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.

A METSAF and CISAF in the EU State Aid System bejegyzés először WTS Klient Hungary | tax | accounting | payroll | advisory | HR services | digital solutions | state aid-én jelent meg.

Over the years, the GBER has become increasingly essential for EU‑level economic development, as it ensures the following benefits:

• Speed: Member States can launch programmes rapidly without waiting for ex‑ante Commission authorisation.

• Predictability: The regulation clearly defines which types of aid and conditions apply automatically, enabling both managing authorities and beneficiaries to anticipate requirements.

• Legal certainty: Aid granted under the General Block Exemption Regulation is presumed lawful, minimising the risk of the Commission later determining the measure to be unlawful state aid.

In 2026, the European Commission proposed the most extensive revision of the General Block Exemption Regulation to date. The public consultation runs until 23 April 2026, and the new framework is expected to enter into force in January 2027. Through this reform, the EU aims to create a framework that is simultaneously:

• faster and more flexible,
• better aligned with the green and digital transitions,
• supportive of broader social and regional objectives,
• while continuing to safeguard fair competition.

Easier implementation, reduced administrative burden

One of the primary goals of the proposed amendments is to reduce administrative burdens for both aid‑granting authorities and applicants. This includes encouraging broader use of simplified cost options, which significantly ease documentation requirements.

These simplified methods include:

• lump sums,
• unit costs, and
• flat‑rate financing.

The draft proposal would also eliminate the mandatory evaluation plans required for large‑budget aid schemes – an obligation that previously consumed substantial resources. This measure would enable faster programme launch and more efficient implementation.

Aid could also become easier to grant for smaller‑scale projects. In certain areas – such as R&D or environmental projects – higher aid intensities may become available regardless of company size. Higher aid intensities reduce the required private contribution, thereby improving access to funding.

This is particularly advantageous in sectors where projects require high upfront investment or where innovation involves significant risk – areas in which many companies have so far been excluded due to the high level of own financing previously required.

Prioritising the green and digital transitions

The reform of the General Block Exemption Regulation – fully aligned with EU strategic objectives – puts an increased emphasis on climate neutrality and technological progress.

The new rules would:

• simplify the framework for environmental and energy‑related aid, and
• significantly expand the range of support available for renewable energy, energy efficiency and decarbonisation.

For operating aid in renewable energy schemes, the proposal would abolish the current EUR 300 million annual programme cap, enabling Member States to launch substantially larger schemes. This is particularly relevant given the rapid expansion of green energy investments. The maximum aid per beneficiary would, however, remain in place to prevent distortions of competition.

Digitalisation appears as an independent aid category under the revised regulation. The new measure supporting digital transition for SMEs and small mid‑cap companies reflects the EU’s recognition that technological upgrading is essential for competition, innovation and economic dynamism across the European internal market. Digitalisation‑related investments – such as automation, cybersecurity or digital infrastructure – would become eligible more easily and rapidly.

Strengthening social and regional objectives

The proposed amendments support not only economic growth, innovation and climate neutrality, but also social cohesion.

As part of this:

• a completely new category – aid for social enterprises – would be introduced, offering favourable conditions for public‑benefit activities;
• to address the housing crisis, the Commission would allow higher aid intensities for energy‑efficiency renovations of social and affordable housing.

From a regional perspective, a key development is that agriculture, fisheries and aquaculture would fall more broadly under the scope of the new General Block Exemption Regulation, enabling regional investment aid to be granted even for primary agricultural producers. This would significantly contribute to the economic development of rural areas.

Owing to the ongoing transformation of the labour market, the proposal places strong emphasis on training and reskilling, especially in digital, technological and STEM competences. This responds both to labour shortages and to the growing need for new skills – while also acting as a prerequisite for a successful green and digital transition.

The significance of the reform

The comprehensive reform of the General Block Exemption Regulation represents a strategic turning point in EU state aid policy. The framework expected in 2027 is not a mere technical adjustment; it is a broad‑based modernisation that will shape EU state aid policy for the next decade. Consequently, once implemented, it may significantly transform the state aid framework based on Individual Government Decisions (EKD) in Hungary.

The objective of the amendments of the General Block Exemption Regulation is to ensure that the aid environment can respond more flexibly to rapidly evolving technological, environmental and market challenges, while strengthening competitiveness and Member State autonomy. As the reform requires companies to rethink their approach to investment‑related aid in the long term, we recommend seeking expert support. The Strategic Advisory, State Aid and Incentives business line of WTS Klient Hungary is ready to assist you. Please feel free to contact us!

This article provides general information and does not constitute advice.

A Renewal of the General Block Exemption Regulation bejegyzés először WTS Klient Hungary | tax | accounting | payroll | advisory | HR services | digital solutions | state aid-én jelent meg.