State aid Scoreboard, 2022

State aid Scoreboard, 2022 - Untitled design 14


On 24 April 2023, the Commission released the 2022 version of the State aid Scoreboard which this year runs to a record 226 pages.[1] It covers the State aid that was granted in 2021 and contains information on both covid-19 measures and non-pandemic aid. Covid-19 related aid reached EUR 191 billion, or 57% of total aid expenditure. Non-crisis aid accounted for EUR 144 billion, or 43% of the total. The total amount of aid reached EUR 335 billion and corresponded to 2.3% of the EU27’s GDP.

These are large amounts by any count and both policy makers and the academic literature have warned about their impact on the integrity of the internal market, especially given that the ability of Member States to grant aid varies significantly. The Scoreboard, however, argues that “the picture that emerges shows that, despite a significant spending dispersion across Member States, the temporary State aid measures adopted in the COVID-19 crisis were proportionate and necessary, matching the economic damage suffered during the crisis. Moreover, there is no evidence of Member States that would have granted an excessively larger amount compared to the others.”

State aid objectives

Most of non-covid-19 aid supported three policy objectives which together absorbed more than 70% of all aid. Subsidies for environmental protection and energy savings reached EUR 69 billion in 2021 and accounted for 48% of all non-crisis aid. The second most important policy objective in terms of public funding was research, development and innovation at EUR 19 billion, and overtook regional development at EUR 14 billion. In 2020, regional aid ranked second.

Sectoral aid

Railways also received a large amount of aid, reaching just below EUR 47 billion, which, however, was significantly less than the amount of EUR 58 billion that was recorded in 2020. State aid to agriculture was EUR 8 billion in 2021. But, it must be noted that agriculture is generously supported with large amounts of funding both from the EU budget and co-funding from Member States, which do not qualify as State aid.

State aid instruments

In terms of instruments used by Member States, the grant again was the most preferred. About 58% of total expenditure was delivered through grants. If also aid provided through tax incentives is included [14%], then the share of non-repayable aid reached 72%. Aid in guarantees and soft loans accounted for only 13% of the total.

However, the practices or preferences of Member States are not uniform. For example, Spain and Romania granted 37% and 43% of their total aid, respectively, in the form of guarantees. In Sweden, Italy and Finland measures involving tax advantages represented 38%, 32%, and 25%, respectively, of their total aid. Greece and Lithuania granted 45% and 23%, respectively, of their aid in the form of soft loans.

Block-exempted aid

Block exemption regulations were the primary means by which to implement State aid measures. In 2021, the GBER was the basis for 2365 new aid measures. The agricultural and fishery block exemption regulations were the bases for another 325 measures. In total, the three block exemption regulations were used for the implementation of 83% of the new State aid measures. The Scoreboard states that “excluding the COVID measures, the new GBER measures account for 93% of total new non-crisis measures.” This implies that the total non-crisis measures in 2021 were 2543. But, if we add 2365 and 325 we get 2690. So, it is unclear how the Commission arrived at the conclusion that the GBER was used for 93% of the non-crisis measures. However, the number of “93%” must be a typing error because later on the Scoreboard refers to “83%”.

The Scoreboard reports the amounts of State aid granted through the GBER and notified measures in terms of constant amounts in 2021 prices. The reported GBER-based amount in constant prices was EUR 61 billion while the notified aid amount was almost 4.5 times higher at EUR 270 billion. This implies that the arithmetic average amount of GBER-based measures was much smaller than the corresponding average of notified measures. So, indeed, the Commission gets to assess the measures with bigger budgets which are more likely to harm competition in the internal market.

What is a bit surprising is that in terms of policy objectives, the top ranking objective of GBER-based measures is RDI at about EUR 17.5 billion in constant 2021 prices. Environmental protection and energy savings come second at about EUR 16 billion, while regional development comes third at EUR 12.5 billion, also in constant 2021 prices.

Active v new aid measures

In 2021, Member States reported 7566 active aid measures of which 77% were schemes. A total of 3239 aid measures were newly implemented, of which 371 or 11% were related to covid-19. This implies that in 2021 the new, non-crisis measures were 2858. The Scoreboard states that “the new GBER measures are 2365, which represents 73% of the total new measures and 83% of the new non-crisis measures.” In other words, the three block exemption regulations, with a total of 2690 measures, accounted for 94% of non-crisis measures. It follows that in 2021, State aid was granted on the basis of 168 new aid measures that had been notified to the Commission.

Aid granted per Member State

The diagrams below show the absolute and relative amounts in relation to the national GDP of each Member State of both pandemic and non-pandemic aid.

Source: DG Competition

The diagrams reveal at least three important aspects of national State aid policies. First, both the absolute and relative amounts of State aid varied significantly across Member States. Second, this variation held true for both covid-19 aid and non-crisis aid. Third, the share of crisis and non-crisis aid also differed significantly across Member States. While the majority of Member States granted more crisis aid, 10 of them granted more non-crisis aid. Belgium and Sweden stand out for the very small share of covid-19 aid. At the other end of the spectrum, Greece, Austria, Slovakia and Cyprus targeted most of their State aid to combating the impact of covid-19.

Naturally, the impact of covid-19 has varied across countries and, therefore, national responses have differed too. However, it remains to be seen whether in the longer term addressing shortfalls of income was more effective or not than supporting actions that improve the economy’s growth prospects such as research or the green transition.

Special sections

The latest version of the Scoreboard also contains special sections on aid granted by the UK in Northern Ireland, the various instruments to deliver covid-19 related aid, and aid to support the green and digital transitions. The section on the green transition is especially interesting given the significance of State aid for environmental protection and energy savings.

[1] The Scoreboard can be accessed at:



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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