On 5 October 2023, the provisions of the Regulation of the Minister of Development and Technology of 29 September 2023 on the granting of state aid for the implementation of investment projects of strategic importance for the transition to an economy with net zero emissions came into force.
According to the regulation, depending on the area of investment implementation, entrepreneurs can obtain even EUR 350 million in grants for investment projects mainly related to the production of: specific low-carbon solutions, their components or the production/recovery of critical raw materials that are necessary for the mentioned production.
What is the scope of projects?
Support is provided for projects consisting in:
1) Production of:
(i) devices such as:
- batteries,
- solar panels,
- wind turbines,
- heat pumps,
- electrolyzers,
- carbon dioxide capture and storage equipment.
(ii) key components for direct use as the material to produce the above-mentioned devices and used for this purpose.
2) Production or recovery of related critical raw materials necessary for the production of devices and key components referred to in point 1.
What is the amount of the targeted grant?
The amount of support depends on: the type of investment, its location and the size of the applicant (SME preference) and ranges from 7.5% to 55% of eligible costs.
The table below presents each option regarding the limits of the aid intensity level for a low-carbon project and the total amount of state aid available to one entrepreneur.
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Option 1 |
Option 2 |
Option 3 |
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Territorial scope |
The voivodeships: a) Kuyavian-Pomeranian Voivodeship, b) Lublin Voivodeship, c) Lubusz Voivodeship, d) Łódź Voivodeship, e) Lesser Poland Voivodeship, f) Opole Voivodeship, g) Podkarpackie Voivodeship, h) Podlaskie Voivodeship, i) Pomeranian Voivodeship, j) Silesian Voivodeship, k) Świętokrzyskie Voivodeship, l) Warmian-Masurian Voivodeship, m) West Pomeranian Voivodeship n) municipalities belonging to the Masovian Voivodeship region, which were not mentioned in option 2. |
The voivodeships: a) Lower Silesian, b) Greater Poland, c) the following municipalities belonging to the Masovian Voivodeship region: - Błonie, - Dąbrówka, - Dobre, - Góra Kalwaria, - Grodzisk Mazowiecki, - Jaktorów, - Kałuszyn, - Kampinos, - Kołbiel, - Latowicz, - Leoncin, - Leszno, - Mrozy, - Nasielsk, - Osieck, - Prażmów, - Serock, - Siennica, - Sobienie-Jeziory, - Tarczyn, - Tłuszcz, - Zakroczym, - Żabia Wola. |
The area of the whole of Poland, excluding the regions shown in the options 1 and 2. |
|
Basic level of state aid intensity* |
Up to 35% of eligible costs |
Up to 20% of eligible costs |
Up to 15% of eligible costs |
|
Increased level of state aid intensity |
20 percentage points - concerning micro and small entrepreneurs |
||
|
10 percentage points - concerning medium-sized entrepreneurs |
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|
Maximum co-financing (equivalent in EUR) |
EUR 350 million |
EUR 200 million |
EUR 150 million |
* In the case of investments in the production of heat pumps and the production of key components for direct use as material for the production of heat pumps, the maximum intensity is reduced by 50% compared to the values indicated in the table.
Who is entitled to apply for the grant?
The application is available for entrepreneurs (not only large companies, but also SMEs) who fulfill the following conditions:
1) Submitting a complete and correct application for a low-carbon project to the relevant institution (during the support granting period).
2) Committing to implement a low carbon project.
3) Committing to incur the minimum eligible project’s costs of at least the equivalent of EUR 110 million.
4) Committing to create at least 50 new job places as a result of implementing a low carbon project.
5) Not being in a difficult situation.
6) Not being obliged to repay the aid on the basis of any previous decision of the European Commission indicating the aid illegal and incompatible with the common market.
7) In the last two years prior to submitting an application for aid for the low-carbon project in question, not relocating activities or any part of them from a plant in a Member State of the European Free Trade Association to a plant in Poland where the project in question is being carried out.
8) Committing not to perform a relocation, as described in the above point, during the realization of the low-carbon project and for two years after its completion.
9) Meeting at least 5 of the 14 supplementary criteria, i.e.:
- creating the specialized job places,
- a net increase of the employees’ number above the minimum threshold,
- incurring the eligible costs above the minimum threshold,
- cooperating with the secondary schools or the entities of high school and education system,
- SME status,
- the investment’s location on the area with the risk of exclusion,
- robotization and automatization of the processes,
- investment in RES,
- utilizing the potential of human resources,
- supporting of acquiring education and professional qualifications as well as co-operation with the vocational education,
- creating of the regional connections,
- taking actions in terms of employees’ care,
- leading a business activity of negative impact on the environment,
- conducting the R&D activity.
10) Commiting to completing the low carbon project no later than 7 years from the start of work.
11) Not commencing the project’s works before submitting the application (land purchase and preparatory work are not considered as a ‘commencement of work’).
When?
- Granting the aid is performed by the Ministry of Development and Technology (MDT) on the basis of the submitted grant’s application.
- Investments (meeting the criteria) covered by applications from before the entry into force of the regulation governing the preference in question, i.e. submitted before 5 October this year, may also be covered by the grant.
- State aid may be granted until 31 December 2025, while it is granted during the validity period of the European Commission's decision on the compatibility of the state aid in question with the internal market.
PwC comment
From our perspective, the grant presented can importantly contribute to the ESG strategies and the creation of climate-enhancing solutions. Undoubtedly, financial support for the presented investments should be of interest to manufacturers of, inter alia, heat pumps, solar panels, wind turbines or carbon storage devices.
In our view, the mentioned grant, due to the indicated criteria, especially the minimum amount of eligible costs of the project at a level of at least the equivalent of EUR 110 million, may be popular mainly among large and medium-sized enterprises. As a rule, micro and small companies, in our view, might find it unattainable to fit into the relatively high entry thresholds.
We would like to point out that investments commenced prior to the submission of the application to the MDT will not be eligible for support. According to the cited regulation, commencement of works means:
"the commencement of construction work relating to the investment or the first legally binding commitment to order equipment or any other commitment which renders the investment irreversible, whichever comes first. The purchase of land and preparatory work, such as obtaining permits and carrying out pre-feasibility studies, shall not be considered as the commencement of work."
If there is an urgent need to start an investment project, we recommend submitting an application as soon as possible.
We encourage you to contact us - we have many years of experience in investigating the potential to benefit from a given source of support, preparing application documentation, or settlementing the state aid projects.
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