On 25 June the European Commission launched the Clean Industry State Aid Framework (CISAF), which will operate alongside the CEEAG and other EU frameworks, valid until 31 December 2030. It sets the rules for subsidising renewables, hydrogen, storage, industrial decarbonisation and clean tech manufacturing.

CISAF is Europe’s response to Washington’s Inflation Reduction Act and China’s dominance in supply chains. It introduces structural changes: Contracts for Difference can last up to 25 years, storage and demand-response are explicitly eligible, aid intensity for clean tech factories can reach 35% in assisted regions, and electricity relief for heavy industry is tied to strict reinvestment in decarbonisation.

1) Will CISAF make state aid faster?

Partly. Romania has chosen to migrate all existing schemes under development to CISAF rules, which will delay CfD round 3 and stand-alone battery support. Once this transition is done, future schemes should move faster under the new approval track. For renewable auctions, if a scheme meets CISAF criteria, it can be approved through a fast-track procedure, cutting approval times to about 3–4 months as seen under the TCTF. Schemes that do not qualify must still be notified under the CEEAG, where DG COMP carries out deeper reviews.

2) How does CISAF change the economics of renewables?

CfDs are extended from 20 to 25 years, which makes debt structuring easier and reduces regulatory risk. Repowering projects are now eligible, including dismantling costs, which gives investors more certainty when upgrading assets. The strict 36-month completion deadline has been dropped, a relief for developers facing grid delays. Auctions remain compulsory for projects larger than 1 MW, except for SME or community-owned projects up to 18 MW.

3) Is non-fossil flexibility finally supported and under what rules?

Yes. Storage and demand-response are explicitly included. Projects must be at least 1 MW or 1 hour in duration. Support is allocated through competitive bidding, with bids ranked only by €/MW of flexible capacity. Contracts require at least one activation per year and impose penalties if availability drops below 50%. If market participation rules are not fully in place, schemes can only be approved for a maximum of two years.

4) How is industry supported on electricity costs?

Energy-intensive users can obtain a 50% discount on the wholesale electricity price, applied to up to 50% of their annual consumption. Prices cannot fall below €50/MWh. At least 50% of the aid must be reinvested in projects such as storage, energy efficiency, renewables or hydrogen. Member States can grant an additional 10% of support if beneficiaries reinvest 75% of it, with 80% directed specifically to demand-side flexibility. This relief can last for three years, with no payments allowed after 31 December 2030.

5) What counts as industrial decarbonisation?

Eligible projects must deliver substantial impact:

• Existing installations must cut at least 40% of GHG emissions, or 90% when avoiding fossil fuel lock-in.
• Electrification projects must reduce energy consumption by 20% or more.
• New plants replacing old ones must achieve 10% lower emissions than the best available alternative.

Projects must be operational within 60 months, and must demonstrate a payback of at least five years. Production increases are allowed only up to 15% of capacity, unless technically unavoidable.

6) How much aid can industrial projects receive?

The ceiling is €200M per project. Aid intensities are differentiated:

• 60% for hydrogen use or production (where at least 40% is RFNBO).
• 45% for renewables, CCUS or flexible electrification.
• 20–35% for low-carbon fuels.
• 30% for other eligible technologies.

SMEs benefit from an additional 5–10% uplift. For projects above €30M, Member States may apply claw-back provisions to recover excess returns.

7) How will Europe subsidise clean tech manufacturing?

Aid covers investment in NZIA technologies and critical raw materials. Intensity depends on location:

• 15% of eligible costs in developed regions, capped at €150M.
• 20% in “c” assisted regions, capped at €200M.
• 35% in “a” assisted regions, capped at €350M.

SMEs gain a further 10–20% uplift. Beneficiaries must contribute at least 25% own financing, and keep production in place for five years (three for SMEs). Accelerated depreciation is available for clean tech equipment.

8) What restrictions apply to manufacturing aid?

Companies that receive aid cannot relocate production within or outside the EEA for two years before and after the investment. This rule is designed to prevent subsidy-driven relocations and ensures that CISAF creates genuinely additional capacity rather than shifting existing factories around Europe.

9) What risk-sharing tools are available for investors?

CISAF allows Member States to de-risk private capital with equity, loans and guarantees.

• Up to €250M per project.
• Duration up to 20 years.
• States must define diversification and exit strategies.

If a project receives aid above 10% of a scheme’s budget, the Commission will review it. For large projects, claw-back mechanisms may also be introduced.

10) Can CISAF support Innovation Fund projects?

Yes. Projects that have already secured Innovation Fund support, or those that passed the selection process but were awarded only a sovereignty seal, can receive co-funding through CISAF. This opens the door for additional capital to projects already vetted by EU due diligence.

Bottom line

CISAF does not solve permitting or supply chain bottlenecks, but it does reset the financial framework of the European energy transition until 2030. The winners will be developers who design projects around flexibility and measurable decarbonisation, investors who arbitrage regional aid differentials, and industrials ready to trade short-term subsidies for long-term transformation.