Linkage Program Grant Guidelines (2024 edition): Linkage Projects

The guidelines operate through a defined set of roles, terms and constraints that structure eligibility, assessment and governance. The Administering Organisation is the Eligible Organisation that submits the application and will be the entity contracting with the ARC; Eligible Organisations are those enumerated in Appendix B, which for this edition is a fixed list of higher education institutions and similar bodies (Appendix B). Partner Organisations are third-party organisations that are not Eligible Organisations and not controlled entities of Eligible Organisations; they must make project-specific cash and/or in-kind contributions and provide a Letter of Partner Organisation Certification using the proforma on GrantConnect (see "Who is eligible to be a Partner Organisation?", clauses 4.8-4.12).

Named participants are individual researchers specified on an application as Chief Investigators (CIs) or Partner Investigators (PIs). The CI role has explicit eligibility requirements: as at grant commencement and during the project, a CI must be employed for at least 0.2 FTE by an Eligible Organisation, or hold an honorary academic appointment at an Eligible Organisation, and must reside in Australia for more than 50 per cent of the project activity period; CIs must not undertake a Higher Degree by Research during the project period (see "Chief Investigators", clauses 4.17-4.19). The Project Leader is the first-named CI, and has to demonstrate project management capacity. A PI representing a Partner Organisation must have a role within that Partner Organisation (see "Partner Investigators", clause 4.21).

Contributions from Partner Organisations are central to the scheme’s mechanics. The application must include Partner Organisation commitments that at least match the requested ARC funding and must include eligible cash contributions of at least 25 per cent of the ARC request (clause 4.3). The Glossary distinguishes cash contributions, in-kind contributions and other material resources, and sets valuation expectations for in-kind contributions, noting the ARC may require audit of those calculations ("In-kind contribution" in the Glossary). The guidelines circumscribe eligible sources of Partner cash, excluding funds appropriated by Commonwealth or State/Territory governments for research and funds previously used to leverage government research or infrastructure funding (clause 4.12(a)). They also cap the eligible combined contribution from Partner Organisations whose funds are predominantly government appropriations to 25 per cent of the required Partner contribution; additional contributions from those organisations are permitted but will not count toward the required amount (clause 4.14).

The guidelines define what constitutes eligible research, and exclude certain activities. "Research" is defined in the Glossary as creation of new knowledge and/or use of existing knowledge in a new and creative way; "applied," "pure basic" and "strategic basic" research are referenced using ABS/ANZSRC definitions; experimental development is separately defined and excluded from funding (Glossary entries and "What grant funds cannot be used for", clause 5.1 and 5.2). The guidelines also prohibit funding of medical research as set out in the ARC Medical Research Policy (2020), and disallow certain costs such as CI/PI salaries, capital works, basic facilities, and indirect costs (clause 5.2).

Selection and approval structures are institutional: applications are peer-reviewed, may be allocated to Detailed Assessors, evaluated by a Selection Advisory Committee that makes recommendations to the ARC Accountable Authority, which makes the final decision taking into account committee advice and alignment with Government priorities; the Minister may intervene on national security, defence or international relations grounds (see "The assessment process", "We make grant recommendations", and the Ministerial paragraph in section 1). The ARC’s processes include probity safeguards, conflict of interest certification, rights to request non-assessment of named assessors within limits, a rejoinder stage, and an appeals process that is limited to alleged administrative errors rather than merits of assessment (see "Requests not to assess process", "Rejoinder process", and "Appeals process").

Administrative documents and policies are referenced as governing instruments: the grant agreement is a standard ARC Linkage Program grant agreement with potential special conditions; applicants must follow Instructions to Applicants, supply a National Interest Test statement, and comply with ARC policies such as the Open Access Policy and Research Integrity Policy (see "Grant Agreements", "How to apply", and "Specific research policies and practices"). The guidelines also set reporting and monitoring obligations, allow site visits and audits, and reserve the ARC’s rights to re-examine claims and request audits (see "Monitoring and reporting").

Finally, the guidelines state publication and confidentiality rules. The ARC will publish grant offers on GrantConnect within 21 days and will publicise named participants, project descriptions, National Interest Test statements and grant amounts; applicants are advised to avoid disclosing information that would compromise confidentiality or IP (see "Advice and Announcement" and "Confidential information"). The guidelines also place the handling of personal information within the Privacy Act 1988 and note that information may be disclosed to other Australian Government business or functions (see "Privacy and protection of personal information" and "Confidential information").

Primary financial and administrative burdens fall on Administering Organisations, that is, Eligible Organisations listed in Appendix B. The Appendix lists a fixed set of universities and similar bodies, for example The Australian National University, Monash University, The University of Melbourne, and others. If an organisation is not in Appendix B it cannot act as Administering Organisation; it can be included as a Partner Organisation or Other Organisation only subject to the Partner rules or Other Organisation rules (see "Who is eligible to apply for a grant?" and Appendix B).

Partner Organisations are materially affected because they must make project-specific contributions, certify their commitments using the proforma Letter of Partner Organisation Certification, and must not be Eligible Organisations or controlled entities of Eligible Organisations. Partner Organisations must not be listed on the National Redress Scheme’s list of institutions that have not joined or signified intent to join; they must also ensure their cash contributions are not sourced from Commonwealth or State/Territory research appropriations nor previously used for government research leverage, and Partner Organisation funds that are predominantly government appropriations can only account for a combined maximum of 25 per cent of the eligible Partner contribution (see "Who is eligible to be a Partner Organisation?", clauses 4.8-4.14). Partner Organisations also face constraints on what their cash can be used for; for example, Partner Organisation cash cannot be a contribution to CI or PI salaries (clause 4.12(b)).

Named participants, including CIs and PIs, are directly constrained. CIs must meet employment or honorary appointment requirements, be resident in Australia for more than half the project period, not undertake an HDR during the project, and the first-named CI is the Project Leader with management responsibilities (clauses 4.17-4.20 and "Responsibilities"). There are limits on the number of concurrent Linkage Program projects a named participant can have as a CI or Director: a maximum of four, counting active projects and applications under assessment and with counting rules that include certain programs and exclude others (clauses 4.25-4.28). If a participant is over the limit, any required withdrawals or relinquishments must be approved via a Variation before application submission (clause 4.29).

The ARC and its internal decision-makers are affected because the guidelines embed specific responsibilities and powers. The ARC manages assessments through Detailed Assessors, the Selection Advisory Committee and the ARC College of Experts (where SACs may be drawn from that College). The ARC Accountable Authority makes the final funding decision and may consider advice from other Commonwealth agencies; the guidelines also authorise the ARC to request additional information and to seek security advice from Commonwealth agencies at any time during assessment (see "The grant selection process", "We may seek advice on security or other matters", and "Who will approve grants").

Other Australian Government agencies are implicated because the ARC may disclose confidential information to other Australian Government business or functions, may seek advice on security or other matters, and because Commonwealth rules govern grants through the Commonwealth Grants Rules and Guidelines (CGRGs), the Privacy Act and the Freedom of Information Act (see "The grant selection process", "Confidential information", "Privacy and protection of personal information" and the first page references to CGRGs).

Other Organisations and Third-party contractors are affected in specific ways: Other Organisations can be named and involved without providing cash or in-kind contributions, but must not be on the National Redress list (see "Who is eligible to be an Other Organisation?"). Subcontractors engaged by the Administering Organisation must be bound by the Privacy Act obligations imposed on the grantee (see "Privacy and protection of personal information", clause 10.2).

Finally, end-users and broader stakeholders are affected indirectly because the scheme aims to foster collaborations with research end-users and to produce outputs intended to benefit industry, government, communities and not-for-profits. The impact assessment criterion specifically requires demonstration of mutual benefit and potential contribution to Australian Government priority areas (assessment criteria, Impact 20 per cent).

Duties

• Administering Organisation duties: The Administering Organisation must submit the application via RMS, ensure Partner Organisations provide required commitments and certification, and enter into the ARC Linkage Program grant agreement if successful. The Administering Organisation must not start project activities or incur ARC-claimed expenditure until the grant agreement is executed; the ARC will not pay more than the approved grant amount. The Administering Organisation must manage reporting obligations through RMS, notify the ARC of changes to contact and banking details, and be prepared for monitoring, site visits, audits and re-examination of claims (see "Application process", "Grant Agreements", "How we pay the grant", "Monitoring and reporting").

• Partner Organisation duties: Partner Organisations must participate for the project activity period, make project-specific contributions of cash and/or in-kind and/or other material resources (not part of a broader contribution), provide a Letter of Partner Organisation Certification using the proforma on GrantConnect, and be prepared to certify governance arrangements and financial commitment in support of project completion (see "Who is eligible to be a Partner Organisation?" and "Partner Organisation responsibilities").

• Named participants duties: Chief Investigators must take responsibility for authorship and intellectual content of the application, meet residential and eligibility requirements, and adhere to obligations specified in the grant agreement. Partner Investigators must take significant intellectual responsibility for the planning and conduct of the project, have relevant skills and experience, and be actively involved in strategic decisions (see "Chief Investigator responsibilities" and "Partner Investigator responsibilities").

• Compliance duties: All applicants and ARC-funded projects must comply with the Australian Code for the Responsible Conduct of Research (2018), the ARC Conflict of Interest Policy (2024), the ARC Research Integrity Policy (2023), the ARC Open Access Policy (2021), and any other codes and expectations on the ARC website. Ethics plans and data management plans must be in place before project commencement. Conflict of interest declarations must be made at submission and documented processes to manage conflicts must be in place for the project duration (see "Specific research policies and practices", "Ethics plan", "Data management plan", and "Conflict of interest").

• Financial and reporting duties: The Administering Organisation must ensure Partner contributions meet the matching and cash minimum rules, attest to accurate valuation of in-kind contributions and be prepared to provide supporting evidence on request, including audited calculations. Financial reporting and timely submission of end-of-year and final reports through RMS are required (see "Eligibility requirements", "In-kind contribution" in Glossary, and "Monitoring and reporting").

Rights

• Right to appeal administrative process errors: Applicants have a procedural right to lodge appeals against NCGP administrative processes, not against committee decisions or assessment merits; appeals must identify the specific guideline clause or policy alleged to have been applied incorrectly and must be authorised by the Administering Organisation’s Deputy Vice-Chancellor (Research) or equivalent (see "Appeals process").

• Right to request not-to-assess: Applicants may submit a Request Not to Assess form naming up to three persons they do not wish to assess their application, provided the request is lodged two weeks prior to the grant opportunity closing date; the ARC has discretion to accept or refuse the request and will not notify applicants of the outcome (see "Requests not to assess process").

• Rejoinder right: Applicants will be given an opportunity to respond to Detailed Assessors’ written comments through a rejoinder. Names of assessors will not be provided (see "Rejoinder process").

• Right to information on outcome and timing: If successful, applicants will receive a copy of the ARC Accountable Authority’s approval within 21 days, and the ARC will list the grant on GrantConnect no more than 21 calendar days after the date of effect. The ARC may impose an embargo on announcements to coordinate parties (see "Advice and Announcement").

• Right to standard grant agreement terms and knowledge of special conditions: A sample grant agreement is available on GrantConnect and offers will include any special conditions; applicants have 30 calendar days from the date of offer to execute the grant agreement (see "Grant Agreements").

• Rights and limits on confidentiality: Applicants may identify information as confidential when submitting it, and the ARC will treat it as confidential if it meets stated criteria. However, documents are subject to the Freedom of Information Act 1982, and the ARC may disclose confidential information to other Australian Government business or functions (see "Confidential information" and "Freedom of information").

Procedural constraints and limits

• Ministerial intervention: The Minister for Education can decide the ARC Accountable Authority should not approve a grant for reasons relevant to security, defence or international relations, and the ARC must comply and follow notification obligations (see "Grant selection process" and Ministerial paragraph).

• Finality of Accountable Authority decisions: The ARC Accountable Authority’s decision is final in all matters in the selection process, subject to the Minister’s intervention and the limited appeals process (see "Who will approve grants" and "Appeals process").

• Limits on appeal: Appeals are limited to alleged administrative process errors, not to committee assessments or assessor ratings or comments (see "Appeals process").

The guidelines do not list a catalogue of monetary fines or statutory criminal penalties within the document, but they set out a range of enforcement mechanisms, conditions for withholding or recovery of funds and refer to other ARC policies that may carry consequences. The concrete enforcement and compliance mechanisms spelled out in the guidelines include the following.

Decision and funding control

• Final approval and payment: The ARC Accountable Authority decides which grants to fund and the amounts and durations; it will not pay more than the approved grant amount. The ARC will not make payments until a grant agreement is executed, and is not responsible for project expenditure before execution (see "Who will approve grants", "How we pay the grant", and "Grant Agreements").

• Ministerial override: The Minister may require that a grant should not be approved for national security, defence or international relations reasons; the ARC must comply and undertake required notifications (see "Grant selection process" and Ministerial intervention).

Monitoring, audit and variation powers

• Monitoring and reporting: The ARC will assess reports and may conduct site visits, request records, re-examine claims, seek further information, or request an independent audit of claims and payments (see "Monitoring and reporting"). These are mechanisms through which the ARC can verify compliance with the grant agreement and the claimed use of funds.

• Grant Agreement variations and special conditions: Variations must be submitted and are subject to ARC approval; special conditions will be identified in grant offers (see "Grant Agreement Variation" and "Grant Agreements"). The ARC can require additional certification as a result of breaches of the Australian Code for the Responsible Conduct of Research (see eligibility clause 4.5).

Suspension, refusal and exclusion

• Refusal to recommend or approve an application: The ARC may recommend that an application not be approved if it considers the application incomplete, inaccurate, false or in breach of the Australian Code for the Responsible Conduct of Research (2018), noting the ARC’s discretion in such cases (see "The grant selection process", clause 8.1.2). The ARC can also require information or actions following security advice obtained from Commonwealth agencies (clause 8.1.3).

• Exclusion of participants: Applications will not be considered where the ARC has made a decision to exclude grant applications involving a particular named participant for a period of time, whether or not they meet eligibility requirements (clause 4.6.5).

Financial and contractual consequences

• Recovering funds and withholding payments: While the guidelines do not state explicit recovery procedures, the standard grant agreement referenced will govern repayment, termination and breach consequences. The guidelines do specify that the ARC will not pay beyond the approved amount and is not responsible for expenditure prior to agreement execution, which imposes financial risk on the Administering Organisation if obligations are not observed (see "How we pay the grant" and "Grant Agreements").

• Audit and independent review: The ARC may request independent audits of claims and payments. The Glossary defines "In-kind contribution" and states that the ARC may require these calculations to be audited, implying potential disallowance of ineligible or unsubstantiated in-kind amounts (Glossary "In-kind contribution").

Administrative and reputational consequences

• Publication and public listing: Grant offers and details are published on GrantConnect including named participants, project description, National Interest Test statement and ARC funding amount, which exposes unsuccessful and successful applicants to public disclosure; applicants are warned to ensure project descriptions do not compromise confidentiality or IP (see "Advice and Announcement"). Publication can have reputational consequences if issues emerge.

• Compliance with other policies: Non-compliance with the Australian Code for the Responsible Conduct of Research or the ARC Research Integrity Policy may result in further actions or additional certification requirements being imposed, as referenced in eligibility clause 4.5 and "Specific research policies and practices".

Limits on appeal and review

• Narrow appeals route: The appeals process is limited to administrative process errors and requires authorisation by a specified senior officer in the Administering Organisation. Appeals cannot challenge assessor ratings or committee decisions on merit, which constrains recourse for applicants disputing substantive assessment outcomes (see "Appeals process").

Other enforcement interfaces

• Freedom of Information and disclosure: The FOI Act applies to documents in the possession of the Australian Government, subjecting application materials and ARC-held documents to potential FOI requests; the ARC also reserves the right to disclose confidential information to other Australian Government business or functions, which may be relevant in enforcement or oversight contexts (see "Confidential information" and "Freedom of information").

In sum, enforcement is effected primarily through control of approval and payments, monitoring and audit powers, conditions in the grant agreement, publication requirements and the ARC’s capacity to refuse or exclude applications or named participants for reasons including integrity or national security. The guidelines point to other ARC policies and the grant agreement for more detailed sanctions, and to external legislation such as the FOI Act and Privacy Act that shape disclosure and data-use consequences.

The guidelines explicitly cross-reference and require compliance with several statutes, Commonwealth policy instruments and sector-specific codes. These interactions create compliance obligations and limit eligible activity.

Statutes and whole-of-government rules

• Australian Research Council Act 2001: The guidelines are approved under section 59 of the ARC Act and the Minister’s approval notes satisfaction with matters in section 58. The ARC operates under the ARC Act framework, and the Accountable Authority and Ministerial roles are governed by that Act (cover page and opening paragraph).

• Commonwealth Grants Rules and Guidelines (CGRGs): The guidelines state the Australian Government will ensure the grant opportunity is run consistent with the CGRGs (see "Probity"). The CGRGs are whole-of-government rules that require specific procedural standards for grants administration.

• Privacy Act 1988 and Australian Privacy Principles: The ARC treats personal information in accordance with the Privacy Act and requires applicants to certify compliance with the Privacy Act and to impose equivalent privacy obligations on subcontractors. This creates data-handling obligations for Administering Organisations and contractors (see "Privacy and protection of personal information").

• Freedom of Information Act 1982: All documents in the possession of the Australian Government are subject to the FOI Act, and the guidelines warn applicants that material they supply may be requested under FOI, tempering claims of confidentiality (see "Freedom of information" and "Confidential information").

Sectoral codes and research-specific instruments

• Australian Code for the Responsible Conduct of Research (2018): Applicants and projects must comply with this Code; breaches can trigger additional certification requirements and may be grounds for excluding named participants or refusing applications (see eligibility clause 4.5 and "Specific research policies and practices").

• ARC Research Integrity Policy (2023), ARC Conflict of Interest Policy (2024), ARC Open Access Policy (2021): These ARC policies are incorporated by reference and set standards on research integrity, conflicts of interest and open access dissemination which must be followed by applicants and grantees (see "Specific research policies and practices").

• AIATSIS Code of Ethics, NHMRC guidelines and Australian Indigenous Data Sovereignty Principles: For projects involving Aboriginal and/or Torres Strait Islander research, the assessment criteria require adherence to the AIATSIS Code of Ethics for Aboriginal and Torres Strait Islander Research (2020), NHMRC guidelines (2018), and the Australian Indigenous Data Sovereignty Principles (2018) (see assessment criterion 6.a).

Taxation, grants and other financial rules

• GST and tax references: All amounts in the guidelines are exclusive of GST unless stated otherwise, and the Glossary defines GST per the A New Tax System (Goods and Services Tax) Act 1999 (see "How we pay the grant" and Glossary "GST").

• HECS and HELP liabilities: The guidelines bar use of grant funds for international student fees or HECS/HELP liabilities (see "What grant funds cannot be used for", clause 5.2(j)). This interacts with higher education funding and student loan regimes.

Constraints arising from other Commonwealth schemes

• National Redress Scheme: Partner Organisations and Other Organisations must not be included if listed on the National Redress Scheme’s website as institutions that have not joined or signified intent to join. This restricts participation by certain institutions and interfaces with the National Redress Scheme obligations (see "Who is eligible to be a Partner Organisation?" and "Who is eligible to be an Other Organisation?").

• Exclusion of Commonwealth-funded contributions: Partner Organisation cash contributions cannot be sourced from funds awarded or appropriated by the Commonwealth or State/Territory for research, nor from funds previously used to leverage government research or infrastructure funding (clause 4.12(a)). This interacts with public funding regimes and grants management practices within organisations.

Intellectual property and contract law

• IP arrangements: The guidelines instruct that IP arrangements should be negotiated between the Administering Organisation and Partner/Other Organisations, and state the ARC does not claim ownership of project IP. The requirement to negotiate IP and to ensure appropriate confidentiality and open access arrangements means standard contract and commercial law principles will apply in agreements among participants and in any special conditions in the grant agreement (see "Specific research policies and practices", IP paragraph).

Security and inter-agency advice

• Security-related advice and Ministerial direction: The ARC may seek advice from Commonwealth agencies at any time during assessment, and the Minister may direct non-approval on security, defence or international relations grounds. These clauses create an interface with national security considerations and relevant legislation or agency powers (see "The grant selection process", clauses 8.1.3 and "The Minister may at any time decide..." paragraph).

Other legal interfaces

• Exclusion for medical research: The guidelines exclude medical research as defined in the ARC Medical Research Policy (2020). This interacts with medical research regulatory regimes and with funding rules from NHMRC and other health research funders (see "What grant funds cannot be used for").

In practice, applicants must manage and document compliance across these statutory and policy instruments. The guidelines impose certification requirements (for privacy, conflicts, partner commitments) and reserve rights to request evidence, audits and further information, which will often require legal and compliance support to satisfy statutory and contractual obligations.

The document provided is the "Linkage Program Grant Guidelines (2024 edition): Linkage Projects" and bears the ministerial approval dated 29 July 2024 by the Minister for Education, Jason Clare, who approved the guidelines under section 59 of the Australian Research Council Act 2001. The front matter states the approval and the date. The guidelines therefore represent the 2024 edition of the Linkage Projects grant rules.

Within the text the guidelines explicitly reference other policy instruments and versions, which signal contemporaneous or prior policy updates relevant to administration and compliance. Notable cross-referenced instrument versions include:

• Australian Code for the Responsible Conduct of Research (2018), referenced multiple times as the primary research conduct standard and as a source of potential certification requirements where breaches are found (see clause 4.5 and "Specific research policies and practices").

• ARC Medical Research Policy (2020 version), cited as the definition and exclusion mechanism for medical research in the Linkage Projects scheme (see "What grant funds cannot be used for", clause 5.2(b)).

• ARC Open Access Policy (2021 version), specified as the policy governing dissemination of findings (see "Specific research policies and practices", clause 5).

• ARC Research Integrity Policy (2023 version), and ARC Conflict of Interest Policy (2024), both cited as documents with compliance consequences and to which applicants must adhere (see "Specific research policies and practices").

These references indicate the guidelines’ reliance on external policy instruments whose versions are explicitly stated. The guidelines also incorporate the CGRGs framework and refer to the FOI Act 1982 and the Privacy Act 1988 for information-handling requirements.

The text does not include a change log or list previous versions of the Linkage Projects guidelines, nor does it detail amendments to specific clauses across editions. It does, however, identify the edition year (2024) and the ministerial approval date. Any substantive changes relative to prior editions are not enumerated in this document; practitioners seeking to identify discrete amendments will need to compare the 2024 edition to the prior edition(s) or review ARC announcements and GrantConnect notices for version history.

The glossary and Appendix B populate the administrative and eligibility scaffolding. Appendix B lists Eligible Organisations for this edition; any change to that list would be an amendment for future editions or administrative updates. The guidelines provide links and instructions to the ARC website and GrantConnect for Instructions to Applicants, sample grant agreements and FAQs, which are operational instruments likely to be updated between guideline editions.

In short, the document establishes its own 2024 vintage and cross-references a set of external policy instruments with specific version years. It does not supply an internal amendment history beyond the edition date and ministerial approval. For a historical trace of changes practitioners must consult archived guidelines, GrantConnect publications and ARC website records.

The guidelines themselves do not report any litigation, case law or judicial decisions. They make no reference to court cases, tribunal determinations or legal precedents. The document sets out appeal rights and limits within the administrative scheme but does not describe judicial review outcomes or precedents relating to the application of these guidelines.

Relevant procedural constraints in the guidelines that affect post-decision remedies include:

• Appeal limitations: The appeals process available under the scheme is limited to administrative process issues and explicitly excludes appeals against committee decisions, assessor ratings and comments, or the assessment outcome. Appellants must identify the specific guideline clause, legislative instrument clause, policy or procedure alleged to have been applied incorrectly and the appeal must be authorised by the Administering Organisation’s Deputy Vice-Chancellor (Research) or equivalent (see "Appeals process"). This narrow administrative appeal route reduces internal remedies for contesting merits.

• Freedom of Information and privacy: Materials held by the ARC are subject to FOI requests and to the Privacy Act; outcomes of FOI requests or privacy disputes can give rise to statutory review or litigation in other contexts, but no examples are provided in the guidelines (see "Freedom of information" and "Privacy and protection of personal information").

• Ministerial oversight and finality: The ARC Accountable Authority’s decision is defined as final in all matters, subject to ministerial direction on security grounds. The guidelines do not elaborate on judicial review or administrative law remedies, but in practice decisions by public authorities are amenable to judicial review on established public law grounds. The document itself does not situate those possible remedies or report any decided litigation challenging ARC decisions.

Because the source contains no litigation history, practitioners who require precedent on how courts have handled disputes about ARC grants, ARC policy interpretations, or grant administrative decisions must look beyond these guidelines to case law databases, administrative law reports and any judicial review decisions involving the ARC or comparable Commonwealth grant schemes. The guidelines’ internal appeal regime, being limited to administrative process and excluding merits, suggests that recourse to external review or judicial remedies may be the only option for substantive disputes, but the guidelines do not address or constrain those external options explicitly.

The guidelines contain multiple specific requirements and exclusions that can produce operational or compliance risks if overlooked. Key pitfalls to watch for, rooted in the text, follow.

Partner contributions and source restrictions

• Mandatory matching and cash floor: Applications must include Partner Organisation commitments that at least match the ARC funding requested and must include eligible cash contributions of at least 25 per cent of the total funding requested, unless all Partner Organisations are Exempt Partner Organisations (clauses 4.3(c) and the Exempt footnote). Failure to secure compliant Partner contributions will render an application ineligible.

• Source of partner cash: Partner Organisation cash contributions cannot be sourced from Commonwealth or State/Territory government funds appropriated for research, nor from funds previously used to leverage government research or infrastructure funding (clause 4.12(a)). Using ineligible funds can invalidate the Partner contribution and jeopardise the application.

• Government-appropriated partner funds cap: Partner Organisations whose funds are appropriated predominantly from government sources for research can only make up a combined maximum of 25 per cent of the combined Partner contributions eligible for the application, and any additional contributions from them will not count toward the required Partner contribution (clause 4.14). This requires careful budgeting and partner selection.

Eligibility and participant constraints

• Administering Organisation must be in Appendix B: Only organisations listed in Appendix B may be the Administering Organisation. If a project partner is a university not in Appendix B, they cannot be the Administering Organisation (see Appendix B).

• Partner Organisations cannot be Eligible Organisations or controlled entities: A Partner Organisation cannot be an Eligible Organisation, a controlled entity of an Eligible Organisation, or an entity more than 50 per cent owned by one or more Eligible Organisations (clause 4.10). This can complicate industry-university joint ventures where ownership or control thresholds are unclear.

• Partner Organisation and Other Organisation redress check: Partner Organisations and Other Organisations must not be listed on the National Redress Scheme’s website as institutions that have not joined or signified intent to join (clauses 4.10(a) and 4.11.2). Failing this check disqualifies them from being partners or other collaborators.

CI-specific constraints

• CI employment threshold and residency: CIs must be employed at an Eligible Organisation at 0.2 FTE or hold an honorary academic appointment, and must reside in Australia for more than 50 per cent of the project period; significant absences require approval and must not total more than half the project activity period (clauses 4.17-4.18). International mobility or long overseas fieldwork must be managed with approvals.

• No HDR enrolment for CIs: CIs must not undertake an HDR during the project activity period (clause 4.19). If a CI enrols in HDR during the project, this could breach eligibility.

Concurrent project limits

• Counting rules are specific: A participant can be concurrently funded as CI or Director on up to four Linkage Program projects. The guidelines specify which programs count and which do not. These counting rules are applied at submission date and include active projects and applications under assessment (clauses 4.25-4.28). Failure to correctly count active projects may lead to ineligibility or the need to seek a Variation to withdraw roles before submission (clause 4.29).

Budget and spending restrictions

• Prohibited uses of funds: Funds cannot be used for medical research as defined in ARC Medical Research Policy 2020, experimental development, certain artistic creation unless research-based, contracted consultancy lacking innovation, production of research tools unless they meet the research definition, basic facilities, capital works, CI/PI salaries, student fees or HECS/HELP liabilities, and a list of other indirect costs (clause 5.2). Misallocating funds may breach the grant agreement and attract audits.

• Caps on specific items: Teaching relief is capped at $50,000 per CI per year, and travel costs are capped at an average of $20,000 per year of the project with exceptions for field research and carer travel costs (clause 5.1(c)-(e)). Budgets must be constructed to respect these caps.

Application timing and procedural pitfalls

• Continuous intake but strict opening/closing: The scheme accepts applications on a continuous basis, but applicants must submit between the opening and closing dates published on GrantConnect. The Request Not to Assess form must be received two weeks prior to the closing date if used (see "Timing of the grant opportunities" and "Requests not to assess process"). Mis-timing a Request Not to Assess can forfeit the option.

• No changes after close: You cannot change your application after the closing date, unless invited by the ARC. If a required withdrawal or role relinquishment is needed to meet CI limits, the Variation must be approved before submission (clause 4.29, "Application process").

• Certification and evidence: The ARC reserves the right to seek evidence supporting certification of applications at any point and may impose additional certification requirements where breaches of the Australian Code have been found (clauses 7.1.4 and 4.5). Applicants should maintain records and supporting documentation for partner contributions, in-kind valuations and conflict disclosures, and be prepared to provide them.

Confidentiality and publication tensions

• Publication obligations: The ARC will publish project details including named participants, project description, National Interest Test statement and grant amount on GrantConnect within 21 calendar days of the date of effect. Applicants should avoid including confidential information in the project title, summary or National Interest Test statement that could compromise IP or confidentiality (see "Advice and Announcement" clauses 9.1-9.3).

• FOI exposure: All documents held by the Australian Government are subject to FOI; marking material confidential does not guarantee non-disclosure, albeit the ARC will treat information as confidential if specific criteria are met (see "Confidential information" and "Freedom of information").

Appeals and dispute resolution limits

• Narrow appeal scope: Appeals are limited to administrative process errors and cannot challenge substantive assessment outcomes, assessor ratings or committee decisions. Appeals must identify a specific guideline clause, policy or procedure alleged to have been misapplied and require institutional authorisation to lodge (see "Appeals process"). Applicants expecting merit review should not rely on the internal appeals mechanism.

Security and inter-agency review

• Security checks and ministerial powers: The ARC may seek advice on security or other matters from Commonwealth agencies during assessment, and may require information about activities and protections in response (clause 8.1.3). The Minister may at any time decide an application should not be approved for security, defence or international relations reasons (section 1). Applicants should expect possible security-related enquiries for certain topics or partners.

Practical timing traps

• Grant agreement execution timeline: The grantee has 30 calendar days from the date of offer to execute the grant agreement; the ARC will not make payments until the agreement is executed, and is not responsible for any project expenditure before execution (see "Grant Agreements" and "How we pay the grant"). Administering Organisations must plan cashflow accordingly.

Valuation and audit of in-kind contributions

• Documentation and audit risk: In-kind contributions must be valued on an appropriate basis and documented; the ARC may require these calculations to be audited. Over-stating in-kind values risks later disallowance (Glossary "In-kind contribution").

These "gotchas" are concrete statutory and administrative constraints that practitioners must manage in proposal design, partner selection, budgeting, governance arrangements and pre-award compliance activity.

This section sets out practical, source-grounded steps an Administering Organisation and project team should take to assemble an application and manage a grant in line with the guidelines.

1. Verify Administering Organisation eligibility

• Confirm the Administering Organisation is one of the Eligible Organisations listed in Appendix B. If not listed, the organisation cannot submit applications as Administering Organisation (see Appendix B).

2. Secure and document Partner Organisations

• Identify Partner Organisations that are not Eligible Organisations or controlled entities of Eligible Organisations, and ensure they are not listed on the National Redress Scheme’s list of institutions that have not joined or signified intent to join (clauses 4.8-4.11).
• Obtain a Letter of Partner Organisation Certification using the proforma from GrantConnect for each Partner Organisation (clause 4.9(c)).

3. Structure and certify Partner contributions correctly

• Ensure total Partner Organisation contributions (cash plus in-kind) at least match the total ARC funding requested and that eligible cash contributions equal at least 25 per cent of the ARC funding requested unless all Partner Organisations are Exempt Partner Organisations (clause 4.3).
• Confirm Partner Organisation cash contributions are not sourced from Commonwealth or State/Territory research appropriations, nor from funds previously used to leverage government research or infrastructure funding (clause 4.12(a)). Document funding sources for auditability.
• If any Partner Organisation is predominantly government-funded for research, ensure their combined eligible contribution does not exceed 25 per cent of the required Partner contribution; additional contributions can be provided but cannot be counted toward the required amount (clause 4.14).

4. Confirm participant eligibility and capacity

• For each CI, ensure they meet the CI criteria: employed at least 0.2 FTE by an Eligible Organisation or hold an honorary academic appointment at an Eligible Organisation, reside in Australia for more than 50 per cent of the project period, will not undertake an HDR during the project, and that the first-named CI (Project Leader) can manage the project (clauses 4.17-4.20).
• For PIs representing Partner Organisations, ensure they have an appropriate role within that Partner Organisation (clause 4.21).

5. Check project counts and, if necessary, adjust roles

• Verify that named participants do not exceed the maximum concurrent Linkage Program project limit of four as a CI or Director, accounting for the specific counting rules set out in the guidelines. If limits are exceeded, obtain ARC approval for Variations before submission to withdraw or relinquish roles (clauses 4.25-4.29).

6. Prepare compliant budget and expenditure plan

• Ensure the budget excludes prohibited items such as CI/PI salaries, medical research costs as defined in the ARC Medical Research Policy (2020), experimental development, capital works, basic facilities, and other excluded items listed in clause 5.2.
• Observe caps: teaching relief up to $50,000 per CI per year and travel averaging not more than $20,000 per year, while noting exceptions for essential field research and carer travel costs (clause 5.1).
• Value in-kind contributions carefully, document the valuation methodology consistent with the Glossary, and retain supporting documentation in case of audit (Glossary "In-kind contribution").

7. Prepare required documents and statements

• Draft the National Interest Test statement articulating benefits beyond the grant period in plain English, as required (see "National Interest Test Statement").
• Prepare a project title and summary that avoid disclosing commercially sensitive or confidential IP information, because these items will be published on GrantConnect if funded (see "Advice and Announcement").
• Ensure CIs take responsibility for authorship and intellectual content and that all named participants have met their obligations regarding previously funded projects, including the submission of satisfactory final reports to the ARC (clauses 4.6.1 and "Chief Investigator responsibilities").

8. Address research integrity, ethics and data management

• Prepare and document an ethics plan; the guidelines require an ethics plan be in place before commencement of the project (see "Specific research policies and practices").
• Prepare a data management plan consistent with ARC expectations and the grant agreement requirements (see "Specific research policies and practices").
• For projects involving Aboriginal and/or Torres Strait Islander research, set out engagement, benefit-sharing, Indigenous leadership and capacity-building strategies, and ensure adherence to AIATSIS, NHMRC and Indigenous data sovereignty principles as required by the Project Quality assessment criterion (assessment criterion a).

9. Manage conflicts of interest and privacy compliance

• Collect conflict of interest declarations from named individuals and organisations as required at the time of submission, and document processes to manage conflicts for the duration of the project consistent with the Australian Code and ARC Conflict of Interest Policy (see "Conflict of interest").
• Ensure compliance with the Privacy Act 1988 including Australian Privacy Principles, and flow-down equivalent obligations to subcontractors. Maintain records of consent and data-handling arrangements (see "Privacy and protection of personal information").

10. Use RMS and follow application timing rules

• Complete the application in RMS and follow Instructions to Applicants published at the grant opening; do not expect to modify the application after the closing date unless invited by the ARC (see "Application process").
• If you wish to name up to three individuals you do not want assessing your application, lodge a Request Not to Assess form in RMS at least two weeks before the grant closing date, providing supporting evidence if the request names ARC College of Experts members (see "Requests not to assess process").
• Prepare to use the rejoinder to respond to Detailed Assessors’ written comments; plan for a rejoinder response in your application timeline (see "Rejoinder process").

11. Prepare grant agreement and governance arrangements

• Review the sample ARC Linkage Program grant agreement available on GrantConnect in advance, and prepare to execute the agreement within 30 calendar days of offer if successful (see "Grant Agreements").
• Negotiate IP arrangements among the Administering Organisation, Partner Organisations and Other Organisations before project commencement, and document governance and decision-making arrangements to satisfy the Strength of proposed research alliance assessment criterion (assessment criterion d).

12. Plan for monitoring, reporting and financial control

• Prepare systems for regular reporting through RMS, including end-of-year and final reports, and plan for post-project reporting and potential evaluations (see "Monitoring and reporting").
• Implement internal controls to segregate ARC-funded project expenditure from ineligible uses, and ensure no ARC-claimed expenditure is made prior to grant agreement execution.
• Maintain auditable records of in-kind valuations, cash receipts from Partner Organisations, and payment receipts so the ARC can re-examine claims and, if required, conduct an independent audit.

13. Communications and publication readiness

• Draft a public-friendly project description and National Interest Test statement that do not compromise IP or confidentiality, keeping in mind that the ARC may publish a project description different to the application and will list project details on GrantConnect within 21 calendar days of date of effect (see "Advice and Announcement").

14. Prepare for security and inter-agency queries

• Be prepared to provide information about project activities and protections if sought by the ARC in response to Commonwealth agency advice on security or other matters, and ensure Partner Organisations can meet any additional due diligence questions (clause 8.1.3).

15. Audit readiness and dispute plans

• Retain documentation supporting all certifications in the application, including conflict disclosures and partner contribution calculations, for the duration of the project and beyond, since the ARC may request these as part of monitoring or audit processes.
• If an administrative process issue arises, follow the ARC appeals process requirements, noting the appeal must be limited to alleged administrative process errors and must be authorised by the Administering Organisation’s Deputy Vice-Chancellor (Research) or equivalent.

Following these steps will align the project planning and application process with the specific requirements in the guidelines. Keep a checklist cross-referenced to the clauses cited above and to the ARC website materials (Instructions to Applicants, sample grant agreement and proforma Partner Organisation certification) to reduce the risk of inadvertent non-compliance.