State of play, main conclusions, outlook

The guidelines create a flexible, fit-for-purpose enabling framework to help Member States provide the necessary support to reach the Green Deal objectives in a targeted and cost-effective manner. The rules involve an alignment with the important EU’s objectives and targets set out in the European Green Deal and with other recent regulatory changes in the energy and environmental areas and will cater for the increased importance of climate protection. They include sections on decarbonisation, energy efficiency measures in buildings, aid for clean mobility energy infrastructure, circular economy, pollution reduction, protection and restoration of biodiversity, as well as measures to ensure security of energy supply, subject to certain conditions.

In particular, the guidelines broaden the categories of investments and technologies that Member States can support to cover new areas (e.g. clean mobility infrastructure, resource efficiency, biodiversity) and all technologies that can deliver the Green Deal (e.g. renewable hydrogen, electricity storage and demand response, carbon capture and usage).

Estimated savings and benefits

The guidelines streamline and increase the flexibility compared to the previous rules by introducing a simplified and more uniform assessment of cross-cutting measures under a single section of the guidelines (i.e., the section on aid for the reduction and removal of greenhouse gas emissions, including through support for renewable energy and energy efficiency) and eliminating the requirement for individual notifications of large green projects within aid schemes previously approved by the Commission.

The inclusion in the guidelines of categories of measures that were so far not covered by Commission guidelines also contribute to improved legal certainty for Member States and other stakeholders, thereby increasing the predictability of the Commission’s assessment and simplifying the design of State aid measures by Member States. This is the case, for instance, of aid for recharging and refuelling infrastructure, which was so far assessed directly under the Treaty.

Finally, the guidelines significantly simplify the assessment of State aid measures aiming to increase the energy performance of buildings (section 4.2), among others by (i) removing the requirement to calculate the eligible costs by deducting the costs that the beneficiary would have incurred in the counterfactual scenario; and (ii) by allowing the joint assessment under the same provisions of aid for the improvement of energy efficiency in buildings, and for other investments that increase the level of energy and environmental performance of buildings (e.g., on-site renewable electricity generation and storage facilities, recharging infrastructure for use by the building users, installation of equipment for the digitalisation of the building’s environmental and energy management and control, equipment for the recovery of rain water). This will also reduce red tape and simplify the implementation of such composite measures by Member States, avoiding the need to assess different components under different provisions.

The streamlined guidelines reduce the duplication of rules to be used for the assessment of projects aiming to contribute to the reduction of greenhouse gas emissions.

As mentioned above, the guidelines also simplify the assessment of aid for projects encompassing different categories of investments. This is the case, for instance, of aid for energy performance of buildings, where energy efficiency measures can be combined with other investments increasing the environmental performance of buildings, and for aid for recharging and refuelling infrastructure, where investments in the deployment of recharging and refuelling infrastructure can be combined with investments in the installation of renewable electricity or renewable or low carbon hydrogen generation and storage facilities.

By making it easier to accommodate the use of financial and technology innovation, they simplify the granting of aid for the deployment of innovative technologies.

They will also provide more legal certainty, leading to a lower risk of Commission decisions being challenged.