The 2025 Edition of the State Aid Scoreboard

The 2025 Edition of the State Aid Scoreboard - State Aid Uncovered photos 98

• In 2024, the total non-crisis state aid granted by Member States reached EUR 152 billion, an increase of 11% over the previous year.
• The three most important policy objectives were environmental protection & energy savings, research and regional development.
• The General Block Exemption Regulation was the basis for about 3200 measures delivering EUR 60.1 billion of aid.
• More than 80% of the state aid for research and for regional development was granted through GBER-based measures.

Introduction

On 15 January 2026, DG Competition published the 2025 edition of the State Aid Scoreboard. This year it arrived much earlier than previous editions.[1] The Scoreboard is one of three valuable sources of statistics, information and analysis on state aid amounts and the objectives that Member States support. The other two are the annual competition reports and the register of state aid awards.

This latest edition of the Scoreboard presents the overall trends in state aid over time and across Member States, the use of different forms and instruments of aid and the delivery of state aid via block-exemption regulations. In addition, it has special chapters examining in more detail state aid for net-zero emissions economy and digital growth and on crisis aid and annexes devoted to state aid for railways and financial institutions.

The overall picture

In addition to presenting the amounts, objectives and type of state aid granted by Member States in 2024, the Scoreboard also tracks the evolution of state aid over the past decade. The total amount of state aid granted by Member States in 2024 was EUR 168.2 billion [excluding railways and agriculture]. That corresponded to 0.9% of the EU’s GDP. The so-called “non-crisis” aid, i.e. excluding measures to alleviate the impact of the Russian invasion of Ukraine and the lingering effects of covid-19, was EUR 152 billion which represented a non-negligible increase over the previous year [since non-crisis aid in 2023 stood at EUR 137 billion, the increase in 2024 was 11% at current prices]. Covid-19 measures absorbed EUR 2.3 billion, while aid granted on the basis of the now expired Temporary Crisis and Transition Framework amounted to EUR 14.1 billion. Railways received EUR 38.4 billion.

The General Block Exemption Regulation [GBER][2] was the basis on which close to 3200 measures were implemented delivering about EUR 60.1 billion of aid. That is, the GBER-based measures accounted for 39% of the total non-crisis aid.

Member State rankings

The top five Member States in terms of absolute amounts of state aid were: Germany, France, Italy, Spain and Poland. The five least spending Member States were the two smallest and the three Baltic states: Malta, Cyprus, Latvia, Estonia and Lithuania. However, when state aid is measured as a share of the national GDP, the rankings change. The top five were: Hungary, Romania, France, Greece and Poland. This means that France and Poland which have big economies also tend to spend relatively more on state aid measures. At the other end of the spectrum, the Member States with the smallest share of state aid in relation to their GDP were: Portugal, Ireland, the Netherlands, Cyprus and Lithuania.

Although we would expect large Member States to grant more aid in absolute terms and small Member States to grant less, these rankings suggest that there is some correlation between the absolute amount of state aid and the “propensity” or “inclination” of Member States to provide subsidies. It is difficult to distinguish between the impact of large v small budgets and the willingness of public authorities to design state aid measures. Perhaps, those Member States that have more streamlined, less cumbersome and faster procedures manage to grant more aid in both absolute and relative terms. Afterall, how much aid is eventually granted also depends on how difficult it is for undertakings to apply for it.

Aid instruments

In terms of instruments used in the delivery of aid, 60% was in the form of a grant or interest rate subsidy. Three instruments accounted for more than 80% of total aid: Grants, interest subsidies and tax exemptions. If we exclude risk capital and capital injections, then the total amount of state aid that was granted in a non-reimbursable form exceeded 95% of total aid.

Tax exemptions were mostly used for two purposes: To exempt energy intensive users from energy taxes that would harm significantly their international competitiveness, and to incentivise investment in assisted regions.

The Scoreboard reveals a wide variation in the use of instruments across Member States. Some Member States such as Luxembourg, Bulgaria and Austria relied almost exclusively on grants and interest rate subsidies. Others, such as Finland, Sweden and France, granted more than 40% of the non-crisis aid in the form of tax advantages. In their case, the aid was intended to support green energy.

Grants were used almost exclusively to support individual households in the context of social policy, employment and important projects of common European interest. By contrast, tax incentives were used mostly for the support of regional and sectoral development, and to remedy the impact of spike in energy prices in the context of TCTF-based measures.

In the case of environmental and energy aid, the Scoreboard also indicates that about 35% of the aid amount was in an unspecified form [i.e. “other” instrument]. Most likely the aid was granted through competitive auctions or “contracts for difference” whereby, green electricity producers receive the lowest amount for which they bid in relation to other competitors and they pay back when the market price rises above the “strike” price.

Policy objectives

The three most important policy objectives, in terms of amounts of aid, were: Environmental protection and energy efficiency, R&D & innovation and regional development. They absorbed, respectively, EUR 67 billion, EUR 14 billion and EUR 13 billion. Together, they accounted for about 63% of total aid (non-crisis).

There was significant variation among Member States in the revealed importance attached to those three policy objectives, reflecting their policy priorities and, naturally, the eligibility of their regions for investment aid. With respect to the environmental protection and energy objective, the top three Member States, in terms of share of aid in their GDP, were: Germany, Czech Republic and Finland. The bottom three were: Bulgaria, Cyprus and Malta. With respect to the R&D & innovation objective, the top three Member States were: Belgium, Croatia and the Czech Republic. The bottom three were: Bulgaria, Malta and Romania. With respect to the regional development objective, the top three Member States were: Hungary, Croatia and Latvia. The bottom three were: Cyprus, Luxembourg and Denmark.

There were also considerable differences in terms of the chosen procedure for the delivery of the aid. While the GBER was the basis for 85% of R&D & innovation aid and 82% for regional investment aid, in the case of aid for environmental protection and energy savings, the GBER accounted only for 28% of the aid. The reason was that a few very large measures granted aid amounts that exceeded the notification thresholds laid down in the GBER.

Use of block-exemption regulations

In 2024, the GBER was the legal basis for the delivery of EUR 60.1 billion corresponding to 3187 new measures in 2024. The Scoreboard does not provide a breakdown of the number of GBER-based measures per Member State. But given the available figures, the average Member State implemented about 120 new GBER-based measures.

The Scoreboard, however, does provide figures for the agricultural and fisheries block exemption regulations which are respectively, 856 new measures and 58 new measures. The total amount of state aid for agriculture, forestry and rural development was EUR 10.4 billion. The amount for fisheries and aquaculture was 50 times less, at EUR 213 million.

Concluding thoughts

A close reading of the Scoreboard reveals the diversity and similarities of state aid policies of Member States. Since no EU rule obliges Member States to grant aid, absolute and relative amounts of aid vary significantly. At the same time, most Member States support primarily three policy objectives: Environmental protection and energy efficiency, research and regional development.

Naturally, their policy choices are very much shaped by what is allowed and how much is allowed by the block-exemption regulations and Commission guidelines. Despite the fact that, in principle, the Treaty on the Functioning of the EU and especially Article 107(3)(c), permits Member States to support indeterminate policy objectives, any measure that falls outside a block-exemption regulation has to be notified individually to the Commission. The preparation for notification and the notification process itself are difficult and time-consuming. If a Member State wants to deviate from existing guidelines the difficulty is compounded, as it enters a grey area where the reaction of the Commission becomes less predictable. Hence the fact that Member States have the theoretical possibility to design unusual measures to address unusual market failures and problems, does not necessarily mean that they actually choose to do so. Policy innovation in the field of state aid is incremental. It would be good if future editions of the Scoreboard also indicate how many measures are implemented and how much state aid is authorised by the Commission outside block-exemption regulations and guidelines.

[1] The 2025 edition of the State Aid Scoreboard can be accessed at:

https://competition-policy.ec.europa.eu/document/download/cc9cdf4e-97e9-4f8e-ac7d-5f094a9fd12d_en?filename=state_aid_scoreboard_note_2025.pdf

[2] Regulation 651/2014.

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About

Phedon Nicolaides

Dr. Nicolaides was educated in the United States, the Netherlands and the United Kingdom. He has a PhD in Economics and a PhD in Law. He is professor at the University of Maastricht and the University of Nicosia. He has published extensively on European integration, competition policy and State aid. He is also on the editorial boards of several journals. Dr. Nicolaides has organised seminars and workshops in many different Member States, and has acted as consultant to several public authorities.

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