Applicants often treat the FGQ as a modelling task. The Commission treats it as an evidence file. The gap between those two views is where most of the assessment questions come from.
Every assumption in the funding gap questionnaire must be justified in the project portfolio and supported by documents, and the Commission has become precise about what that means. Market studies, internal or external, with the exact page and segment referenced. Complete documents, not extracts. And no redactions permitted, business secrets or NDAs notwithstanding; confidential material is protected by the case team, not blacked out by the applicant. On the cost side, each CAPEX and cost item is expected to carry supplier quotations, invoices or market analysis. On the revenue side, internal transfer-pricing arrangements are not accepted as evidence of what a product will earn.
Seven evidence rules, applied before the model is even opened.
The counterfactual needs a paper trail
The same standard applies to the counterfactual scenario: it must be the alternative that was actually discussed at management level, evidenced by contemporaneous documents showing its content, its consideration and the associated decision. A counterfactual that exists only inside the spreadsheet is an assertion, not evidence.
Discipline that prevents questions
– One set of figures. The FGQ and the project portfolio are read together; any divergence between them makes both suspect and triggers requests for information.
– Explain the why, not just the what. For every assumption, state what was assumed and why, and show the link to the supporting document. The reviewer should never have to reconstruct your reasoning.
– Disbursement follows costs. The expected aid instalments should align with annual eligible costs unless a deviation is explained and linked to the financing need.
– Currency hygiene. Any conversion to euro carries its rate, source and date.
The takeaway. Build the data room while you build the model, not after. A funding gap file where every number already carries its quote, study or board paper moves through pre-notification with a fraction of the questions, and questions are what cost you months.
Sources
– IPCEI Communication, OJ C 528, 30.12.2021 (EUR-Lex)
– European Commission – IPCEI overview (DG Competition)
– European Commission, Funding gap template for IPCEI projects (RDI & FID), version 3.2 adjusted for IPCEI AI, April 2026 (distributed to applicants via national authorities)
– DG COMP Unit H23, IPCEI AI workshop for direct participants and Member States: project portfolio, funding gap and spillovers, 12 June 2026 (workshop materials)