State Aid: The CISAF After Its First Year: What Have We Learned?

The EU State aid rules have shifted over the past decade. From traditionally placing tight limits on targeted investment aid, the State Aid framework has now been adapted to give Member States more room to support investments in innovation, the green transition, and strategic industrial projects.

Key Takeaways

• The Clean Industrial Deal State Aid Framework (CISAF) was adopted and became applicable on 25 June 2025 and remains in force until 31 December 2030. It makes part of the Temporary Crisis and Transition Framework (TCTF) permanent and widens the range of aid options and eligible technologies.
  Uptake of schemes under the CISAF is uneven: 16 Member States have obtained approval for a total of 32 aid schemes under the CISAF, with Spain, France, Italy and Austria accounting for half of the approved schemes. Sweden, Finland, and the Baltic States are among the countries with no scheme approved so far.
• The largest approved schemes support renewable energy production, including a EUR 63 billion French offshore wind scheme and a EUR 23 billion Italian scheme, both using two-way contracts for difference (CfDs). The most common type of scheme supports investment in clean technology manufacturing, with budgets ranging from EUR 6 million to EUR 4,100 million.
• France’s C3IV tax credit scheme offer early evidence of impact: 73 projects have received aid since 2024 and are expected to trigger 22 billion of industrial investment by 2030. The CISAF extension with a budget of EUR 1,100 million, is expected to support around 40 additional projects.
• The CISAF reiterates that not all State investments constitute State aid. Public co-investment on market terms, such as equity stakes in green industrial projects, therefore offers an alternative to aid, provided market terms are documented before the investment decision.

Frequently asked questions

What is the CISAF and when did it enter into force?
The CISAF was adopted and became applicable on 25 June 2025. It replaces the TCTF and remains in force until 31 December 2030. It carried over and extended elements of the TCTF, added new aid options, and widened the range of eligible technologies.

How many Member States have used the CISAF so far?
Since its entry into force, 16 Member States have obtained approval for a total of 32 aid schemes under the CISAF. Spain, France, Italy and Austria account for half of the approved schemes. Other countries with more than one scheme are Czechia, Denmark, Germany, and Slovenia. Sweden, Finland, and the Baltic States are among the countries with no scheme approved so far.

What types of schemes have been approved under the CISAF?
Three broad categories have emerged: schemes supporting renewable energy production (the largest in budget, using two-way contracts for difference), schemes easing the impact of high electricity prices on energy-intensive companies, and schemes supporting investments in clean technology manufacturing, which is the most common type.

Does public co-investment always count as State aid?
No. The CISAF reiterates that not all investments by the State constitute State aid. When the State acts as a market economy investor, it can co-invest alongside private parties without this constituting State aid, provided the investment is made on market terms as assessed under the market economy operator (MEO) test.

Main article

Background
The EU State aid rules have shifted over the past decade. From traditionally placing tight limits on targeted investment aid, the State Aid framework has now been adapted to give Member States more room to support investments in innovation, the green transition, and strategic industrial projects.

Last year, on 25 June 2025, the CISAF was adopted and became applicable, which took this shift a step further. The CISAF, which replaces the TCTF and remains in force until 31 December 2030, carried over and extended elements of the TCTF, and added new aid options and widened the range of eligible technologies. Like the TCTF, the CISAF puts particular weight on aid for capital-intensive green industrial investments.

The CISAF has now been in place for more than a year. In this post, we look at how Member States have used it so far and what to expect next.

Uneven Uptake Across Member States
Since its entry into force, 16 Member States have obtained approval for a total of 32 aid schemes under the CISAF. Spain, France, Italy and Austria account for half of the approved schemes. Other countries with more than one scheme are Czechia, Denmark, Germany, and Slovenia. Sweden, Finland, and the Baltic States, are among the countries with no scheme approved so far.

Figure 1: Number of aid schemes approved under the CISAF
Number of schemes

Source: The European Commission’s Press Corner, link.

Scheme sizes can vary considerably, mainly depending on the scheme’s objective. The largest schemes that have been approved support renewable energy production. For example, in July 2026, the Commission approved a EUR 63 billion French scheme running for 25 years for the construction and operation of eleven offshore wind farms, and in June 2026, a EUR 23 billion Italian scheme for renewable energy production such as onshore wind, solar, and hydropower. Both grant aid through so-called two-way contracts for difference (CfDs): the beneficiary receives the difference when the market price falls below the strike price, and must pay back the difference when the market price exceeds it. Their large budgets reflect long contract periods of 20 years in Italy and 25 years in France.

A second group of schemes has been set up to ease the impact of high electricity prices on energy-intensive companies. A few Member States particularly exposed to volatile electricity prices have set up schemes for this purpose.

The most common type of scheme is designed to support investments in the manufacturing of clean technology. Typically, under these schemes, projects that meet the eligibility criteria can apply for aid up to fixed caps. Budgets in this group range from as small as EUR 6 million to EUR 4,100 million.

Figure 2: Budgets of CISAF schemes supporting clean technology manufacturing
Million EUR