Vereniging Universiteiten van Nederland
UNL
Universities of the Netherlands represents the interests of the 14 Dutch research-intensive universities at national and international level.
ID: 994694795829-46
Lobbying Activity
20 Nov 2025
Universities of the Netherlands (UNL) values the opportunity to contribute to this consultation for the proposal for the Erasmus+ programme 2028-2034 within the next Multiannual Financial Framework (MFF). We especially welcome the confirmation that Erasmus+ will remain an independent, self-standing programme and that current programme priorities will be continued. Predictability and continuity of the budget are crucial to ensure a sustainable, ambitious and inclusive future for the Dutch universities participating in Erasmus+ projects. UNL appreciates the proposed increase of the budget of the new Erasmus+ programme as compared to the current budget. It is an important and necessary step forward. However, UNL is very concerned this budget, in its proposed form, will be insufficient to deliver on the considerably expanded programme's ambitions for education and training, mobility and skills. The proposed programme will combine the existing Erasmus+ programme with the European Solidarity Corps. We understand the benefits of combining programmes with shared goals, however, it is important to clarify the budgetary implications of this proposal for universities' participation in the Erasmus+ programme. We therefore urge the Commission to double the budget of the next Erasmus+ programme in order to expand accessible and impactful learning mobility and inclusion for all, to meet increased expenses for universities (e.g. personnel costs and higher grants), and to ensure the success of the new programme. In all of this, learning mobility must remain the core action of Erasmus+ and receive increased funding. Budget increase is also needed to secure a clear direction and investment path for the alliances under the European Universities Initiative. Without this, this promising initiative risks remaining project-based and fragmented rather than enabling alliances to become permanent pillars of the European Education Area. The new Erasmus+ programme offers opportunities for international cooperation on themes that are important for Europe. We therefore consider it positive that the alliances fall under Erasmus+. In addition, UNL appreciates the reference to the Alliances in the draft proposals for Horizon Europe, as well as in the ECF proposal. This represents a significant improvement over the current programme and offers promising opportunities for greater synergy between these programmes and related co-financing schemes. To further develop the sustainability of alliances without hindering cooperation and innovation, we recommend flexibility in funding requirements to ensure stability and growth until self-sufficiency is achieved, realistic expectations and aims of alliances, and specific, additional funding for innovative activities. For the future of the alliances, predictability, sustainability, flexibility, and autonomy are crucial. Members of UNL are concerned there will be less funding for capacity-building projects because other priorities will take precedence. The proposed simplification of the structure and focus on mobility and capacity building are causing confusion and uncertainty about the future of existing successful action lines. We emphasise the importance of the budgetary continuation of Erasmus Mundus and recommend grants be continually made available beyond the focus on strategic areas. There is also hardly any reference to sustainability and the Sustainable Development Goals in the proposal, while these are essential for addressing global challenges and are especially relevant in collaboration with third countries. Finally, the implementation of the programme urgently needs to be simplified to significantly reduce the administrative burden on institutions and participants. An important point of attention is to continue to focus on removing legal and administrative barriers to transnational cooperation in order to develop new joint programmes and infrastructures. Our full reaction is attached.
Read full responseResponse to EU’s next long-term budget (MFF) – EU funding for competitiveness
6 Nov 2025
Universities of the Netherlands (UNL) welcomes the ambition of the European Commission to strengthen the Unions long-term competitiveness and resilience through the creation of the European Competitiveness Fund (ECF). We note that the proposal requires further clarification, and concerns around the inclusion of key actors and disciplines must be addressed. Universities play a crucial role in the knowledge ecosystem that underpins Europes economic and societal strength, and we therefore value the opportunity to provide input on this important proposal. The proposal stresses synergies between the ECF and Horizon Europe. From the perspective of the research and innovation community, it is essential that the relationship is carefully designed. Horizon Europe should remain the leading program for excellent research and collaborative innovation. The ECF must complement this role, focusing on industrial policy and providing additional support for research, ideally by transferring funds to the pillars within FP10. Strong and transparent governance is indispensable. Clear responsibilities between the European Commission and the Member States are necessary to ensure legitimacy and efficiency. The Commission should work in close partnership with the Member States and partners from the knowledge sector and industry. All these actors should have a meaningful role in shaping the priorities, implementation and continued development of the ECF. The four proposed windows of the ECF address key areas, but competitiveness cannot be limited to technology and industry. It equally depends on social sciences, effective public policy, and societal resilience. Social and technological innovation reinforce one another: progress in governance, participation, and behaviour is essential for innovation to deliver public value. SSH research underpins democracy, sustainability, and social cohesion core elements of Europes competitiveness. We therefore call on the ECF and FP10 to recognize and fund social innovation as an equal counterpart to technological innovation, ensuring a balanced and comprehensive approach to Europes industrial and societal competitiveness. The proposal must provide greater clarity on how resources will be distributed, what the eligibility criteria are, and how different actors universities, SMEs, large firms, and public institutions can access support. While these topics will gain greater clarity as the programme is implemented, transparent rules for allocation and evaluation at the earliest stage will be key to ensuring that the ECF enjoys broad support and that funding goes to projects with the highest added value. Competitiveness starts with people. Europes capacity to innovate depends on the quality of its education, the strength of its universities, and the vitality of its research base. Fundamental, curiosity-driven research is the foundation for long-term competitiveness. While high-TRL research is crucial for its ability to deliver immediate societal results, many of the greatest breakthroughs of the past decades have originated in fundamental science. Sufficient financing for the entire innovation pipeline is essential to enable long-term competitiveness: from training and upskilling students and researchers, financing all types of research, and supporting knowledge transfer and spin-offs. UNL appreciates the ambition of the Commission to create a coherent framework for competitiveness. To succeed, the ECF must clearly distinguish its role from Horizon Europe, establish transparent and streamlined governance, adopt a broad and inclusive view of competitiveness, and invest in the entire talent and innovation pipeline. Crucially, sufficient funds should be available to invest in cutting-edge research that ensures Europes long-term competitiveness. By embedding these principles, the ECF can become a powerful instrument to reinforce Europes knowledge base, industrial strength, and societal resilience.
Read full responseResponse to EU’s next long-term budget (MFF) – EU funding for competitiveness
6 Nov 2025
Universities of the Netherlands welcomes the Commissions proposal for a decision to establish Horizon Europe for the period of 2028-2034. The recognition of R&I as central to Europes prosperity, competitiveness and strategic autonomy is positive, as is the decision to maintain FP10 as a standalone programme with its own legal base. At the same time, clarification and various improvements are required to ensure FP10 delivers on its objectives. The proposed budget of 175 billion is ambitious, yet once corrected for inflation risks falling far short of the doubling it is presented as. To strengthen competitiveness and address societal challenges, UNL calls for a move towards 200 billion in line with the Draghi report. This figure should be spent exclusively on R&I activities and should under no circumstances be diverted to other objectives. The manner in which this funding is spent also matters: simplification, flexibility and efficiency are excellent objectives, but we emphasize that expanding lump sum funding and making use of personnel unit costs increases administrative burdens and reduces accessibility of Horizon funding. Excellence must be the prime evaluation criterion, as expressed in Article 25. Reports that this article is being changed by the Council of the EU are highly concerning. For Pillar II, governance should balance the role of the Commission and Member States, while ensuring strong involvement of scientists, universities and research offices. The regulation underplays the importance of Social Sciences and Humanities. Funding for the Society component of Pillar II is inadequate, and SSH integration must be significantly strengthened. FP10 should not be reduced to an industrial policy tool: it requires long-term investments across disciplines and technology readiness levels, with room for low- and mid-TRL research to drive curiosity-driven breakthroughs. The proposed links to the European Competitiveness Fund (ECF) raise concerns. While synergies can be useful, they must not compromise FP10s autonomy or shift resources away from fundamental and pre-competitive research. Budget for R&I must remain ring-fenced for excellence-driven, bottom-up science. UNL stresses that FP10, especially Pillar I, should remain primarily bottom-up. While thematic connection with key societal challenges is positive, we emphasize that detailed policy directionality sells the scientific community short: unbounded, bottom-up research consistently leads to excellent results, while supporting objectives such as competitiveness and sustainable development. Therefore, UNL emphasizes that activities such as MSCA must remain fully bottom-up and free of policy directionality. This also implies that Moonshot initiatives should not be funded via bottom-up instruments like MSCA or ERC, and should integrate SSH and low-TRL research. New European Bauhaus is welcome, but its non-research components fit better in the ECF, with only the research parts included in FP10. International cooperation is a cornerstone of FP10. Association should remain the closest form of participation for non-EU partners, based on reciprocity and shared values. Yet the Regulation should also enable more flexible partnerships with leading research organisations worldwide, complementing association and supporting Europes role in tackling global challenges. Clear rules are needed to manage cooperation in sensitive areas, while keeping excellence as the guiding principle. Finally, UNL notes the inclusion of dual-use research but warns that without clear governance and legal certainty, this risks undermining FP10s civil orientation. A transparent framework is required to distinguish between civil research, dual-use potential and defence-related work, with safeguards to uphold openness and inclusiveness. For our full reaction, please consult the attachment.
Read full responseResponse to EU’s next long-term budget (MFF) – EU funding for competitiveness
6 Nov 2025
Universities of the Netherlands (UNL) welcomes the Council Decision on establishing the Specific Programme implementing Horizon Europe for the period 2028-2034. We appreciate the recognition of research and innovation as key to Europes prosperity, resilience, and, of course, competitiveness. At the same time, we see a need for more ambition and clearer safeguards to ensure that FP10 can deliver on its goals. The proposed 175 billion budget is an important step forward but once corrected for inflation and rising costs it falls short of what is needed. To strengthen Europes competitiveness and deliver on societal challenges, the budget should strive for 200 billion, in line with the Draghi report. Horizon must remain a standalone program, with resources protected from diversion to short-term political objectives. Strong and independent governance is essential. The European Research Council (ERC) must retain its autonomy, with the Scientific Council and its President fully safeguarded. The decision to shorten the ERC presidency to 2+2 years requires justification, and any excessive steering by the Commission risks undermining excellence-driven research. Excellence must remain the primary evaluation criterion, as guaranteed in Article 25 of the proposal for a Regulation. For Pillar II, governance should balance the roles of Commission and Member States while ensuring meaningful involvement of scientists, universities and research support offices. UNL is concerned that the Society component within Pillar II is underfunded. Europes strength lies not only in technology but also in its excellence in Social Sciences and Humanities (SSH), which provide the insights needed to connect innovation to societal needs. FP10 must avoid reducing Pillar II to an industrial policy tool and instead ensure a balanced, long-term investment across disciplines and TRLs, with sufficient space for low- and mid-TRL research to drive breakthroughs. Synergies with the European Competitiveness Fund (ECF) can be valuable, but FP10 must not be subordinated to shifting industrial policy priorities. The entire Horizon budget should be ring-fenced (and not skimmed yearly) to protect excellence-driven, bottom-up research, while cooperation with the ECF should not come at the expense of fundamental and pre-competitive science. UNL emphasizes that FP10, particularly Pillar I, should remain primarily bottom-up. While connecting research to key societal challenges is valuable, we caution that imposing detailed policy directionality risks limiting the scientific community: truly open, bottom-up research consistently produces excellent results while advancing objectives such as competitiveness and sustainable development. Therefore, UNL insists that instruments like MSCA stay fully bottom-up and free from policy directionality. This also means Moonshot initiatives should not be funded through bottom-up instruments like MSCA or ERC and should integrate SSH and low-TRL research. The New European Bauhaus is welcome, though its non-research components are better suited for the ECF, with only its research elements included in FP10. Overall, the Council Decision provides a solid foundation for FP10, but greater ambition on the budget, stronger protection of ERC and excellence, and a balanced approach to SSH and societal challenges are required. UNL looks forward to engaging in the negotiations to ensure FP10 strengthens Europes knowledge base and delivers sustainable competitiveness for the future. For our full reaction, please consult the attachment.
Read full responseResponse to European Research Area (ERA) Act
9 Sept 2025
Universities of the Netherlands (UNL) supports the ERA Act as a chance to reduce fragmentation and promote the fifth freedom: free movement of researchers, knowledge, and technology. The Act should combine competitiveness with academic freedom, mobility, and respect for national autonomy. 1. Investment in Research and Innovation: The 3% GDP target for R&I is essential. Underinvestment leads to job insecurity, rejected proposals, and limited mobility. The ERA Act should mobilize public and private investments, link national funding to EU monitoring, and safeguard the types of curiosity-driven research that have led to countless innovations. The Act should support international collaboration, including in the social sciences and humanities, while defence spending must not dominate. 2. Academic Freedom and the Fifth Freedom: Academic freedom needs enforceable safeguards and sanctions against violations. Researchers must be free to publish, communicate, and move across borders, with affordable access to infrastructures as outlined in the European Charter for Access to Research Infrastructures. The EU should act as a safe haven for academic freedom and strengthen leadership in open science and open access. 3. Coordination Between Member States and the Commission: Better coordination is positive if national stakeholders remain involved and thematic freedom is preserved. Platforms such as the European Research Area and Innovation Committee (ERAC) and the ERA Forum are vital and should be reinforced. The Commission can reduce fragmentation, but research priorities must be set by research communities themselves. 4. Research Careers and Mobility: The Act should improve research careers and mobility, building on existing programs: the European Research Council (ERC) funds frontier research, the Marie Skłodowska-Curie Actions (MSCA) support researcher training and mobility, and Erasmus+ fosters student mobility. The ERA Act can add value via European University Alliances and stronger links to EU skills initiatives. To address precarious careers, the Act should support better integration of research and academic careers, including research management, and enable cross-border pension schemes. 5. Responsible Use of Artificial Intelligence: The Act should promote responsible and ethical use of AI in research, preventing dependence on non-European systems and misuse, while avoiding overly strict rules that stifle innovation or weaken competitiveness. 6. What the ERA Act Should Include: Key principles are: balanced investment in both fundamental and applied research; strong protection of the fifth freedom with common mobility standards; links with education through diploma recognition and lifelong learning; research assessment aligned with CoARA and open science; targeted measures for underrepresented groups and reducing disparities between member states; better integration of research careers, including cross-border pensions; and an EU-wide intellectual property framework to accelerate knowledge valorisation while protecting knowledge security. 7. What the ERA Act Should Avoid The Act should not include deployment or marketization of EU products, as these activities belong in other funds. Additionally, the Act must strike a careful balance by preventing both undue interference from national governments in research content and methods, and the imposition of conflicting rules by other member states that could undermine national values. Finally, Existing instruments such as ERAC, the ERA Forum, and monitoring systems should be reinforced, not replaced. 8. Conclusion The ERA Act can reshape Europes research landscape by boosting investment, coordination, careers, and freedoms. Its success depends on proportionate, evidence-based measures developed in close dialogue with stakeholders. Our full input can be found in the attachments of this Call for Evidence input.
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