Support for mapping and developing cybersecurity levels

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, 26/11/2025

COMP/H23/HS/bsz

comp(2025)13110605

Permanent Representation of

Estonia to the EU

Rue Guimard 11/13

1040 Bruxelles

E-Mail: [email protected]

[email protected]

Subject: Monitoring of Block Exemption Measures

SA. 106808 (2025/MX) - Support for mapping and developing

cybersecurity levels

Dear Madam, dear Sir,

I thank you for the letter dated 10 November 2025 in which your authorities provided

information on the above-mentioned scheme.

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

the scheme under reference is, prima facie, in line with the provisions of the General

Block Exemption Regulation (GBER)1.

At the same time, we would like to draw your authorities' attention to the fact that the

rules relating to cumulation of aid (as set out in Article 8 of the GBER) are not included

in the “Conditions and Procedure for Supporting the Mapping and Development of

Cybersecurity Level” but only indirectly mentioned via references to the GBER or the de

minimis Regulation. Please note that for the sake of clarity, it is preferable for future aid

scheme to fully incorporate criteria, such as those related to cumulation of aid, into the

legal basis of an aid measure, rather than simply referring to the source of the definition

and its associated criteria.

DG Competition has decided not to ask your authorities for any additional information

regarding the above measures.

1 Commission Regulation (EC) No 800/2008 of 6 August 2008 declaring certain categories of aid

compatible with the common market in application of Articles 87 and 88 of the Treaty (now Articles

107 and 108 TFEU) OJ L 214, 9.8.2008, p. 3, as from 1 July 2014 replaced by 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

We however would like to draw your attention to the fact that the monitoring was limited

to the assessment of the compliance of the national legal basis with the GBER.

Therefore, the closure of this case does not contain any conclusions beyond that

assessment and the aid scheme concerned, or its successor may be subject to subsequent

monitoring.

The official in charge of this file in DG Competition is Saskia HENDRIKS

([email protected]).

Please mention the reference to this case file, as provided in the subject SA.106808

(2025/MX), in any future correspondence.

Yours sincerely,

e-signed

Demos SPATHARIS

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 R&D&I, IPCEI and Environment

Brussels, 26/11/2025

COMP/H23/HS/bsz

comp(2025)13110605

Permanent Representation of

Estonia to the EU

Rue Guimard 11/13

1040 Bruxelles

E-Mail: [email protected]

[email protected]

Subject: Monitoring of Block Exemption Measures

SA. 106808 (2025/MX) - Support for mapping and developing

cybersecurity levels

Dear Madam, dear Sir,

I thank you for the letter dated 10 November 2025 in which your authorities provided

information on the above-mentioned scheme.

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

the scheme under reference is, prima facie, in line with the provisions of the General

Block Exemption Regulation (GBER)1.

At the same time, we would like to draw your authorities' attention to the fact that the

rules relating to cumulation of aid (as set out in Article 8 of the GBER) are not included

in the “Conditions and Procedure for Supporting the Mapping and Development of

Cybersecurity Level” but only indirectly mentioned via references to the GBER or the de

minimis Regulation. Please note that for the sake of clarity, it is preferable for future aid

scheme to fully incorporate criteria, such as those related to cumulation of aid, into the

legal basis of an aid measure, rather than simply referring to the source of the definition

and its associated criteria.

DG Competition has decided not to ask your authorities for any additional information

regarding the above measures.

1 Commission Regulation (EC) No 800/2008 of 6 August 2008 declaring certain categories of aid

compatible with the common market in application of Articles 87 and 88 of the Treaty (now Articles

107 and 108 TFEU) OJ L 214, 9.8.2008, p. 3, as from 1 July 2014 replaced by 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

We however would like to draw your attention to the fact that the monitoring was limited

to the assessment of the compliance of the national legal basis with the GBER.

Therefore, the closure of this case does not contain any conclusions beyond that

assessment and the aid scheme concerned, or its successor may be subject to subsequent

monitoring.

The official in charge of this file in DG Competition is Saskia HENDRIKS

([email protected]).

Please mention the reference to this case file, as provided in the subject SA.106808

(2025/MX), in any future correspondence.

Yours sincerely,

e-signed

Demos SPATHARIS

Head of Unit