Frameworks beyond the GBER

Against this backdrop, targeted frameworks such as the Clean Industrial State Aid Framework (CISAF) and the Middle East Crisis Temporary State Aid Framework (METSAF) should be understood. These instruments do not replace the general state aid rules, including GBER. Instead, they complement them and provide additional room for Member States to pursue specific economic policy objectives.

The two frameworks perform different functions within this multi-layered regulatory environment. While CISAF primarily supports investments related to the green industrial transition and long-term competitiveness, METSAF is a temporary instrument specifically designed to address an acute economic shock. What they have in common is that both enable targeted, rapid and situation-specific interventions while remaining integrated into the existing state aid architecture.

CISAF: A framework for supporting the green industrial transition

CISAF was adopted by the European Commission on 25 June 2025 as the state aid pillar of the Clean Industrial Deal. Its primary objective is to enable Member States to support green transition investments quickly and at scale while safeguarding the integrity of the Single Market.

The framework covers several key areas:

• deployment of renewable energy and clean energy systems,
• industrial decarbonisation, particularly in energy-intensive sectors,
• expansion of clean technology manufacturing capacities,
• electricity cost compensation and competitiveness support.

One of the most significant innovations of CISAF is the substantial relaxation of state aid approval requirements, particularly in sectors where European industry faces increasing global competitive pressure, such as from the U.S. Inflation Reduction Act (IRA) or Chinese industrial policy. In practice, the EU is moving from a largely reactive competition-control model towards a more proactive industrial policy financing approach.

The framework will remain in force until the end of 2030, creating a stable and predictable environment for long-term investments.

METSAF: A rapid response to a geopolitical shock

Unlike CISAF, METSAF is a classic crisis-management instrument introduced by the European Commission on 29 April 2026 to mitigate the economic consequences of the Middle East crisis.

The immediate rationale behind the framework was that the conflict led to:

• higher energy prices,
• rising fuel and fertiliser costs,
• significant cost shocks affecting businesses across the real economy.

Accordingly, the purpose of METSAF is not structural transformation but the rapid management of liquidity constraints and cost-side pressures. The main target sectors include:

• agriculture and food production,
• fisheries,
• transport and logistics,
• energy-intensive manufacturing industries.

The framework provides several specific instruments, including:

• compensation of up to 70% of increased input costs,
• simplified aid schemes (e.g. up to EUR 50,000),
• higher aid intensities for electricity-related support.

An important feature of METSAF is its temporary nature. It is applicable only until 31 December 2026, clearly reflecting its emergency and short-term character.

The integrated logic of the two frameworks

METSAF explicitly builds on CISAF in several respects and even modifies certain elements of it. For example, it allows for increased aid intensities under specific CISAF measures, particularly in the field of energy price compensation.

What does this mean at Member State level?

It is important to underline that the entry into force of CISAF and METSAF does not automatically result in the introduction of new aid schemes in the Member States. Rather, these frameworks create regulatory and policy opportunities, enabling governments to design and implement relevant support programmes within the conditions defined by the frameworks and in line with their own priorities and budgetary capacities.

For companies to gain actual access to these instruments, Member States must take an active role. They must decide which elements of CISAF and/or METSAF they intend to apply and develop the specific aid programmes operating under these frameworks. Consequently, practical availability and the volume of support will largely depend on national-level implementation. In this respect, the recently formed Hungarian government may already take these instruments into account when reconsidering the future direction of state aid policy.

The professionals at Strategic Advisory, State Aid and Incentives business line of WTS Klient Hungary are at your disposal should you require expert assistance regarding state aid opportunities available to your company.

Feel free to contact us.

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Legal background

The Hungarian Government Decree 314/2025. (X.17.), published in the Official Gazette on 17 October and effective from the next day, amends Decree 210/2014. (VIII.27.) on the use of investment promotion funds.

According to the new provisions, the changes introduced to the grants provided by HIPA – the Hungarian Investment Promotion Agency – are designed to:

• encourage a greater number of clinical research projects to be conducted in Hungary, and
• align national regulations with the European Commission’s guidelines on state aid, as detailed in communication C/2025/3602.

Major changes in supporting R&D collaborations

One of the most significant updates to the EKD regulatory framework involves the treatment of costs related to contract research carried out jointly by companies and universities or healthcare institutions.

Previously, only up to 50% of such collaborative research costs could be claimed as eligible. As of 18 October, this threshold has increased to 75%.

This change is especially aimed at fostering the local implementation of clinical research, deepening collaboration between pharmaceutical and medical technology companies and Hungarian universities or clinics.

The broader objective is to strengthen Hungary’s position among international R&D hubs and support the expansion of its knowledge-based economy.

Introduction of the Clean Industrial Deal State Aid Framework (CISAF)

The domestic implementation of the Clean Industrial Deal State Aid Framework (CISAF) – approved by the European Commission over the summer – marks a key step toward more flexible and effective support for clean industrial investments.

The CISAF program specifically targets industries critical to achieving net-zero emissions, with a focus on the following areas:

• Development of clean technologies, such as solar panel systems, thermal energy storage solutions, and geothermal power plant manufacturing
• Production of key components for these technologies
• Extraction or recovery of critical raw materials essential to the advancement of clean industry.

This new support scheme is a cornerstone of Hungary’s ambition to play an active role in Europe’s green transition and sustainable industrial development.

Renewable energy and storage: updated grant conditions

Investments in renewable energy continue to be eligible for support under the HIPA system. However, the latest changes in the EKD regulatory framework clarify the eligibility criteria.

Support is now only available if the project involves not only the expansion of production capacity but also the installation of an energy storage system.

This approach aims to foster the development of stable and flexible energy systems, in line with Hungary’s goals for decarbonisation and energy independence.

The latest amendment to the EKD regulatory framework in Hungary opens up new opportunities for companies active in R&D and clean technologies. The Strategic Advisory, State Aid and Incentives business line of WTS Klient Hungary is ready to advise you on investment plans with expert guidance. Don’t hesitate to contact us!

This article provides general information and does not constitute advice.

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One of the key innovations of the new framework is the accelerated and simplified approval procedure, which aims to speed up the implementation of renewable energy programmes and related investments. The regulation facilitates the faster integration of solar and wind energy into energy systems and supports the rollout of low-carbon fuels such as blue and green hydrogen. Member States may provide aid to energy-intensive companies exposed to international competition, provided that they are willing to invest in decarbonisation. The framework is technology-neutral, meaning any investment contributing to greenhouse gas emission reduction or improved energy efficiency may be eligible for support.

CISAF defines a total of five aid categories. Aid for the deployment of clean energy covers renewable energy generation, storage, low-carbon fuels, flexibility solutions, as well as temporary price support for energy-intensive industries. Aid for industrial decarbonisation aims to reduce emissions from industrial activities or improve their energy efficiency, without increasing production capacity. The level of support can be set administratively, based on the funding gap, or through a competitive bidding process.

Aid for scaling up manufacturing capacity of clean technologies applies to products covered by the Net Zero Industry Act (NZIA) – including nuclear technologies – as well as their key components and the critical raw materials needed for production. In more developed regions such as Budapest, the support may cover up to 15% of eligible costs (maximum EUR 150 million), while in less developed regions – which comprise most of Hungary – the intensity can reach 35% (up to EUR 350 million). For small and medium-sized enterprises (SMEs), the aid intensity can be increased by an additional 10–20 percentage points. The framework also allows for accelerated depreciation of investments.

In addition, individual projects positively evaluated by the EU under the Innovation Fund are also eligible for support. The fifth category focuses on de-risking green-oriented private investments through various financial instruments – such as public equity, loans, and guarantees – and may involve financial intermediaries.

CISAF is expected to serve as the basis for new national-level support schemes across most Member States, helping to more effectively encourage green investments.

On 25 June 2025, the European Commission adopted a new state aid framework in support of the objectives of the Clean Industrial Deal: the Clean Industrial State Aid Framework (CISAF), which will remain in force until 31 December 2030.
If you have any questions regarding the topic discussed in this article, the experts of WTS Klient is always ready to assist you with professional support.

This article provides general information and does not constitute advice.

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