in the ERA, which was successfully implemented. The realisation of the ERA will only succeed if it is based on the research community's needs. Science Europe, therefore, welcomes that both the Commission and Member States genuinely allowed the participation of stakeholders in the ERA Forum and its sub-groups. We commend, in particular, that active participation was not limited and that all debates were open to the stakeholder groups' representatives. It is also worth noting that both the Commission and Member State co-chairs of the Forum actively encouraged the inclusion and participation of our organisations. We also appreciate that this approach was reflected in the ERA Forum sub-groups. Substantial but unequal improvements to the EU policy agenda. Overall, the ERA policies have been sensibly more successful than in the previous time periods. The number and quality of the resulting initiatives and concrete outcomes mark an improvement that we strongly welcome. In this sense, the priorities and ambitions in the Pact remain valid, and the essence of the work is to be undertaken in subsequent policy agendas and their actions and related activities. Specifically, the implementation of the ERA actions on the Global Approach to Research and Innovation and Inclusive Gender Equality provides strong examples of the new ERA governance steering EU research policy in the right direction. Concretely, initiatives related to the Team Europe Approach, knowledge security, and the publication of the Zero-Tolerance Code of Conduct on Gender-Based Violence were significant achievements. In addition, the Multilateral Dialogues on Principles and Values generated much-needed exchanges between the EU and its international partners. This value is recognised in the Brussels Declaration, adopted on 16 February 2024. These examples demonstrate the added value of updated governance and the success of the ERA Forum and most of its subgroups. We also welcome the leadership of the Commission and Member State co-chairs and sponsors of the ERA actions included in the 2022-2024 Policy Agenda. Science Europe wishes to mention the Commission's Gender Sector, which demonstrated its essential role in EU policy and should be further consolidated as a Unit. However, despite its success, we regret that the ERA policy agenda failed to advance EU policy on important, transversal priority areas significantly. - Firstly, the policy agenda did not provide noticeable added value in areas such as Open Science and links with Research Assessment. Initiatives related to these topics were limited to activities already being implemented by existing structures, especially the Coalition on Reforming Research Assessment (CoARA) and the European Open Science Cloud (EOSC). Secondly, progress in some actions has been limited. Science Europe particularly regrets the minimal progress that has been made towards implementing the ERA action on academic freedomespecially in the context of global and European backsliding. In addition, where actions are being brought forward without a dedicated subgroup or informal structure, information sharing with the ERA Forum has been infrequent. Science Europe Europe is grateful to be able to participate in the new governance. We are fully committed to contributing to the European Research Area's implementation and ensuring its continued success. We are attaching our complete response to the present consultation.
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Meeting with Christian Ehler (Member of the European Parliament) and League of European Research Universities

11 Mar 2024 · Science and research policy

Response to Report on the application of the General Data Protection Regulation

7 Feb 2024

Public research-funding and research-performing organisations often collaborate and finance research projects with partners from different countries within and outside the European Union. These collaborations are usually established with multiple partners from the public sector, which involve the processing of personal data. Additionally, researchers collect, generate, and share data, including personal data, across borders with their international partners. Research organisations have developed structures, tools, and policies to ensure their activities comply with the GDPR. The 07/2020 Guidelines of the European Data Protection Board have also provided much-needed clarifications. However, many challenges remain. Joint Controlling vs. Separate Controlling The rules around controlling and processing data are interpreted differently by different organisations. This can create difficulties for organisations to reach an agreement on the controlling of data and necessary agreements. When GDPR applies, research-funding and research-performing organisations must define each partner's roles and responsibilities for all kinds of data processing in their collaboration agreements. This involves determining whether the data controlling is done together or separately for each case. Several factors must be considered to establish the appropriate agreement, including the nature of the shared data, the appropriate legal basis, the respective data flows, and the different roles fulfilled by the various partners. Much progress has been made in the application of the different types of controlling agreements, and policies have been put in place in research organisations. However, there is still a lack of unified understanding of when an organisation is a joint controller or even a controller at all. Organisations have adopted different approaches to determine when they are a controller or processor, which impact the agreements they have with international partners. Choosing and Applying the Right Tools Adequacy decisions confirm that a specific country offers an essential equivalent level of data protection. Only 15 countries have been recognised by the European Commission and for two of those (Canada and the United States) the decision only applies to commercial entities. As a result, research-funding and research-performing organisations have had to use additional tools in their collaborations. Standard Contractual Clauses (SCCs) have been introduced in collaborative agreements to comply with the GDPR. Joint Controller Agreements and Data Processing Agreements are also being used. However, the Schrems II Judgement of 16 July 2020, invalidating the EU-US Privacy Shield, has had wide-ranging effects on the applicability of SCCs and due diligence requirements for European organisations. Additional tools like Transfer Impact Assessments (TIAs) and Code of Conduct could prove useful. However, TIAs are difficult to conduct as relevant information might not be readily available to research organisations and understanding what measures to take to mitigate the identified risks remains challenging. In addition, Codes of Conduct, while promising, are still being developed. Collaborating with International Partners Many Science Europe member organisations have encountered difficulties negotiating with partners outside the EEA. In particular, many non-EEA organisations are reluctant to sign binding agreements on data protection. This is due to the reluctance to apply EU law to their activities and the technicity of GDPR agreements. Differences in legal and policy cultures also play an important role, with international partners perceiving that their EU counterparts are imposing their own legal rules on them while not being bound by theirs. There also can be difficulties in reconciling the legal obligations of EEA (stemming from GDPR) and non-EEA (stemming from national legislation) partners.
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Meeting with Christian Ehler (Member of the European Parliament) and CESAR Centro per lo Sviluppo Agricolo e Rurale

30 Jun 2022 · Horizon Europe and Union Budget

Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

20 Jul 2021

Artificial Intelligence (AI) is already widely used across all sectors and in all parts of society and it bears a lot of potential for research, innovation, and the economy. Science Europe, the representation of major national research funding and performing organisations, welcomes the fact that the European Commission (EC) intends to update its liability rules for AI. Clear EU-wide rules are important for both users and producers of AI systems from all sectors. A fragmented legal landscape with different national approaches would hinder cross-border collaboration and, consequently, innovation. The EC’s Inception Impact Assessment only focuses on the industry and business sectors, and does not take into consideration the important roles that research plays for AI and AI plays for research. Researchers and the organisations that fund and/or employ researchers will be impacted by any EU legislation regulating AI, as they are developers, producers, and users of AI systems. Researchers use AI to conduct research in any discipline, and research organisations increasingly use AI in research administration and management of projects and programmes. Science Europe would like to underline the following points: • Widen the scope of the impact assessment to include research: research organisations should be included in the impact assessment alongside industries and businesses as it should include all sectors involved in AI development and take all possible impacts into account when developing legislative proposals to regulate AI. • Strike a right balance to foster innovation and trust: Rules must be clear for the producers of AI systems so they know their obligations, and for users to have all relevant information at hand to identify who is liable. Science Europe agrees with the EC that liability rules must strike the right balance between legal certainty for both users and consumers and fostering innovation. Rules should not create an environment where developers and producers do not dare to search for innovative solutions. Legal certainty is needed to increase users’ trust in AI applications. • ‘Future-proof’ rules: The challenges that new emerging technologies present nowadays for liability rules will not cease to exist as there is no end to technological development. It is therefore of utmost importance that any legislative framework is ‘future-proof’. New legal frameworks have to be swiftly adaptable to new developments and their related risks. • Rely on existing expertise: Sound, unbiased AI systems heavily depend on being trained with high-quality, unbiased data. The research sector has a lot of experience on data management, with good practices and established standards in place. Learning from this experience can help ensure the availability of high-quality data. • AI and Open Science: Open Science, that is the sharing and re-use of research outputs, is strongly promoted by the EC, Member States, and research stakeholders across geographical and disciplinary borders. With an increasing amount of data available for researchers, there is also a growing need to have reliable systems to process large amounts of data. AI applications will therefore play an ever more important role in the research system. As with other legislative proposals in the digital field, it is necessary to ensure that EU legislation takes the needs, standards, and practices of the research sector into account and fosters Open Science. Science Europe Member Organisations have a vast experience as users and producers of data and data-processing applications. Their collective knowledge contributes to the capacity and efficiency of the European Research and Innovation system and serves society at large. Science Europe would like to offer its expertise and the extensive experience of its members to inform the upcoming legislation on AI.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

Access, interoperability, and the use of high-quality data are cornerstones of research and innovation. Science Europe, therefore, welcomes the initiative of the European Commission, as outlined in the European Strategy for Data from 19 February 2020, to create a single market for data that would enable the digital transformation of society through more and better access to data. Science Europe and its Member Organisations, major national public Research Funding Organisations (RFOs) and Research Performing Organisations (RPOs), strongly promote the sharing, interoperability, and re-use of data in research. Re-using data can have impacts that go beyond its initial purpose and is necessary to generate further knowledge by building on existing information. Science Europe welcomes the EC intention of increasing access and use of data to facilitate use by public and private actors and ensure positive effects for the use of data in the public interest. This includes the use of data for research purposes. We, therefore, appreciate the opportunity to comment on the Inception Impact Assessment for a Data Act and would like to draw the Commission’s attention to two aspects, both relating to the scope of the future legislation: 1. Which public sector bodies will be in the scope of the Data Act? The Inception Impact Assessment (IIA) for the Data Act does not indicate clearly which public actors will be in the scope of the future legislation. The section ‘Use of privately held data by the public sector’ broadly refers to the ‘public sector’ and to ‘data whose use are necessary to serve the public interest’. However, the following sentence in the same paragraph only refers to business-to-government (B2G) data sharing. This raises the question of which parts of the public sector the new legislation is aimed at. Many public RFOs and RPOs are public sector bodies according to their national legislation and they all fund and support research which is in the public interest, but they are not part of a government. As these organisations, and the researchers they employ and fund, play a vital role in fostering innovation in Europe, clarity on whether the research sector will fall under the scope of the Data Act would be welcomed. The Data Act should specify the characteristics of the ‘public bodies and entities acting in the public interest’ to provide legal clarity for the research and innovation community. 2. How will research and innovation be affected by the Data Act? While the IIA refers multiple times to the potential of data for innovation, research is only mentioned in the social and environmental categories of the preliminary assessment of expected impacts. Yet, it remains the main bedrock of education, innovation, and economic competitiveness. As research contributes to all the impact areas mentioned in the Inception Impact Assessment, any Impact Assessment in preparation of the legislative proposal for the Data Act should also assess the potential impact of the act on the research sector. The absence of substantial research considerations in the Inception Impact Assessment raises even more than the issue described under point 1, the question in how far research and innovation will be affected by the future Data Act. The research sector has vast experience in data generation, storage, curation and (re-)use. Taking into account its relevant expertise and knowledge, the research sector can contribute to making the European single market for data useful for the society and economy at large. Science Europe will be happy to participate in further consultation activities and provide input to inform the future Data Act.
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Response to Pact for Research and Innovation in Europe

12 May 2021

In line with Science Europe’s continued involvement in building the European Research Area (ERA), this paper provides input to the Commission’s Consultation on the preparation of the ‘Pact for Research and Innovation in Europe’. Science Europe appreciates the efforts of the ERA Forum for Transition in developing the Pact. Science Europe, bringing forward the perspective of the major national research performing and research funding organisations, supports the development of a Pact for Research and Innovation that includes R&I-related values and principles. It is crucial that these are implemented in a relevant way for the research activity in the ERA, meaningfully involving research communities, national governments, research organisations, and R&I stakeholders in the development and implementation of the ERA policies. Science Europe's full input is attached and available here: https://scieur.org/response-era-pact An ambitious Pact needs concrete commitments The roles of the European Commission, European Parliament, Council of the EU, Member States, and stakeholders should be clarified. Tangible and concrete commitments and objectives must be defined, according to their distinct responsibilities and capacities. In line with the principle of subsidiarity, Member States should provide adequate funding for R&I, which is key to achieving the ERA. The Pact should reaffirm the investment target of 3% of EU GDP dedicated to research and development, as well as the new 1.25% EU GDP public effort target to be achieved by Member States by 2030, as proposed in the Communication on ‘A new ERA for Research and Innovation.’ Linked to the setting up of principles and values, the commitments should include the revision and update of some existing codes and policies, such as European Charter & Code for Researchers, European Code of Conduct for Research Integrity, or European charter of access to research infrastructures. In addition, adequate new policies and legislative initiatives should be proposed. To be achieved, the ERA needs to be inclusive The ERA as a political vision for Europe should consider that not all European countries are EU Member States, and that, together, we are able to actively and constructively contribute to a European research ecosystem that is globally competitive. Science Europe calls for the countries associated to the EU Framework Programmes to be included in the development process of the ERA. In particular, Switzerland and the United Kingdom, as key players in ERA, should be part of the process defining the values and priorities. Science Europe considers that a structured and systemic approach to stakeholders’ involvement in both the development of the Pact and the ERA governance would be beneficial for ERA. It would facilitate constructive discussions and greater ownership of the Pact for Research and Innovation (R&I) by stakeholders. ERA needs to be built on research values The Pact for Research and Innovation needs to reflect the values that underpin the research ecosystem. In this context, Science Europe considers that certain principles are essential to research and the ERA. These include, but are not limited to: • Research excellence and scientific quality. • Academic freedom and institutional autonomy. • Equality, diversity and inclusion. • Ethics and research integrity. • Openness. • Transparency. • Free circulation of researchers and ideas. Science Europe considers that the following priority areas should be at the core of the Pact and ERA, and that concrete and tangible actions need to be defined to advance progress in them: • Improving access to research excellence and reducing the geographical divide • Research careers • Research culture • Open Science • Science communication • Research Infrastructures • Gender equality and inclusion • Research assessment • Synergies between the national and EU levels.
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Response to Requirements for Artificial Intelligence

10 Sept 2020

Science Europe welcomes the opportunity to react to the European Commission’s (EC) Inception Impact Assessment for a ‘Proposal for a legal act laying down requirements for Artificial Intelligence’. Science Europe Member Organisations, major national research funding (RFOs) and performing organisations (RPOs), are important users and producers of data. As such they can contribute to and be impacted by Artificial Intelligence (AI) developments in many ways. Science Europe considers that the implications of an AI legislation on the research and innovation (R&I) sector are currently not sufficiently taken into account. The importance of AI for R&I The importance of AI for R&I is growing quickly. Future EU legislation on AI could have an impact on the activities of RPOs and RFOs, including: • Research on the development of AI systems; • Implementation and embedding of AI methods in, possibly, all fields of research; • Use of AI in research administration and governance, for example to identify reviewers for grant applications or pre-assess project applications. The EC analysis of the answers to the consultation in spring 2020 shows that fostering R&I on AI is of great importance to many respondents. It is therefore surprising that the EC Inception Impact Assessment from 23 July 2020 does not refer to the R&I sector at all and, instead, is purely business oriented. Science Europe would like to see R&I properly addressed in EU legislation on AI. In this respect, Science Europe invites the EC to take into account the following three points: 1. Developers’ and users’ liability The question of liability for developers and users of AI systems does not only concern industry, as implied in the Inception Impact Assessment. Researchers are important contributors to the development of AI systems. The EC should ensure that potential EU legislation tackling liability issues provides the necessary safety guarantees to both users and developers of AI systems while at the same time fostering R&I on AI. 2. Links between AI and Open Science Science Europe members define and implement numerous Open Science policies, including Open Access to research publications and research data. Science Europe promotes Open Science policies and, moreover, Science Europe and some of its members are actively engaged in the development of the European Open Science Cloud (EOSC). EOSC will make data available on a large scale and across borders for researchers to use, based on the principle as open as possible as closed as necessary.’ The increased availability of data will lead to many researchers using AI technologies for data analysis. Healthy, unbiased datasets and data protocols are needed for researchers to produce quality research. The EC needs to ensure that future legislation on AI supports Open Science policies. 3. Solid scientific results depend on robust and reliable data Researchers using AI systems to conduct their research, as well as research organisations using AI in their daily business for research administration and governance, need to be sure that the data and the AI systems they use are reliable. The quality of results provided by AI applications depends on robust data collection methodologies and tools, transparency of data sets, as well as monitoring and curation of data sets and algorithms. This is critical to ensure that AI systems do not cause erroneous results because of biased data. The EC services should take these aspects into account when considering a potential legislative or soft law approach on AI and ensure coherence with other legislative projects such as the proposal on European data spaces. Science Europe would be happy to collaborate with the EC by providing further input from its member organisations and their expertise on AI in the R&I sector. Future EU legislation on AI needs to strike the right balance between safeguards for users and developers of AI systems and a legal environment that fosters R&I.
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Response to Legislative framework for the governance of common European data spaces

31 Jul 2020

Science Europe welcomes that the European Commission consults stakeholders on its Inception Impact Assessment for a ‘Legislative framework for the governance of common European data spaces’. Science Europe Member Organisations, major national research funding and performing organisations, have a vast experience as users and producers of data. Science Europe believes that sharing their collective knowledge with the Commission will help strengthen the European research and innovation (R&I) landscape and serve society at large. Science Europe would like to draw the attention to four main aspects related to the R&I sector. 1) Importance of cross-sectoral data-sharing for research and innovation: Science Europe is pleased to note that with the upcoming legislative proposal on the governance of common European data spaces, the Commission intends improve cross-sectoral data access, not only for the economic sector, but also for R&I. Data from all sectors have cross-cutting value for R&I and consequently for society at large. The current COVID-19 crisis demonstrates the importance of data. They not only support health research, but are also essential, for example, to counter-balance fake news and address the social and economic challenges caused by the crisis. 2) Horizon Europe funding needs to benefit the research and innovation sector: Science Europe takes note of the Commission’s intention to invest in modern data infrastructures with money from, among other sources, the future Framework Programme for R&I, Horizon Europe. Science Europe promotes data accessibility and interoperability through federated infrastructures, as demonstrated by its support and engagement in the development of the European Open Science Cloud (EOSC). Modern data infrastructures are necessary to effectively maximise the use of public investments. These foster the use and re-use of data, within and across sectors, thus increasing their value. It is crucial to ensure that any investments funded by Horizon Europe primarily benefit the R&I sector. 3) Maintain sectoral data-sharing standards while ensuring interoperability: Science Europe continuously emphasises the importance of defining appropriate rules and standards for access, use, and re-use of data. The key issue at hand is to ensure interoperability among data spaces without relaxing sectoral data-sharing standards. Highly data-dependent sectors, such as the R&I sector, already have well-functioning standards in place. It is important to respect these existing standards and the authorities should avoid introducing new standards that are too broad. In the R&I sector, the FAIR principles (making data findable, accessible, interoperable, and re-usable) as well as the principle ‘as open as possible, as closed as necessary’ are well-established among researchers and research institutions. 4) EOSC as central point for standard setting and best practice sharing in research and innovation: The need and purpose of creating new bodies to exchange best practices and issue guidelines should be assessed sector by sector. An overview of central points for all data spaces should be kept to guarantee coherence at EU level. In the R&I sector, EOSC was purposefully established as the federation of existing infrastructures, instead of creating new ones. Some key principles and lessons learned can be used in developing bodies for other sectors, such as the essential conditions for interoperability and engagement with all types of potential users from an early stage. In the R&I sector, EOSC will allow researchers to use and re-use data, and help stakeholders exchange best practices and issue guidelines for data sharing.
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