A New Era in EU State Aid Policy: CISAF Enters into Force

On 25 June 2025, the European Commission adopted the new Clean Industrial State Aid Framework (CISAF), a state aid scheme designed to promote investments aimed at establishing a “clean industry.” The framework offers Member States new opportunities to provide state aid to support such investments. The Commission’s objective is for Member States to support companies in their green industrial transition through simplified and targeted state aid instruments, thereby enhancing the European Union’s global competitiveness. In this article, we provide an overview of the key aspects of CISAF.

CISAF is closely linked to the objectives of the European Green Deal, adopted in 2019, under which the Union committed to achieving net zero emissions by 2050, aiming to make Europe the first carbon-neutral continent.
Achieving climate neutrality requires European industry to reduce its emissions while ensuring the domestic production—within the EU—of the technologies needed for the transition, such as heat pumps, electrolysers, batteries, and renewable energy generation equipment.

CISAF becomes one of the key instruments of the Green Deal: it aims to promote investments that contribute to the decarbonization of the energy and industrial sectors.

Until 2030, CISAF provides Member States the opportunity to use state aid to support private and state investments in renewable energy, the decarbonization of energy-intensive industries, the development of clean technology manufacturing capacities, and the compensation of competitive disadvantages caused by energy prices—thus contributing to the achievement of the Green Deal’s goals.

To ensure a competitive transition to the net zero economy, the European Commission introduced the Clean Transition Dialogues in February 2025. This initiative focuses on the following priority areas:

European industry faces significant challenges in global markets as European companies are often at a competitive disadvantage due to factors such as rising energy costs, global competition for clean technology manufacturing capacity, the regulatory pressure within the EU next to the legal requirements to reduce CO₂ emissions.

As a result, European companies are expected to remain globally competitive while also complying with EU climate and regulatory requirements—often incurring additional costs and administrative burdens compared to their international competitors.

The European Union acknowledges these challenges and recognizes that companies cannot successfully overcome them on their own. Therefore, it has established a new state aid framework: CISAF.
The ultimate goal of CISAF is to enhance the EU’s competitiveness without compromising its climate objectives.

Until 2030, CISAF enables Member States to support, through state aid and in various forms:

CISAF is thus a framework that allows Member States to design various aid schemes aligned with these objectives. However, any aid measure must be notified to and approved by the European Commission in advance.

Compared to state aid measures for other objectives, CISAF provides more flexible conditions for these types of support schemes.

It is important to stress that CISAF is an option—not an obligation—for Member States. They may choose to create aid schemes that fully comply with the CISAF conditions, but they are not required to establish or implement support programs under CISAF.

In our summary we are presenting how does the framework defines the priority areas and aid instruments:

Objective area	Aid form	Aid conditions			Bonus
		Competitive Bidding	Max. aid intensity	Max. aid
1. Rollout of renewable energy	1.1.Investment aid	In some cases mandatory	45% in case of administratively set 100% in case of competitive bidding	N/A	20-10% SME bonus
	1.2. Direct price support schemes	In some cases mandatory	N/A	May cover eligible costs (in case of renewable energy production).	N/A
2. Low-carbon fuels	2.1. Investment aid	In some cases mandatory	20% in case of administratively set 100% in case of competitive bidding	N/A	20-10% SME bonus
	2.2. Direct price support schemes	Mandatory	100%	N/A	N/A
3. Non-fossil flexibility support	3.1. Investment aid	Mandatory	N/A	N/A	N/A
4. Aid for capacity mechanisms for a target model	N/A	N/A	N/A	N/A	N/A
5. Temporary electricity price relief for energy-intensive users	Price compensation	N/A	50% (compared to annual consumption)	Decreased price shall not go under 50 €/MWh	10% in case realizing decarbonization investments
6. Aid for the decarbonisation of industry	Investment aid	Member states can decide to apply competitive bidding	60% for investments enabling the use of hydrogen or hydrogen-derived fuels, where the share of renewable fuels of non-biological origin (RFNBOs) is at least 40 % 45% for investments in the production of renewable energy, energy storage, investments in flexible electrification, investments in carbon capture equipment 35% for investments enabling the use of low-carbon fuels; 20% a for investments in the production of low-carbon fuels; 30% for all other technologies.	Under EUR 200 million For amounts exceeding EUR 200 million, an individual notification to the Commission is mandatory regarding the assessment of the funding gap.	10-5% SME bonus
7. Aid to ensure sufficient manufacturing capacity in clean technologies	Investment aid	N/A	15% of the eligible costs outside assisted areas 20% of the eligible costs at assisted „c” areas 35% of the eligible costs at assisted „a” areas	EUR 150 million outside assisted areas EUR 200 million of the eligible costs at assisted „c” areas EUR 350 million of the eligible costs at assisted „c” areas	20-10% SME bonus
8. Ad hoc aid	Investment aid	N/A	N/A	The lower of either: (i) matching aid, (ii) funding gap	N/A
9. Demand-support for clean technology equipment (Accelerated depreciation)	Accelerated depreciation	N/A	N/A	Accelerated (including immediate and full) depreciation of equipment purchase or leasing costs	N/A
10. Schemes to support specific Innovation Fund projects	10.1. Investment aid 10.2. Tax allowance 10.3 Loan 10.4. Guarantee	Projects receiving funding from the Innovation Fund	25% outside assisted areas 40% at assisted „c” areas 55% at assisted „a” areas	EUR 150 million /project outside assisted areas EUR 200 million /project at assisted „c” areas EUR 350 million /project at assisted „c” areas	20-10% SME bonus
11. Aid to reduce risks of private investments in renewable energy, industrial decarbonisation, clean technology manufacturing and energy infrastructure, or projects supporting the circular economy	11.1. Capital injection	N/A	N/A	EUR 250 million	N/A
	11.2. Loan	N/A	N/A	N/A	N/A
	11.3. Guarantee	N/A	N/A	N/A	N/A

When Does CISAF Apply?

The CISAF framework is applicable from 25 June 2025 until 31 December 2030.
The new framework replaces the Temporary Crisis and Transition Framework (TCTF) introduced in 2023. CISAF is designed for a longer timeframe and offers more structured rules, incorporating the experiences gained under TCTF. As a result, CISAF covers a broader scope than TCTF.
Note that the entry into force of CISAF does not affect support schemes already approved under TCTF — those remain valid until 31 December 2025, as stated in the respective Commission decisions.

What Does This Mean for Hungarian Companies?

The entry into force of CISAF does not automatically create new aid opportunities for Hungarian companies (or companies in other Member States). The implementation of CISAF-based support schemes requires national-level adoption and definition of aid schemes.

Given the growing international competition to attract clean industrial investments, Member States are expected to introduce various CISAF-based support measures in the upcoming period.

For more information on CISAF-related support opportunities, please contact our experts.