Closed bounded acquisition, 9 September 2026. Three primary originals retained; one deliverable read selectively. This note makes no finding about the current operation of an advertising exclusion list.
The identified project is AI4TRUST, grant 101070190, running 1 January 2023–28 February 2026, with an EC signature dated 6 December 2022. CORDIS, last updated 17 June 2026, labels it closed. The registered German participant is GDI GLOBAL DISINFORMATION INDEX GUGHAFTUNGSBESCHRANKT. Its published net EU contribution and total cost are each EUR 385,275. The whole-project contribution/cost is EUR 5,950,682.50 and must not become GDI income. Fondazione Bruno Kessler coordinates the Horizon research action. [CORDIS, project header, programme and German GDI participant entry](http[local research file]
GDI appears in the participant section, separate from the section describing partners that do not sign the grant. This supports a funded participant characterization rather than an associated-partner or UK-guarantee claim. The financial field is the registry's published EU contribution; no dated transfer ledger was acquired. Neither ownership of the German entity by UK Disinformation Index Ltd nor an IP transfer between them is established. The existing UKRI identity in the case is not joined to this project.
This is a confirmed GDI Horizon project active during the April 2024 FON0071 disclosure. It is the strongest identified match, not an explicit identification of that disclosure's unnamed grant or proof that it was GDI's only Horizon project. The earlier statement and this record are distinct sources with different specificity.
D2.1, submitted 1 November 2023, records coordinator and quality-manager review (PDF 2–3). Its selected definitions distinguish project emphasis on intent from GDI's risk-based alternative (11–12). GDI's described NLP method uses analyst-coded examples and semantic matching to flag websites for human review (34–35). Existing GDI keyword lists contributed to the project's search seeds (55). Planned collection is purpose-limited, and consortium interface access depends on data-sharing agreements (65). The internal GDI policies mentioned at 69 are not reproduced. [D2.1 original](http[local research file]
The document's internal acceptance/submission labels do not prove Commission acceptance. Query refinement is not publisher recourse. The NLP licensing guidance crossing pages 68–69 is introduced for NCSR-D/FBK; it must not be assigned to GDI as an executed licence. This is a design record, not a runtime audit.
In its 20 April 2026 retrospective, GDI reports developing the decision-support system within the Monitoring Dashboard: combined detection signals, trained using consortium fact-checker annotations, surface risk patterns for human review. It also requests faster Article 40 vetting, mandatory platform API compatibility with approved third-party detection systems, and researcher audit access. [GDI retrospective, “What AI4TRUST delivered” and “Recommendations”](http[local research file]
That is a meaningful reported research contribution → request for institutional access. The platform refusals described in the same article remain GDI's account: the applications and responses were not acquired. The article is not a legal instrument, award of access, or proof that a platform implemented the requested compatibility.
The strongest actual knowledge-flow evidence runs from GDI's existing resources into funded methodology. The retrospective supplies a later, attributed output claim. No selected record identifies that output with DEL, the former Oracle segment, IAS's former input, or the prospective OHMD. Similar risk terminology does not establish shared code, training data, licences, recipients or commercial deployment. Nothing here establishes that FCDO commissioned these inputs or directed subsequent exclusions.
For later integration, useful relations are the EU contribution recorded against the German participant; that participant's research role; GDI's pre-existing resource contribution to D2.1; the documented internal report review; the attributed Monitoring Dashboard contribution; and GDI's request for new access obligations. Keep the April 2024 grant match qualified, financial allocation separate from cash, and requested authority separate from an awarded right. No graph edits were made.
The strongest rival explanation is ordinary consortium research using participants' prior expertise, followed by advocacy about research access. The present records support that account at least as well as a theory of publicly funded commercial exclusion infrastructure. The latter requires an additional documented transfer or use.
The highest-value missing record is the AI4TRUST consortium agreement's GDI background/results and exploitation or access-rights schedules, or a specific licence tying its decision-support output to a named commercial product. Likely holders are the project coordinator and relevant GDI legal participant. D2.1 also points to data-management/platform specifications, but this run did not acquire another deliverable or treat generic grant rules as exercised powers. A grant accession/payment record would settle finer legal and money-state questions; a corporate record would settle the UK/German relationship. The named annotation codebook and final decision-support thresholds/validation are further precise records needed to test classification choices. The codebook and internal policies are expected records, not evidence of bias. These are reopening conditions, not claims that the documents do not exist.
Originals: horizon-cordis.html, horizon-gdi2026.html, horizon-d21.pdf. horizon-cordis.full-dom.txt preserves header/date fields omitted by the narrower main-text extraction. The 90-page PDF was not read in full: text scope is PDF 1–5, 9–12, 34–35, 53–55, 60–65, 68–69. Images actually viewed: 2, 3, 11, 35, 55, 65. PDF 2 visually emphasizes Public, UCAM reviewer, Coordinator accepted and Ready for submission; its boxes are not filled checkmarks. No Commission approval is inferred. No keyword annex, live dataset or operational interface was used.
The PDF reader returned an Internal Error; one ordinary GET then retained the original successfully. CORDIS and GDI originals also returned 200. No further acquisition route was opened. Exact files, hashes, dates and source scopes are in horizon-captures.json; transport evidence remains in horizon-transport.json.