Middle East crisis Temporary State aid Framework (METSAF)

The Middle East crisis Temporary State aid Framework (“METSAF”) was adopted by the European Commission on 29 April 2026 to address the economic impact of the Middle East crisis on the sectors most affected and, more broadly, to support the EU economy in this context. These sectors notably include agriculture, fisheries, transport and energy-intensive industries. 

The METSAF enables Member States to act swiftly to ensure that the growth and viability of the most exposed companies are not irreparably undermined by the current crisis. To that end, it sets the compatibility conditions under which the European Commission may approve, in accordance with Article 107(3)(c) TFEU, various forms of support, including aid based on actual consumption to offset part of the increases in input costs, such as fuel or fertilisers, as well as simplified schemes for limited amounts of aid. 

The METSAF will remain in force until 31 December 2026. Throughout its application, the Commission will continuously review its content, scope and duration in light of developments in the Middle East and the broader economic situation. 

The Middle East situation has triggered volatility in global energy prices since February 2026, with significant spillover effects on electricity costs, supply chains and economic stability across the EU. These developments have heightened inflation risks, strained growth prospects and disproportionately impacted vulnerable households, raising concerns about the functioning of the internal market and energy security.

In response, the European Council, in its conclusions of 19 March 2026, called for targeted and temporary measures to address rising energy prices and short-term electricity market volatility, echoing the Commission President’s letter of 16 March 2026. Within this context, the Commission developed the METSAF, in consultation with Member States, as a targeted response aimed at mitigating the impact of ongoing energy market volatility on the most exposed sectors, including agriculture, fisheries, road transport, intra‑EU short‑sea shipping and energy‑intensive industries.

The METSAF complements the wide range of measures already available to Member States under existing EU State aid rules to address the consequences of the crisis. Based on Article 107(3)(c) TFEU, it sets out the compatibility conditions under which the Commission will authorise aid notified by Member States, while providing for accelerated approval procedures compared to standard State aid processes. In parallel, Member States may continue to rely on sector-specific frameworks, including the Agricultural Block Exemption Regulation and relevant guidelines for agriculture and forestry, as well as the Fishery Block Exemption Regulation and applicable guidelines for fisheries and aquaculture. Additional support may be granted under the General Block Exemption Regulation, rules on public passenger transport and guidelines on State aid for maritime transport. Moreover, EU State aid rules enable Member States to provide liquidity support, including urgent rescue aid, and, pursuant to Article 107(2)(b) TFEU, to compensate companies for damage directly caused by exceptional occurrences.

The METSAF focuses on the agriculture, fisheries, transport and energy-intensive industries. 

Beneficiaries must satisfy the scheme‑specific criteria (including, where required, documenting exposure to the crisis) and comply with applicable transparency, monitoring and cumulation rules.

The METSAF applies until 31 December 2026, subject to review by the Commission in light of market developments. The Commission may extend or adapt the framework in response to developments in the Middle East and the functioning of the internal market.

The METSAF provides for several categories of aid that can be implemented by Member States:

• Temporary, targeted support for the most exposed sectors (agriculture, fisheries, road transport and intra‑EU short‑sea shipping):
  • Compensation of up to 70% of the additional costs incurred as a result of increases in fuel or fertiliser prices since 28 February 2026, calculated on the basis of beneficiaries’ consumption.
  • A simplified aid option, capped at EUR 50,000 per company (excluding intra‑EU short‑sea shipping). Member States may rely on relevant statistical data and other criteria, such as the size and nature of the beneficiary’s activity, to streamline administrative procedures and avoid individual monitoring of actual consumption.
• Support for energy‑intensive industries: An increased maximum aid intensity of up to 70% (instead of 50%) for electricity costs incurred by energy‑intensive industries under temporary electricity price relief schemes pursuant to Section 4.5 of the Clean Industrial Deal State Aid Framework (CISAF).

Each national scheme must include appropriate safeguards to avoid overcompensation and to preserve incentives for energy efficiency where relevant.

In addition, the METSAF allows adjustments to electricity price relief schemes approved under Section 4.5 of the CISAF, by increasing the aid intensity for eligible electricity costs while keeping decarbonisation requirements unchanged. Cumulation with aid under the ETS State aid Guidelines is possible up to a defined share of the CISAF amount.

Finally, the Commission has indicated that it is prepared to assess, on a case‑by‑case basis and subject to specific conditions, temporary measures that may include subsidising fuel costs for electricity generation from gas, with a view to reducing overall electricity prices.

Member States must formally notify their aid schemes to the European Commission prior to their implementation and aid may not be granted before the schemes’ formal authorisation by the Commission. The METSAF nevertheless provides for an accelerated approval process.

Subject to the METSAF conditions, Member States may design schemes for sectors evidently affected by the Middle East crisis, as well as liquidity measures for affected companies. As mentioned above, the precise scope and ceilings are set out in the notified schemes.

Member States granting aid under the METSAF must publish detailed information on individual aid awards exceeding EUR 100,000 (above EUR 10,000 for the primary agriculture and fisheries sectors), within specified deadlines, and submit annual reports to the Commission. In addition, Member States are required to maintain comprehensive records of all aid measures for a period of 10 years and make them available to the Commission upon request.

To ensure compliance and effective oversight, the Commission may request further information on individual aid measures and their implementation, including verification that the conditions of approval decisions are respected. It may also require aggregated data from Member States to monitor the application of the framework.

CMS lawyers represent both public authorities and private companies on all aspects of State aid rules, notably State aid granted on the basis of the METSAF. This includes: 

• Legal assessment of the application of the METSAF and its compatibility. 
• Setting up aid schemes.
• Assisting public authorities in notifying State aid according to the METSAF to the European Commission.
• Assisting public authorities or beneficiaries in State aid granted on the basis of the METSAF in investigations by the European Commission. 
• Drafting and lodging complaints with the European Commission. 
• Litigation before national and EU courts.

The CMS State Aid Practice Area Group comprises 40 State aid law specialists practising State aid law in 17 jurisdictions located in 20 cities in Europe and beyond – all committed to assist you. 

Find your local contact person in our brochure CMS State Aid Group .