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 H3: IPCEI, Environment and Innovation II

Brussels, 06/11/2026 DG COMP H3/GS/bsz

comp(2026)11517741

Permanent Representation of

Estonia to the EU

Rue Guimard 11/13

Bruxelles – 1040

[email protected]

[email protected]

Subject: Monitoring of Block Exemption Measures

SA.107952.MX – EE – Ettevõtja rakendusuuringute toetus (alates

02.06.2023)

Dear Madam, dear Sir,

I thank you for all the information your authorities provided on the above-mentioned

scheme in the framework of the 2026 monitoring exercise.

On the basis of the information submitted by your authorities, DG Competition considers

that the scheme under reference SA.107952 – EE – Ettevõtja rakendusuuringute

toetus (alates 02.06.2023) is, prima facie, in line with the provisions of the General

Block Exemption Regulation (GBER)1.

In this context, DG Competition has decided not to ask your authorities for any

additional information regarding the above measure.

Nevertheless, in the case at hand, it is noted that with respect to some of the compatibility

conditions, namely i. that all figures used shall be taken before deduction of taxes and

other charges (Art. 7 (1) GBER), ii. that aid payable in the future shall be discounted

(Art. 7 (3) GBER) and iii. aid cumulation rules (Art.8 GBER), the national legal basis

merely makes a general reference to the GBER, without outlining the requirements of the

relevant GBER provisions in the national legal basis itself.

We would like to draw your authorities' attention to the fact that it is important to outline

the relevant GBER requirements in the text of the national legal basis, in order to ensure

that interested parties have no doubts as to the conditions on which aid can be granted.

1 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.

2

Therefore, the Estonian authorities should consider reflecting the relevant GBER

requirements more explicitly in any future GBER schemes (e.g. by copying the text of

the relevant GBER provisions in the national legal basis).

Yours sincerely,

e-signed

p.o. Rodrigo PEDUZZI

Max LIENEMEYER

Head of Unit

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 H3: IPCEI, Environment and Innovation II

Brussels, 06/11/2026 DG COMP H3/GS/bsz

comp(2026)11517741

Permanent Representation of

Estonia to the EU

Rue Guimard 11/13

Bruxelles – 1040

[email protected]

[email protected]

Subject: Monitoring of Block Exemption Measures

SA.107952.MX – EE – Ettevõtja rakendusuuringute toetus (alates

02.06.2023)

Dear Madam, dear Sir,

I thank you for all the information your authorities provided on the above-mentioned

scheme in the framework of the 2026 monitoring exercise.

On the basis of the information submitted by your authorities, DG Competition considers

that the scheme under reference SA.107952 – EE – Ettevõtja rakendusuuringute

toetus (alates 02.06.2023) is, prima facie, in line with the provisions of the General

Block Exemption Regulation (GBER)1.

In this context, DG Competition has decided not to ask your authorities for any

additional information regarding the above measure.

Nevertheless, in the case at hand, it is noted that with respect to some of the compatibility

conditions, namely i. that all figures used shall be taken before deduction of taxes and

other charges (Art. 7 (1) GBER), ii. that aid payable in the future shall be discounted

(Art. 7 (3) GBER) and iii. aid cumulation rules (Art.8 GBER), the national legal basis

merely makes a general reference to the GBER, without outlining the requirements of the

relevant GBER provisions in the national legal basis itself.

We would like to draw your authorities' attention to the fact that it is important to outline

the relevant GBER requirements in the text of the national legal basis, in order to ensure

that interested parties have no doubts as to the conditions on which aid can be granted.

1 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.

2

Therefore, the Estonian authorities should consider reflecting the relevant GBER

requirements more explicitly in any future GBER schemes (e.g. by copying the text of

the relevant GBER provisions in the national legal basis).

Yours sincerely,

e-signed

p.o. Rodrigo PEDUZZI

Max LIENEMEYER

Head of Unit