Yes, Implementing Partner can decide to participate without requesting any funding. However, it will imply to perform monitoring and reporting activities included in the SGA, according to its Annex 1 “Description of the Action”. Please refer to Article 18 of the Model Specific Agreement, which you can find at the following link: https://ec.europa.eu/inea/sites/inea/files/model_grant_agreement_en.pdf. It’s worth noting that in such cases, those beneficiaries will not be subject to all the obligations normally foreseen for the other beneficiaries (e.g. they will not be subject to financial audits nor will they have to submit an IFS or CFS).