Horizon Europe — FAIR data mandatory, no opt-out; Article 17 ties compliance to payments

The European Commission's Horizon Europe Programme Guide (2021 onward) makes FAIR data mandatory for all Horizon Europe projects with no opt-out provision. Grant Agreement Article 17 ties compliance to payments: non-compliance can trigger grant reduction or financial penalties.

For C-0003 and C-0025, Horizon Europe operationalizes the shift from self-reported plan to enforceable obligation at funder scale outside the United States: the EU does not require institutions to write a plan; it makes the FAIR properties contractual, with payment as the enforcement mechanism. Combined with the NIH DMS Policy (E-0044), the Gates Foundation's automated review (E-0045), Wellcome's compliance framework (E-0090), and the NSF DMP gating (E-0091), Horizon Europe forms one of five concurrent verification regimes pushing the mandate environment from declarative to programmatic.