Suur-Ameerika 1 / 10122 Tallinn / 611 3558 / [email protected] / www.fin.ee registrikood 70000272

Ettevõtluse ja Innovatsiooni Sihtasutus

[email protected]

Meie 10.07.2026nr 12.1-1/2950-1

Abikava SA.107952 järelevalve

Lugupeetud kolleegid

Alates 2006. aastast on Euroopa Komisjoni Konkurentsi Peadirektoraat (edaspidi komisjon)

teostanud järelevalvet liikmesriikide rakendatud riigiabi meetmete üle. 2026. aasta valimisse

kuulub ettevõtlus- ja infotehnoloogiaministri 21. märtsi 2022. a määruse nr 23 "Ettevõtja

rakendusuuringute määrus" alusel antav toetus ehk abikava SA.107952 „Ettevõtja

rakendusuuringute toetus (alates 02.06.2023)“, mida rakendab Ettevõtluse ja Innovatsiooni

Sihtasutus. Järelevalve raames kontrollib komisjon abikava vastavust komisjoni määrusele

(EL) nr 651/2014 ELi aluslepingu artiklite 107 ja 108 kohaldamise kohta, millega teatavat liiki

abi tunnistatakse siseturuga kokkusobivaks ((ELT L 187, 26.06.2014, lk 1). Edastame Teile

komisjoni kirja, palume vastata komisjoni küsimustele ning täita lisatud tabel ja saata vastused

Rahandusministeeriumile hiljemalt 27. augustiks.

Lugupidamisega

(allkirjastatud digitaalselt)

Kaur Kajak

halduspoliitika asekantsler

Lisa: 1. SA.107952(2026.MX

2. SA.107952 (2026.MX): Annex to the letter

Ljudmilla Sokolnikova 611 3360

[email protected]

Lisaadressaadid: Majandus- ja Kommunikatsiooniministeerium

2

SA. 107952.MX - Annex to the information request

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In the table below, you will find a list of compatibility conditions and provisions that may be relevant for the assessment of the legal basis concerning the

block-exempted aid measure under monitoring (Commission Regulation (EU) No 651/2014, OJ L 187, 26.6.2014, p. 1, as amended).

Please provide information, in short form, in the column "Where to find them in legal basis or secondary law?" by a reference to the relevant paragraph and

page number of the legal document, e.g. Art. 1, p. 3, Legal text; Paragraph 3, p. 5, Secondary law).

If a condition or provision is implicitly fulfilled i.e. it is not especially contained in the legal text of the aid measure, please give a short explanation where

it is established.

Where a condition is not applicable, please put "N/A" and give a short explanation.

Annex regarding the legal basis

A. Common provisions of application

GENERAL COMPATIBILITY CONDITIONS COMPLIANCE CHECK (OK?)

Article 1

Article 1 – Exclusion of certain activities and aids above a certain amount (§2)

The GBER shall not apply to:

 R&D&I aid schemes with average annual State aid budget exceeding EUR 150 million from

six months after their entry into force this Regulation may continue to apply for a longer period

to any of these aid schemes after having assessed the relevant evaluation plan notified by the

Member State to the Commission, within 20 working days from the scheme's entry into force.

Where the Commission has already extended the application of this Regulation beyond the initial

six months as regards such schemes, Member States may decide to extend those schemes until

the end of the period of application of GBER, provided that the Member State concerned has

submitted an evaluation report in line with the evaluation plan approved by the Commission.

 any alterations of schemes referred above other than modifications which cannot affect the

compatibility of the aid scheme under GBER or cannot significantly affect the content of the

approved evaluation plan

 aid to export related activities

 aid contingent upon use of domestic over imported goods

Article 1 – Exclusion of certain sectors (§3)

The GBER shall not apply to:

SA. 107952.MX - Annex to the information request

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 The processing and marketing of agricultural products* where the amount of aid is fixed on

the basis of the price or quantity of such products purchased from primary producers or put on

the market by the undertakings concerned; or where the aid is conditional on being partly or

entirely passed on to primary producers;

 Aid to facilitate the closure of uncompetitive coal mines (Council decision 2010/787/EU);

* If an undertaking active also in sectors within the scope of GBER, the Regulation applies to

aid granted in respect of these sectors provided that Member State ensures that the activities in

the excluded sectors do not benefit from the aid.

Article 1 – Exclusion of companies concerned by the Deggendorf rule (§4)

The GBER shall not apply to:

(a) aid schemes which do not explicitly exclude the payment of individual aid;

(b) ad hoc aid granted by the Member State in favour of an undertaking which is subject to

outstanding recovery order following a previous Commission Decision declaring an aid illegal and

incompatible with the internal market.

Article 1 – Exclusion of companies in difficulty (§4)

The GBER shall not apply to undertakings in difficulty

 by derogation: this Regulation applies to undertakings which were not in difficulty on 31

December 2019 but became undertakings in difficulty during the period from 1 January

2020 to 31 December 2021.

Article 1 – Exclusion of aid measures violating Union Law (§5)

The GBER shall not apply to State aid measures, which entail, by themselves, by the conditions

attached to them, or by their financing method, a non-severable violation of Union law, in particular:

(a) aid measure where the grant of aid is subject to the obligation for the beneficiary to have its

headquarters or to be predominantly established in the relevant Member State. Requirement for an

establishment or branch in the aid granting Member State at the moment of payment of the aid is

allowed.

(b) aid measure where the grant of aid is subject to the obligation to use nationally produced goods

or national services;

(c) aid measures restricting the possibility for the beneficiaries to exploit the research, development

and innovation results in other Member States.

Article 4 – Individual notification thresholds

The GBER shall not apply to aid which exceeds:

 Research and development:

SA. 107952.MX - Annex to the information request

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i. if the project is predominantly fundamental research: EUR 40 million per undertaking,

per project; where more than half of the eligible costs of the project incurred through

activities within the category of fundamental research;

ii. If the project is predominantly industrial research: EUR 20 million per undertaking, per

project; where more than half of the eligible costs of the project incurred through activities

within the category of industrial research or industrial research and fundamental research

taken together;

iii. if the project is predominantly experimental development: EUR 15 million per

undertaking, per project; where more than half of the eligible costs of the project incurred

through activities within experimental development;

iv. if the Eureka project or project implemented by a Joint Undertaking (Article 185 or

Article 187 TFEU), the amounts referred to in points (i) to (iii) are doubled.

v. if the aid for research and development projects is granted in the form of repayable

advances which, in the absence of an accepted methodology to calculate their gross grant

equivalent, are expressed as a percentage of the eligible costs and the measure provides

that in case of a successful outcome of the project, as defined on the basis of a reasonable

and prudent hypothesis, the advances will be repaid with an interest rate at least equal to

the discount rate applicable at the time of grant, the amounts referred to in points (i) to (iv)

are increased by 50 %;

vi. aid for feasibility studies in preparation for research activities: EUR 7,5 million per

study;

vii. for aid for SMEs for research and development projects awarded a Seal of Excellence

quality label and implemented under Article 25a, the amount referred to in Article 25a

(2,5 million per SME per research and development project or feasibility study);

viii. for aid Marie Skłodowska-Curie actions and ERC Proof of Concept actions

implemented under Article 25b the amounts referred to in Horizon 2020 or Horizon

Europe programme rules);

ix. for aid involved in co-funded research and development projects implemented under

Article 25c, the amounts referred to in Horizon 2020 or Horizon Europe programme rules;

x. for aid for Teaming actions implemented under Article 25d, the amounts referred to in

Horizon 2020 or Horizon Europe programme rules;

 for investment aid for research infrastructures: EUR 20 million per infrastructure; for aid

for innovation clusters: EUR 7,5 million per cluster;

 innovation aid for SMEs: EUR 5 million per undertaking, per project;

 for aid for process and organisational innovation: EUR 7,5 million per undertaking, per

project.

SA. 107952.MX - Annex to the information request

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The thresholds shall not be circumvented by artificially splitting up the aid schemes or aid

projects.

Article 5 – Transparency of aid

Only transparent aid (aid in respect of which it is possible to calculate precisely the gross grant

equivalent of the aid ex ante without any need to undertake a risk assessment) shall be exempted.

The following are considered to be transparent:

 aid comprised in grants and interest rate subsidies

 aid comprised in loans (where gross grant equivalent has been calculated on the basis of the

reference rate prevailing at the time of the grant)

 aid comprised in guarantees:

where the gross grant equivalent has been calculated on the safe-harbour premiums laid down in a

Commission Notice

or

the methodology to calculate the gross grant equivalent has been accepted by the Commission

following a notification before the implementation on the basis of the Commission Notice on

Guarantees and the approved calculation methodology explicitly addresses the type of the guarantee

and the type of the underlying transaction at stake in the context of the application of the GBER

 aid for tax advantages (where measure provides for a cap to ensure that threshold is not

exceeded)

 aid in the form of repayable advances, if the total nominal amount of the repayable advance

does not exceed the thresholds applicable under GBER or if, before implementation of the

measure, the methodology to calculate the gross grant equivalent of the repayable advance

has been accepted following its notification to the Commission.

 aid in the form of the sale or lease of tangible assets below market rates where the value is

established by an independent expert evaluation prior to the transaction or by reference to a

publicly available, regularly updated and generally accepted benchmark

Article 6 – Incentive effect

Aid can only be exempted if it has an incentive effect:

 The beneficiary submitted written application for aid to Member State, before work

on the project or activity starts, with at least the following information:

- undertaking's name and size;

- description of the project, including its start and end dates;

- location of the project;

- list of project costs;

SA. 107952.MX - Annex to the information request

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- type of aid (grant, loan, guarantee, repayable advance, equity injection or other) and amount

of public funding needed for the project

 Ad hoc aid to large enterprises; in addition to the above, the Member State has verified

before granting the aid that the beneficiary provided documentation establishes one or more

of the following:

- a material increase in the scope of the project/activity due to the aid, or

- a material increase in the total amount spent by the beneficiary on the project/activity due

to the aid, or

- a material increase in the speed of completion of the project/activity concerned;

→ Exceptions:

 Tax advantages if:

- the measure establishes a right to aid in accordance with objective criteria and without

further exercise of discretion by the Member State; and

- the measure has been adopted and is in force before work on the aided project or activity

has started, except in the case of fiscal successor schemes, where the activity was already

covered by the previous schemes in the form of tax advantages.

 The following categories of aid are not required to have or shall be deemed to have an

incentive effect:

- aid for research and development projects awarded a Seal of Excellence quality label, Marie

Skłodowska-Curie actions and ERC Proof of Concept actions awarded a Seal of Excellence

quality label, aid involved in co-funded projects and in co-funded Teaming actions, if the

relevant conditions laid down in Article 25a, Article 25b, Article 25c or Article 25d are

fulfilled.

Article 7 – Eligible costs

For the purposes of calculating the aid intensity

 All figures shall be taken before any deduction of tax or other charge. The amounts of eligible

costs may be calculated in accordance with the simplified cost options (Reg 1303/2013, or Reg

2021/1060) whichever is applicable provided that the operation is at least partly financed

through a Union fund that allows the use of those simplified cost options and that the category

of costs is eligible according to the relevant exemption provision;

 Aid granted in a form other than a grant, the aid amount shall be the gross grant equivalent of

the aid.

 Aid payable in the future, including aid payable in several instalments shall be discounted to its

value when granting. Eligible costs shall also be discounted to their value at the time of

granting the aid. The discounting interest rate shall be the one which was applicable at the time

of granting the aid;

SA. 107952.MX - Annex to the information request

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 Where aid is granted in the form of repayable advances which, in the absence of an accepted

methodology calculating their gross grant equivalent, are expressed as a percentage of the

eligible costs and the measure provides that in case of successful outcome of the project, as

defined on the basis of a reasonable and prudent hypothesis, the advances will be repaid with

 an interest rate at least equal to the discount rate applicable at the moment the aid is granted, the

maximum aid intensities may be increased by 10 percentage point.

Eligible costs & documentation

 Eligible costs must be supported by clear, specific, and contemporary documentary evidence.

 The amounts of eligible costs may be calculated in accordance with the simplified cost options

set out in Reg 1303/2013, provided that the operation is at least partially financed through a

Union fund that allows the use of those simplified cost options and that the category of costs is

eligible according to the relevant exemption provision.

Article 8. Cumulation

 Total amount of aid (for the aided activity or project or undertaking) shall be taken into account

for thresholds and maximum aid intensities (§1);

 If Union funding (not under the control of the Member State) is combined with State aid, only

the latter shall be considered for determining whether notification thresholds and maximum aid

intensities or maximum aid amounts are respected, provided that the total amount of public

funding granted in relation to the same eligible costs does not exceed the most favourable

funding rate laid down in the applicable rules of Union law (§2);

 GBER exempted aid may be cumulated with any other State aid as long as the measures concern

different identifiable costs (§3a);

 No cumulation of exempted aid with any other aid on the same eligible costs, partly or fully

overlapping, if the result would exceed the highest aid intensity/amount applicable to this aid

 under GBER (§3b)1;

1 Financing provided to the final beneficiaries with support from the InvestEU Fund covered by Section 16 of Chapter III and the cost covered by this financing shall not

be considered for determining compliance with the cumulation provisions laid down in the first sentence of this point. Instead, the amount relevant for determining

compliance with the cumulation provisions of the first sentence of this point shall be calculated as follows. First, the nominal amount of the financing supported by the

InvestEU Fund shall be deducted from the total eligible project costs, obtaining the total remaining eligible costs; second, the maximum aid shall be calculated by

applying the relevant highest aid intensity or aid amount only to the total remaining eligible costs.

In cases of Articles for which the notification threshold is expressed as a maximum aid amount, the nominal amount of financing provided to the final beneficiaries with

the support from the InvestEU Fund shall also not be considered for determining whether the notification thresholds in Article 4 are respected.

Alternatively, for senior loans or guarantees on senior loans supported by the InvestEU Fund under Section 16 of Chapter III, the gross grant equivalent of the aid

entailed in such loans or guarantees provided to the final beneficiaries may be calculated in accordance with Article 5(2), point (b) or (c), as appropriate. This gross grant

SA. 107952.MX - Annex to the information request

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 State aid exempted under the GBER shall not be cumulated with any de minimis aid in respect

of the same eligible costs if such cumulation would result in an aid intensity exceeding those

laid down in Chapter III of the GBER (§5).

Articule 9 – Publication and information

 Publication on a comprehensive State aid website, at national or regional level of the following

(§1):

a. the summary information in the standardised format (see Article 11) or a link providing

access to it;

b. the full text of each aid measure (see Article 11) or a link providing access to the full text;

c. the information (see annex III) on each individual aid award exceeding EUR 500 000 (see

Annex III), for beneficiaries active in primary agricultural production (other than Section

2a) each individual aid award for such production exceeding EUR 60 000 and for

beneficiaries active in the fishery and aquaculture sector (other than 2a) each individual aid

award exceeding EUR 30 000.

 For schemes in the form of tax advantages, the conditions set out in paragraph 1(c) of this Article

shall be considered fulfilled if Member States publish the required information on individual aid

amounts in the following ranges (in EUR million (§2)):

- 0,03-0,5 (only for fishery and aquaculture);

- 0,06-0,5 (only for primary agricultural production);

- 0,5-1;

- 1-2;

- 2-5;

- 5-10;

- 10-30; and

- 30 and more.

 The information referred to in paragraph 1(c) shall be organised and accessible in a standardised

manner, (see Annex III), and shall allow for effective search and download functions. The

information referred to in paragraph 1 shall be published within 6 months from the date the aid

was granted, or for aid in the form of tax advantage, within 1 year from the date the tax

declaration is due, and shall be available for at least 10 years from the date on which the aid was

granted (§4).

 Member States shall comply with the provisions of this Article at the latest within two years

after the entry into force of GBER (§6).

equivalent of the aid can be used for ensuring, in line with the first sentence of this point, that cumulation with any other aid for the same identifiable eligible costs does

not result in exceeding the highest aid intensity or aid amount applicable to the aid under this Regulation or the relevant notification threshold under this Regulation.

SA. 107952.MX - Annex to the information request

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Article 11 – Reporting (info sheets)

 The following has to be sent by Member States to the Commission: (§1):

a. Summary information in the standardised formal laid down in Annex II, together with

a link providing access to the full text of the measure, including its amendments, within

20 working days following its entry into force, via the Commission’s electronic

notification system;

b. Annual report (Reg (EC) 794/2004) in electronic form, on the application of GBER,

containing the information indicated in that Regulation, in respect of each whole year

or each part of the year during which GBER applies.

For definitions on concepts: article 2 (pay attention to the new definition of undertaking in difficulty)

SA. 107952.MX - Annex to the information request

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B. Specific conditions for aid for research and development and innovation

ARTICLE 25

AID FOR RESEARCH AND DEVELOPMENT PROJECTS

COMPLIANCE CHECK (OK?)

Aid for research and development projects, including projects having received a Seal

of Excellence quality label under the Horizon 2020 or under the Horizon Europe

programme and co-funded research and development projects and, where applicable,

aid for co-funded Teaming actions, shall be compatible with the internal market within

the meaning of Article 107(3) of the Treaty and shall be exempted from the

notification requirement of Article 108(3) of the Treaty, provided that the conditions

laid down in this Article and in Chapter I are fulfilled. (§1)

Activities eligible to receive aid

 The aided part of the research and development project shall completely fall

within one or more of the following categories (§2):

a) fundamental research;

b) industrial research;

c) experimental development;

d) feasibility studies.

Eligible costs

 Eligible costs of R&D allocated to a specific category of R&D shall be

following(§3):

a) Personnel costs: researchers, technicians and other supporting staff to the

extent employed on the project;

b) Costs of instruments and equipment; to the extent and for period used for the

project. If not used for their full life for the project, only the depreciation costs

corresponding to the life of the project; based on generally accepted

accounting principles.

c) Costs for of buildings and land; to the extent and for the duration period used

for the project. Buildings: only depreciation costs corresponding to the life of

the project; based on generally accepted accounting principles. Land; costs of

commercial transfer or actually incurred capital costs.

d) Costs of contractual research, knowledge and patents bought or licensed from

outside sources at arm's length conditions, as well as costs of consultancy and

equivalent services used exclusively for the project;

SA. 107952.MX - Annex to the information request

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e) Additional overheads and other operating expenses, including costs of

materials, supplies and similar products, incurred directly as a result of the

project.

 The eligible costs for feasibility studies shall be the costs of the study (§4)

Aid intensity

 Aid intensity for each beneficiary no more than (§5):

a) 100 % of the eligible costs for fundamental research;

b) 50 % of the eligible costs for industrial research;

c) 25 % of the eligible costs for experimental development;

d) 50 % of the eligible costs for feasibility studies.

 Bonuses: Aid intensities for industrial research and experimental development

may be increased up to 80 % of the eligible costs as follows (§6):

a) by 10 percentage points for medium-sized enterprises and by 20 percentage

points for small enterprises;

b) by 15 percentage points if one of the following conditions is fulfilled:

i. the project involves effective collaboration:

- between undertakings of which at least one SME, or project carried

out in at least two Member States, or in a Member State and in a

Contracting Party of the EEA Agreement, and no single undertaking

bears more than 70 % of the eligible costs, or

- between an undertaking and one or more research and knowledge-

dissemination organisations, where the latter bear at least 10 % of the

eligible costs and have the right to publish their own research results;

ii. project results widely disseminated (through conferences, publication,

open access repositories, or free or open source software)

 Aid intensities for feasibility studies may be increased by 10 percentage points

for medium-sized enterprises and by 20 percentage points for small enterprises.

SA. 107952.MX - Annex to the information request

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ARTICLE 26

INVESTMENT AID FOR RESEARCH INFRASTRUCTURES

COMPLIANCE CHECK (OK?)

 Compatible and exempted from notification if general compatibility conditions

(Chapter I) and conditions of this Article apply (§1)

 If the infrastructure pursues both economic and non-economic activities;

financing, costs and revenues of each type of activity shall be accounted for

separately on the basis of consistently applied and objectively justifiable cost

accounting principles (§2)

 Market price is charged for the operation or use of the infrastructure (§3)

 Access is open to several users on a transparent and non-discriminatory basis.

Preferential access under more favourable conditions may be granted to

undertakings which have financed at least 10% of the investment costs in

proportion to their contribution to the investment costs; and the preferential access

conditions are made publicly available (§4)

 Eligible costs: investment costs in intangible and tangible assets (§5)

 Aid intensity not to exceed 50 % of the eligible costs (§6)

 If public funding for both economic and non-economic activities; Member States

must put in place monitoring and claw-back mechanism to ensure that applicable

aid intensity is not exceeded as a result of an increase in the share of economic

activities compared to the situation envisaged at the time of awarding the aid (§7)

ARTICLE 28

INNOVATION AID FOR SMES

COMPLIANCE CHECK (OK?)

 Compatible and exempted from notification if general compatibility conditions

(Chapter I) and conditions of this Article apply (§1)

 Eligible costs (§2):

a. costs for obtaining, validating and defending patents and other intangible

assets;

b. costs for secondment of highly qualified personnel from a research and

knowledge-dissemination organization or a large enterprise, working on

research, development and innovation activities in a newly created function

within the beneficiary and not replacing other personnel;

c. costs for innovation advisory and support services.

 Aid intensity must not exceed 50 % of the eligible costs (§3).

SA. 107952.MX - Annex to the information request

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 In the particular case of aid for innovation advisory and support services the

aid intensity can be increased up to 100 % of the eligible costs provided that the

total amount of aid for innovation advisory and support services does not exceed

EUR 200 000 per undertaking within any three year period (§4).

Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11.

EUROPEAN COMMISSION DG Competition State aid: General Scrutiny and Enforcement R&D&I, IPCEI and Environment

Brussels, 02/07/2026

COMP/H23/GS/bsz

comp(2026)7175216

Permanent Representation of

Estonia to the EU

Rue Guimard 11/13

1040 Bruxelles

E-Mail: [email protected]

Subject: Monitoring of block-exempted aid measures

SA.107952 (2026.MX) – Ettevõtja rakendusuuringute toetus (alates

02.06.2023)

Dear Madam, dear Sir,

Pursuant to Article 108(1) TFEU (1) "The Commission shall, in cooperation with

Member States, keep under constant review all systems of aid existing in those States".

Consequently, DG Competition carries out an ex post monitoring of a randomly selected

sample of aid measures implemented by Member States.

Aid scheme "SA.107952 Ettevõtja rakendusuuringute toetus (alates 02.06.2023)" has

been chosen for monitoring. The monitoring of this aid scheme covers the period that the

scheme was applicable during the period 2023-2024 (‘reference period’). The monitoring

is registered as SA.107952.MX.

DG Competition will examine whether the selected aid scheme respected the provisions

of the General Block Exemption Regulation (‘GBER’) (2) applicable during the reference

period (3).

According to the GBER (4), in order to enable the Commission to monitor the aid scheme

exempted from notification, Member States shall maintain detailed records with the

(1) Treaty on the Functioning of the European Union.

(2) Commission Regulation (EU) No 651/2014 of 17 June 2014 declaring certain categories of aid

compatible with the internal market in application of Articles 107 and 108 of the Treaty, OJ L 187,

26.6.2014, p. 1, as amended.

(3) This is without prejudice to the possibility to apply subsequent versions of that block exemption

regulation to individual aid granted before the respective provisions of that regulation have entered into

force.

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information and supporting documentation necessary to establish that all the conditions

laid down in the GBER are fulfilled, and provide such records to the Commission upon

its request.

Your authorities are requested to provide the following information concerning the legal

basis of the selected State aid scheme:

(1) To confirm that the legal basis published on the website referred to in the

summary information sheet (https://www.riigiteataja.ee/akt/117022023002) is the

legal basis of the scheme as it applied during the reference period. If this is not

the case, your authorities are requested to provide the applicable legal basis. Your

authorities are also requested to provide a copy of the secondary law provisions

implementing the scheme;

(2) To complete the annexed table, indicating where in the text of the legal basis the

relevant conditions and provisions of the aid measure can be found; and

(3) To indicate whether the scheme is still being applied or whether and when it

expired or was replaced by a successor scheme; in such instance, please indicate

the reference number of the successor scheme and provide the text of the legal

basis.

We would also recall that in case of non-compliance with the provisions of the GBER,

your authorities have the duty to recover any unlawful aid granted in line with the case

law of EU courts (5).

In order to facilitate the correspondence in relation to this monitoring case, we propose to

use English as the working language. Should your authorities agree to this, we kindly

invite you to complete the attached language waiver template and return a signed copy of

it as soon as possible.

Please provide us the contact details of the person(s) in case of questions with respect to

the reply to this request for information, including the e-mail address(es) and the phone

number(s).

The above mentioned information should reach the Commission within 20 working

days of the date of this letter.

In any correspondence, please mention the reference to this monitoring case, as provided

above in the subject SA. 107952.MX.

The official in charge in DG Competition is Guillaume SCHWALL,

[email protected], + 32 2 2952544.

(4) According to Article 12 of Regulation 651/2014, in order to enable the Commission to monitor the aid

exempted from notification, Member States shall maintain detailed records with the information and

supporting documentation necessary to establish that all the conditions laid down in the GBER are

fulfilled, and provide such records to the Commission upon its request; in case of approved aid.

(5) Judgment of the Court of 5 March 2019, C-349/17, Eesti Pagar AS v. Ettevotluse Arendamise

Sihtasutus, ECLI:EU:C:2019:172; Judgment of the Court of 7 April 2022, joined cases C-102/21 and

C-103/21, Autonome Provinz Bozen, ECLI:EU:C:2022:272.

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Yours sincerely,

(e-signed)

Rodrigo Peduzzi

Deputy Head of Unit

Enclosure: Table regarding the legal basis

Enclosure: Template for language waiver