EIC Board publishes draft Code of Conduct for consultants to support applicants
- ›The European Innovation Council Board has published a draft voluntary Code of Conduct for consultancies that help EIC applicants.
- ›The code is intended to set minimum standards for transparency, professionalism and ethical behaviour in the fast growing innovation consultancy market.
- ›Stakeholders are invited to comment on the draft by emailing RTD-COC-EIC-BOARD@ec.europa.eu by 22 September 2023.
- ›The measure is voluntary and its effectiveness will depend on uptake, monitoring and interaction with existing EU rules on integrity and fraud prevention.
EIC Board publishes draft Code of Conduct for consultants
On 1 August 2023 the European Innovation Council Board published a draft Code of Conduct aimed at consultancies that assist applicants to the EIC. The Board says the move follows stakeholder consultations and is motivated by the rapid growth of the innovation consultancy market and the risks that growth brings to transparency and fairness in the application process. The draft is open for comments and feedback until 22 September 2023 via RTD-COC-EIC-BOARD@ec.europa.eu.
Why the EIC Board is acting now
The EIC Board flagged two drivers behind the proposal. First, a rising number of applicants turn to paid consultants because internal resources and proposal drafting experience are limited. Second, the consultancy market itself has expanded quickly, producing a wide range of actors with different practices and standards. The Board frames the draft code as an effort to promote fairness, to raise professional standards and to improve transparency about the role of consultants in preparing proposals and in managing projects after they are awarded.
What the draft promises and what it does not
The Board explicitly proposes a voluntary instrument rather than a binding regulation. The draft is presented as a set of minimum rules to encourage ethical behaviour and transparency. The public announcement does not claim new enforcement powers for the EIC Board. The draft is therefore primarily a reputational and contractual tool that depends on buy in from consultants, applicants and intermediary networks.
Typical issues the code aims to address
The announcement is short on the text of the code. Based on standard practice across similar initiatives, the measures the Board is likely aiming to cover include clarity on fees and services, declaration of conflicts of interest, obligations on confidentiality and data protection, limits on promises about outcomes and guidance on advertising and claims about success rates. The goal is to reduce misleading practices and conflicts that can disadvantage applicants and distort competition for grants and investments.
What a meaningful Code of Conduct should include
Stakeholders reviewing the draft should assess whether it contains concrete, enforceable commitments rather than aspirational language. Possible elements to look for are clear provisions on disclosure of fees and relationships, a conflict of interest register, minimum competency requirements for staff providing advisory services, explicit rules on authorship and ownership of proposal material, and data protection safeguards in line with EU rules.
| Topic | What to expect in the draft | Why it matters |
| Fee transparency | Disclose pricing models and any success contingent fees | Reduces hidden costs and prevents exploitative contracts |
| Conflicts of interest | Declare relationships with investors, evaluators or partner organisations | Helps prevent undue influence and reputational risk |
| Scope of service | Define services offered and limits on intermediating or submitting on behalf of applicants | Clarifies responsibilities and preserves applicant autonomy |
| Data and confidentiality | Rules on handling applicant data and compliance with EU data protection law | Protects sensitive technical and personal information |
| Accuracy and claims | Prohibit guarantees of funding and misleading success rate claims | Protects applicants from false expectations |
Who will be affected and how
Primary stakeholders include applicants to the EIC, especially small teams and early stage companies that lack internal grant writing capacity. Consultancies will be asked to sign up to the voluntary code and to change commercial and operational practices where necessary. The EIC itself and its implementing agency EISMEA will need to judge how to promote the code, monitor take up and interact with other EU integrity frameworks such as fraud prevention procedures.
How stakeholders can respond to the consultation
The EIC Board has invited comments on the draft code. The deadline for written feedback is 22 September 2023. Responses should be specific, identify provisions that are unclear or unenforceable and propose concrete language or monitoring arrangements. Applicants and intermediaries might also suggest mechanisms for certification, dispute resolution and reporting of breaches.
| Action | Details | Contact / Deadline |
| Submit feedback | Send comments on the draft Code of Conduct for consultants | RTD-COC-EIC-BOARD@ec.europa.eu by 22 September 2023 |
| Read draft | Draft Code of Conduct is available on the EIC website and related EIC Board pages | Published 1 August 2023 |
Practical questions about effectiveness
Voluntary codes often improve standards when paired with incentives such as preferred access to support services, public registries, or certification labels. Without incentives or enforcement there is a risk of low uptake, uneven implementation and continued opaque practices. The EIC Board and EISMEA will need to decide whether signatories will be listed publicly and how breaches will be handled.
A measured conclusion
The EIC Board has responded to a real problem in the grant ecosystem by publishing a draft Code of Conduct for consultants. The draft is a modest tool which aims to improve transparency and set minimum standards. Its impact will depend on how detailed the provisions are, whether market actors adopt the code, and how the EIC and its agencies support, monitor and, if necessary, enforce compliance alongside existing EU oversight instruments. Stakeholders should use the consultation window to press for clear, enforceable language and for practical monitoring arrangements.
Contacts and documents
Send feedback to RTD-COC-EIC-BOARD@ec.europa.eu by 22 September 2023. The draft Code of Conduct is published on the EIC website under the EIC Board consultation documents dated 1 August 2023.