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The FP7 Post-Grant Open Access Pilot policy guidelines state that eligible FP7 projects are those "finished no longer than two years ago at funding request submission time". 

"Projects are eligible to receive funding after the project has ended and up to 2 years after the project official end date (based on project information in the CORDIS database http://cordis.europa.eu).

If the project is no longer eligible to receive funding, there will be a notification upon submission. This can be overruled by the administrator if the acceptance and invoice date prove that the publication falls within the eligibility window, despite the date of submisson falling out of it.

Occasional exceptions may be made to this rule when a project was extended or had an early termination. Please get in contact with us in order to suggest a system update if this is the case for your project.

The funding needs to be requested upon acceptance of the manuscript. The Pilot is not aimed at retroactively reimbursing fees for papers that have been published already.

"