Complementary instruments alongside the GBER
In our previous article "Renewal of the General Block Exemption Regulation", we provided a detailed overview of the planned reform of the General Block Exemption Regulation (GBER), which serves as a cornerstone of the EU state aid framework by ensuring fast, predictable and transparent aid rules for Member States. The proposed changes clearly demonstrate that EU state aid policy is increasingly moving towards greater flexibility and stronger support for strategic objectives.
Frameworks beyond the GBER
Against this backdrop, targeted frameworks such as the Clean Industrial State Aid Framework (CISAF) and the Middle East Crisis Temporary State Aid Framework (METSAF) should be understood. These instruments do not replace the general state aid rules, including GBER. Instead, they complement them and provide additional room for Member States to pursue specific economic policy objectives.
The two frameworks perform different functions within this multi-layered regulatory environment. While CISAF primarily supports investments related to the green industrial transition and long-term competitiveness, METSAF is a temporary instrument specifically designed to address an acute economic shock. What they have in common is that both enable targeted, rapid and situation-specific interventions while remaining integrated into the existing state aid architecture.
CISAF: A framework for supporting the green industrial transition
CISAF was adopted by the European Commission on 25 June 2025 as the state aid pillar of the Clean Industrial Deal. Its primary objective is to enable Member States to support green transition investments quickly and at scale while safeguarding the integrity of the Single Market.
The framework covers several key areas:
- deployment of renewable energy and clean energy systems,
- industrial decarbonisation, particularly in energy-intensive sectors,
- expansion of clean technology manufacturing capacities,
- electricity cost compensation and competitiveness support.
One of the most significant innovations of CISAF is the substantial relaxation of state aid approval requirements, particularly in sectors where European industry faces increasing global competitive pressure, such as from the U.S. Inflation Reduction Act (IRA) or Chinese industrial policy. In practice, the EU is moving from a largely reactive competition-control model towards a more proactive industrial policy financing approach.
The framework will remain in force until the end of 2030, creating a stable and predictable environment for long-term investments.
METSAF: A rapid response to a geopolitical shock
Unlike CISAF, METSAF is a classic crisis-management instrument introduced by the European Commission on 29 April 2026 to mitigate the economic consequences of the Middle East crisis.
The immediate rationale behind the framework was that the conflict led to:
- higher energy prices,
- rising fuel and fertiliser costs,
- significant cost shocks affecting businesses across the real economy.
Accordingly, the purpose of METSAF is not structural transformation but the rapid management of liquidity constraints and cost-side pressures. The main target sectors include:
- agriculture and food production,
- fisheries,
- transport and logistics,
- energy-intensive manufacturing industries.
The framework provides several specific instruments, including:
- compensation of up to 70% of increased input costs,
- simplified aid schemes (e.g. up to EUR 50,000),
- higher aid intensities for electricity-related support.
An important feature of METSAF is its temporary nature. It is applicable only until 31 December 2026, clearly reflecting its emergency and short-term character.
The integrated logic of the two frameworks
METSAF explicitly builds on CISAF in several respects and even modifies certain elements of it. For example, it allows for increased aid intensities under specific CISAF measures, particularly in the field of energy price compensation.
What does this mean at Member State level?
It is important to underline that the entry into force of CISAF and METSAF does not automatically result in the introduction of new aid schemes in the Member States. Rather, these frameworks create regulatory and policy opportunities, enabling governments to design and implement relevant support programmes within the conditions defined by the frameworks and in line with their own priorities and budgetary capacities.
For companies to gain actual access to these instruments, Member States must take an active role. They must decide which elements of CISAF and/or METSAF they intend to apply and develop the specific aid programmes operating under these frameworks. Consequently, practical availability and the volume of support will largely depend on national-level implementation. In this respect, the recently formed Hungarian government may already take these instruments into account when reconsidering the future direction of state aid policy.
