New detailed procedure for EKD decision-making

The primary objective of the ministerial instruction is to provide a uniform and transparent framework for the entire process of granting subsidies from the investment promotion budget appropriation. The regulation sets out in detail the responsibilities of HIPA, the ministry and investors from the submission of the subsidy request through to the closing of the grant agreement, thereby ensuring a predictable operating environment for investors.

Investment decision-making has resumed

The regulatory changes are particularly timely because, after spring 2026, the substantive assessment of investment applications submitted to HIPA essentially came to a halt. Over the past few months, the Ministry of Economy and Energy reviewed the cases in progress, and the first Investment Committee meeting was then held in July, where eight projects were already discussed. The decisions enabled HIPA to continue negotiations with investors in relation to several projects.

Based on the government’s strategic priorities, in the new investment promotion system, increasing emphasis will be placed in the future  on:

• high added value,
• innovation content,
• research and development activities,
• technology transfer,
• and the involvement of Hungarian suppliers and universities

when assessing investments.

More time available for project preparation

One of the most important elements of the new procedure is the extension of the timeframes available to investors.

According to the rules:

• the conditional grant offer remains valid for 12 months, instead of the previous 6 months;
• following acceptance of the offer, 24 months are available for finalising and signing the subsidy agreement, compared with the previous 12-month time limit;
• both deadlines may be extended once by a further 12 months.

This is particularly advantageous for large-scale investments implemented by international corporate groups, where internal approval, financing or permitting processes may often take several months. The longer timeframe available may reduce the risk of a subsidy process being delayed purely for administrative reasons.

The role of R&D and innovation is strengthening

Both the new regulation and the investment policy priorities formulated by the ministry indicate that knowledge-intensive investments will receive particular attention in the future. The procedure addresses research and development projects separately at several points and assigns a key role to the R&D qualification issued by the National Research, Development and Innovation (NRDI) Office.

This is in line with the objective that subsidies should primarily support investments that

• create higher added value,
• bring advanced technology to Hungary, and
• strengthen the country’s innovation capacity.

Institutional renewal at HIPA

As part of the renewal of the investment promotion system, Buday Bence has held the position of CEO of HIPA since 28 July 2026.

The change in leadership does not in itself entail any change to the conditions of the subsidy schemes; however, it fits well into the process aimed at restarting investment promotion decision-making and ensuring more predictable and faster administration for investors.

What should investors do?

For companies considering EKD subsidies, the new investment promotion system may represent a favourable opportunity. The modified decision-making mechanisms have become operational, the procedure has been clarified, and the time available for project preparation has been extended significantly. At the same time, it remains advisable to start developing the subsidy strategy at an early stage of the investment, with particular attention to properly presenting the R&D, innovation and high added value-creating elements, which are playing an increasingly important role in subsidy decisions.

STATE AID

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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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