The Clean Industrial Deal State Aid Framework (CISAF): an efficient tool to support the Clean Industrial Deal?
On 25 June 2025, the European Commission adopted the State aid framework supporting the Clean Industrial Deal (CISAF). The CISAF, which replaces the Temporary Crisis and Transition Framework (TCTF), provides for several categories of aid that can be granted by Member States to improve access to affordable energy, to boost demand and supply of tech products, to unlock public and private investments, to power the circular economy, to develop international partnerships and to secure skills and quality jobs for social fairness. It was drafted following a survey on the impact of the TCTF, a public consultation and multilateral meetings with Member State experts on the contemplated measures to be adopted.
The CISAF, which will be in force until 31 December 2030, aims at supporting the Clean Industrial Deal (CID), a major initiative to enhance industrial competitiveness and decarbonisation across the EU.
The CISAF provides the following key provisions designed to streamline and facilitate State aid measures for Member States:
- Measures accelerating the rollout of renewable energy and low carbon fuels through aid schemes: firstly, the CISAF aims at simplifying the procedures for approval and accelerating implementation of investments in renewable energy, investments in storage of RFNBOs, biofuels, bioliquids, biogas and biomass fuels (where the storage is exclusively for renewable energy), and investments in electricity, as well as thermal storage.
The category of measure also provides aid schemes to ‘fast-track’ the rollout of low-carbon fuels, such as blue and green hydrogen, provided certain conditions are met. These measures empower Member States to invest more efficiently and swiftly in clean energy projects, a key step in meeting the decarbonisation objectives of the CID and accelerating the transition to renewable energy.
Finally, the CISAF also provides new rules on flexibility measures and capacity mechanisms; they give Member States tools to integrate variable renewables such as wind and solar power while ensuring reliable electricity supply. The CISAF’s 'target model' capacity mechanisms may qualify for fast-track approval, while other designs are assessed under the Climate, Energy and Environmental Aid Guidelines (CEEAG).
- Temporary measures supporting electricity cost relief for energy-intensive users: these aim at ensuring the transition to low-cost clean electricity by enabling Member States to support electricity prices for companies in sectors that are energy-intensive, highly exposed to international competition and face higher energy costs than other competitors in regions with less ambitious climate policies. In return, the companies are required to invest in decarbonisation.
- Measures facilitating industrial decarbonisation of existing production facilities: these focus on supporting investments in a broad range of decarbonisation technologies, such as electrification, hydrogen, biofuels, biomass, hydrogen derived fuels, carbon capture utilisation and storage of natural gas. Member States may also design tender-based and direct aid schemes to support these projects based on predefined aid amounts. For larger projects (more than EUR 200 million), the aid will be capped according to the project’s funding cap. As an alternative, Member States can also choose to determine the maximum aid amount under an aid scheme by a competitive bidding process that complies with certain conditions.
- Measures ensuring sufficient manufacturing capacity in clean technologies in the EU: under the CISAF, Member States can support investments in new manufacturing capacity. This includes support through schemes for all technologies covered by the Net-Zero Industry Act, as well as individual aids for net-zero manufacturing projects when necessary to prevent their relocation outside Europe. This aid is extended to provide support for the production and processing of critical raw materials necessary for manufacturing such technologies. Also, the CISAF authorises Member States to offer higher levels of aid to match support provided in third countries, preventing investments from being diverted from the EU. Finally, the CISAF allows Member States to offer tax incentives, such as allowing companies to deduct the cost of clean technology investments from their taxable income more rapidly.
- Measures to de-risk private investments: Member States can adopt measures to reduce the risks associated with private investment in projects covered by the CISAF, including industrial decarbonisation, clean technologies, clean energy, energy infrastructure projects and projects supporting the circular economy. Support may consist of equity, loans or guarantees given to a fund or a special purpose vehicle managing eligible projects.
The CISAF therefore sets up various new categories of aid to encourage Member States to finance the implementation of the CID. However, national budgets have been under strain and priorities are switching in the current international context.
Moreover, the conditions are restrictive as most of the aid may only be granted under an aid scheme and after prior notification to the European Commission. This is therefore a missed opportunity for a fast, streamlined process and simplified compatibility conditions.
In parallel with the CISAF, the CEEAG remains in force and may be used by Member States to grant different or individual aid. The coexistence of both aid frameworks with similar objectives does not facilitate the application of State aid rules.
In addition, Member States may continue to implement State aid in this area under the General Block Exemption Regulation (GBER), without prior notification to the Commission. The GBER, which expires on 31 December 2026, is currently under revision and should in future include additional categories of aid under simplified compatibility conditions.
So far, the European Commission has only adopted a French aid scheme relating to offshore wind farms. It is therefore too early to evaluate the real impact of the CISAF on Member State policy.
CMS has the widest coverage and largest team of State aid specialists in Europe. In addition, we have extensive experience in setting up aid schemes and support measures for individual projects.
Please feel free to consult our brochure to find the CMS contact in your jurisdiction.
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