Applicants tend to treat the project portfolio as a funding application. The Commission treats it as the aid notification itself, and everything written in it becomes obligatory once the aid is approved.
The project portfolio (PP) is the document on which DG Competition approves your project. Together with the funding gap template, the competition assessment and the annexes, it must provide all the information required for the aid decision, and the whole package must be logically connected and non-contradictory: one set of facts, whichever document the case team opens. It is prepared by the direct participant itself, under the responsibility of the notifying Member State, with one PP per legal entity and per project. Two different projects mean two complete files.
The PP at the centre, and the files that must never contradict it.
Rules that surprise first-time applicants
– Everything committed becomes obligatory. Once aid is authorised, the PP is fixed. Work packages, milestones, spillover commitments and collaboration undertakings turn into monitored obligations, which is why the Commission insists the text be concrete, meaningful and as much as possible in layman language.
– Real people read it, including researchers. The R&D sections are assessed by qualified Commission researchers, so scientific substance belongs in the file. The Commission's own advice: have the person responsible for the answers read the template instructions, not only an AI agent.
– Confidential, with exceptions. The PP is in principle confidential, but parts of it are not: the project summary and the spillover commitments will be used publicly. Business secrets must be marked explicitly; redacting them is not the mechanism, marking them is.
– Even the file name is prescribed. Documents follow a systematic naming convention, for example AI_FR01_Company_PP_v1: wave identifier, Member State and project number, company, document type, version. Excels are submitted unlocked, revisions with tracked changes.
The current templates also ask applicants to keep the document readable: an indicative 50 to 75 pages plus annexes, a readable font, numbered paragraphs, and all template instructions deleted from the final text.
The takeaway.
Write the portfolio as the legal document it is, not as a pitch. Every sentence is either information the Commission needs or a commitment you will be monitored against; know which one you are writing at any moment.
Sources
– IPCEI Communication, OJ C 528, 30.12.2021 (EUR-Lex)
– European Commission – IPCEI overview (DG Competition)
– European Commission, IPCEI project portfolio template (v1, October 2023; adjusted for IPCEI AI, 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)