Luxembourg National Research Fund

Amended law of 31 May 1999 establishing a National Research Fund in the public sector, in particular Articles 2 and 3, as well as the following implementing regulations:

• Amended Grand-Ducal regulation of 27 July 2000 laying down the procedures relating to the presentation, selection and implementation of research activities benefiting from a grant from the National Research Fund.
• Amended Grand-Ducal regulation of 6 October 2008 relating to the methods of allocation, calculation, and management of training & research grants.

As part of its legal mission, the National Research Fund (FNR) is called upon to:

• allocate grants to research projects selected based on scientific quality criteria, taking into account their economic, social, or cultural potential;
• allocate grants for training & research, and finance measures linked to their promotion in order to support research trainees;
• contribute to the implementation and use of the research results of these programmes and projects and ensure respect for intellectual property generated by the activities supported;
• award grants to researchers and scientists and allocate subsidies to individuals as well as associations engaged in activities of scientific nature;
• promote, coordinate, or manage, in whole or in part, Luxembourg’s participation in international research cooperation programmes, including the allocation of grants to research projects within the framework of international programmes.

Article 3(3) of the law of 31 May 1999 as amended specifies in particular:

Eligible expenses in this respect include personnel expenses, expenses for third party services, operating and acquisitions expenses, and other expenses relating to the implementation of the research activities concerned, and the use and publication of their results. Acquisition, construction, or property development expenses may be considered eligible expenses if they are deemed indispensable for carrying out this research.

The purpose of this document, hereinafter referred to as the “Regulations” is:

• to specify the different costs categories and expenses eligible for reimbursement by the FNR, in compliance with legal provisions,
• to set the eligibility criteria and the terms under which said costs and expenses are reimbursed for the various funding instruments implemented by the FNR
• and to specify the themes: scope, grant ceilings, co-funding, double ceiling, eligibility according to progress, changes to budget breakdown, monitoring procedures, as well as general references.

If one or more provisions of these Regulations are found to be null, void, or contrary to a law or to a Grand-Ducal regulation, they will be deemed unwritten, but the other provisions will retain their validity in full.

The Regulations can be used as follows to ascertain the eligible costs for a specific FNR funding instrument:

Note that sections 1 to 5 and 8 to 12 include other procedures to be considered for FNR funding, as mentioned above under section 1.3.

Annex 3: Eligible budget lines by funding instrument

“Annex 3.1 table 1 – Special rules relating to personnel costs applicable to certain funding instruments:

Annex 3.2. Special rules – equipment:

Annex 3.3. Special rules – travel costs:

Annex 3.4 Special rules – mobility and training allowance:

Annex 3.5. Special rules – subcontracting:

The Regulations apply to all FNR Beneficiaries, as defined and identified on the FNR website, under the section “FNR Beneficiaries” (https://www.fnr.lu/fnr-beneficiaries/) and cover all FNR funding instruments ( https://www.fnr.lu/funding/).

To be eligible for FNR funding, certain categories of beneficiaries must be accredited^[1] by the Ministry of Higher Education and Research or the Ministry of the Economy.

[1] https://www.fnr.lu/fnr-beneficiaries/

To be eligible, expenses must be real, justified, reasonable, necessary, and related to the Project. Granting of FNR funding may not have the purpose or effect of generating a profit for the Beneficiary(ies). Section 11 provides information on monitoring procedures.

The granting of FNR funding may in no case constitute double funding of operating, acquisition or personnel costs already subsidised by the State or financed by the Parties via national or foreign third-party sources of funding other than the FNR.

The Parties are authorised to apply for one or several other aid(s) from other funders for the same Project – or for a similar Project (in full or in part) – for which a grant application has been submitted to the FNR. The Parties must, however, inform the FNR of this when submitting the grant application. Two Projects are deemed of a similar nature if they (in full or in part) describe the same main objectives or constitute a mere adaptation.

Once the FNR grant has been granted and accepted by the Parties, the interdiction of double funding applies.

VAT is not an eligible cost where the Party(ies) can recover VAT from the Luxembourg tax authorities, in accordance with Luxembourg indirect tax regulation.

In all funding instruments, except for instruments allocating “research & training grants”, a budget table must be submitted using the relevant form alongside the grant application.

All estimated costs for the Project must be detailed and explained, as must the sources and amounts of the various financial contributions (FNR, own funds, funding from third parties other than the FNR) from which the Project is to benefit. Depending on the funding instrument, more detailed explanations may be required. The FNR may decide to limit its funding if no satisfactory justification of the budget is provided.

The budget table must indicate the maximum allowable amounts that can be charged to the FNR for reimbursement for each budget line.

Some costs may be indicated on a verifiable flat-rate basis (for example, in relation to activities performed regularly by the relevant Party), provided that they do not differ substantially from the actual incurred (real) cost and the activities are in accordance with the FNR eligibility criteria.

No reallocation is allowed between direct and indirect costs, as well as for costs listed under 6.8 in Section 6 and the Junior track [CORE Junior only] mentoring costs (see 6.6.5).

Section 10 describes the implementation of a change in the budget breakdown [not applicable to AFR; Industrial Fellowships; IPBG; Open Access Fund; PRIDE; RESCOM]. In case of doubt, the FNR must be contacted.

This budget line refers to the personnel allocated to the Project. More specifically, it refers to the payroll costs of all staff, full or part-time, who work directly on the Project and are stated in the Project description, where the working hours spent (monitoring and valuation) can be duly supported by an auditable record.

The concerned staff must have a valid employment contract (or equivalent contract)[1] with the Party/Beneficiary in accordance with the legal and regulatory provisions in force.

The Principal Investigator or Project Manager must be known at the time of application submission. The FNR requirements for Principal Investigator(s), Supervisor(s), and Project Manager(s) (http://bit.ly/PIandSupervision) within FNR funded projects apply.

The need for staff as provided for in the budget must be clearly outlined (name, category of staff: post-doctoral student / PhD student, etc., person already recruited or to be recruited, expected person-months, FNR funding requested).

Changes of profile (e.g. Postdoc to technician) during the execution of the Project must be requested in accordance with the terms as defined in the Agreement.

Actual working time on the relevant Project must be auditable to form the basis of the costs charged to the Project. To do this, the actual working time attributable to the Project must be recorded (time sheets) for each person assigned to the Project.

When persons are contracted to work one hundred per cent (100%) of their time on a single project (whether full-time or part-time), timesheets are not necessary since their costs can only be allocated to that one Project.

In all other cases, timesheets for a given project are mandatory.

There are two categories of personnel costs (6.1.1. & 6.1.2.), with salary costs for “training & research grants” governed by Article 5 of the Grand-Ducal regulation of 6 October 2008 relating to the methods of allocating, calculating, and managing training & research grants, as amended by the Grand-Ducal regulation of 29 October 2014.

[1] The employment relationship must be duly described and justified.

This budget line is for new equipment dedicated to the Project. This encompasses the costs of laboratory/workshop equipment (including computers and servers), software and installation costs and other equipment as indicated in the Project description (see Agreement) and stated in the budget (see Section 5 ).

The FNR will only finance equipment listed in the accepted proposal. Any additional funding request for equipment must be submitted in writing for approval by the FNR.

The FNR reserves the right to limit its equipment funding on a case-by-case basis.

Specific rules apply depending on the amount to be funded and the instrument concerned. Annex 3.2 below details the applicability of these rules by funding instrument where the item “equipment” is eligible.

To justify the requested funding, the general information below must be provided along with costings.

General information:

• The precise nature of the equipment along with specific technical requirements;
• Its unit cost and number of units;
• Its relevance to the Project;
• The necessity for the equipment, considering the equipment currently available to the Beneficiary;
• Its useful life according to the Beneficiary’s accounting practices and depreciation method (for example, straight-line);
• The share of the equipment to be used in the Project, valuation of the use (percentage used and duration) must be auditable;
• Its use outside the Project with indication of residual value (if applicable);
• Its use by other national or international research groups/institutions (if applicable);
• For equipment that must be developed during the project (or equipment which may not be functional if used individually) and whose full development costs exceed twenty-five thousand (25,000) euros (total costs and not individual parts), co-funding should be provided and the source given;
• For equipment with an acquisition cost that is greater than one hundred thousand (100,000) euros or two hundred thousand (200,000) euros (“FNR + own resources” funding), a business and/or utilisation plan is required at submission.

Example – equipment for which the acquisition cost is greater than twenty-five thousand (25,000) euros:

• Project duration: 3 years
• Equipment purchase costs: 50,000 euros during the first year of the Project
• Useful life: 5 years, straight-line depreciation (10,000 euros/year) assuming a residual value of 0 euros
• Share of equipment used in the Project: 75% of the time used (3 years in this example)
• Eligible costs (pro rata) of 22,500 euros

= 3 (years of use) x 10,000 euros (annual depreciation) x 75% (percentage of use) = 22,500 euros

This budget line includes all consumables (chemicals, glassware, electronics, etc.) required for the Project to operate a device, obtain a research result, or organise a workshop as part of a Project promoting scientific culture and whose duration of use is limited to its wear or consumption.

Note that consumables are not individual parts of a prototype or parts used to repair or extend existing equipment.

The applicant must indicate the nature of the consumables (chemical reagents, glassware, etc.) and justify the total cost estimate and the requested budget in the relevant section of the budget table.

This budget line covers travel expenses, accommodation and subsistence expenses or allowances, as well as expenses relating to participation in conferences and training.

The relevant section of the budget table, if applicable, can be used to detail these costs when submitting the Project, for example:

• Brief indication of the conferences or technology fairs in which you wish to participate and the number of employees concerned;
• Accommodation and travel expenses for speakers, panellists, and organisers from abroad (for an international conference held in Luxembourg);
• Travel, hotel and meal expenses for guest speakers, moderators, and presenters (promotion of scientific culture);
• Travel costs, entrance fees, guide fees, accommodation, and meals (only for school activities abroad) (promotion of scientific culture);

To reduce the amount of red tape when submitting the Project and to give the team (including PhDs) the necessary flexibility, a lump sum may be indicated. The FNR will only cover the actual incurred travel costs in the final settlement.

Annex 3.3 below specifies the application of specific rules for the various funding instruments where the “travel expenses” item is eligible. These specific rules are as below.

It is therefore essential to provide the total person-months effort of all the people working on the Project. If the Project team requires a higher travel budget, this must be duly justified.

The FNR expects all researchers participating in the Project (in particular PhD candidates) to benefit from this budgetary item provided by the FNR.

Other provisions that apply depending on the funding instrument include the following.

This budget line concerns the costs associated with services provided by subcontractors. The Parties may subcontract specific services:

• Unless they constitute key elements of the Project (see Agreement);
• Unless they can be taken on directly by one of the Parties;
• If they are limited in time and scope.

The applicant must justify the need for the requested funding in terms of:

• Need to use a third-party service provider (e.g. expert, technical assistance),
• Planned volume of work (number of hours) and price (market price) for subcontractors.

Audit trails must be available to the FNR (such as invoices):

Restrictions in “subcontracting” funding:

1. A “contracting” or “non-contracting” partner cannot be a “subcontractor” (*);
2. The subcontractor (natural person and/or institution) has no right to the intellectual property generated as part of the Project;
3. The subcontractor has no rights to co-authorship on scientific publications generated from the Project;
4. Consultancy fees and travel costs for scientific advisory boards set up by the Principal Investigator / consortium are not eligible Project costs.

(*) This would be seen as a direct scientific contribution or technical consultancy to the Project and should be budgeted for the partner in the appropriate budget line. Subcontracting to non-contracting partners is therefore explicitly forbidden, as it is considered as a circumvention of the laws and regulations defining the Beneficiaries of FNR funding.

Annex 3.5 below details the applicability of specific rules, mentioned below, by funding instrument, if the “subcontracting” item is eligible.

This budget line includes other direct costs, not included in the above-mentioned cost categories, for items necessary to Project implementation. These costs must be duly justified, directly attributable to the Project and supported by a verifiable document (e.g. an invoice).

Annex 3.6 below provides examples of these other direct costs (List A) and specifies restrictive eligibility rules:

• Costs linked to the organisation of scientific conferences and/or workshops in Luxembourg (rental of rooms/premises including technical equipment);
• Field work/surveys;
• Scientific publications: conference proceedings, PhD theses, book chapters and scientific monographs related to the Project;
• The FNR requires that all scientific articles and scientific monographs related to FNR (co)funded projects are published in Open Access.
• Documentation (not provided in institutional libraries);
• Costs linked to the acquisition of reference materials & books;
• Costs of preparing technical reports & market studies;
• Publication and printing costs (posters, leaflets, programmes and invitations, activity report, etc.);
• Communication/marketing costs within the framework of the Project;
• Patent, license, or trademark filing fees;
• Copyright fees and licensing fees for new technologies, only in special cases to be agreed with the FNR;
• Costs generated by the use of existing equipment at partner institutions. This may include rental/access fees for equipment or analysis costs. These costs must be measurable and recoverable according to the Party’s internal regulations in force. The following must be specified in the “online” form, if applicable:

 o Type of equipment in question;
o Cost justification;
o Information on whether the existing equipment was purchased by the State;
o Residual useful life and details of the calculation on which the budget estimate is based.

• Equipment related costs, such as transfer/relocation, maintenance (external contracts or agreements);
• Fees for obtaining a visa;
• Recruitment and advertising costs for staff directly employed on the Project funded by the FNR.

When submitting a Project for evaluation, the source and amount of external financial contributions to the Project besides those of FNR shall be indicated.

Another external financial contribution could be a grant from another funding body, a donation from a charitable institution, license revenues, etc. Other FNR grants are considered an external contribution to the Project.

Financial contributions to the Project from external funding sources for the benefit of the Party(ies) shall be detailed in the budget table.

Contributions from non-contracting partners are not considered as an external source of funding. These contributions, including those of the international co-funding partner(s), should be detailed in the budget table in terms of human resources and planned budget.

In the case of “international co-funding”, the name of the international funding agency concerned must be indicated.

Annex 5 below indicates the different funding instruments that must communicate this information.

The summary budget of a Project is as follows:

(*): The FNR assumes that the difference between “total Project costs” and the “FNR financial contribution” plus the “external financial contribution” will be covered by the institution’s own resources.

The budget must be provided for each Party, indicating an estimate of the eligible costs required and the amount of funding expected from the FNR. Justification and additional information must be provided in the respective fields of the budget table.

Annex 5: External financial contributions and double ceiling