Energy efficiency financial instruments combined with grants

This factsheet provides practical guidance on the State aid implications of combining financial instruments with grants to support energy efficiency investments, particularly in residential and public buildings. Prepared under the fi-compass Scale Up initiative in close cooperation with the DG COMP, it addresses a key area of complexity for managing authorities, national promotional banks and financial intermediaries seeking to combine financial instruments under EU shared-management funds with grant components in compliance with EU State aid rules.
The document explains how State aid can arise at multiple levels within a financial instrument and sets out the conditions under which it can be excluded. It then examines how compatibility with the internal market can be ensured through the General Block Exemption Regulation (GBER) or the Climate, Energy and Environmental Aid Guidelines (CEEAG), analysing four practical combinations of loans with grant components: technical support grants, interest rate subsidies, capital grants for low-income households and performance-linked capital rebates.
Aimed at policymakers and practitioners involved in EU shared-management funds, this factsheet serves as a hands-on reference for navigating State aid compliance when designing energy efficiency financial instruments under the 2021–2027 Common Provisions Regulation. It covers de minimis thresholds and aid intensity ceilings, helping programmes structure compliant combined financial instruments that contribute to EU climate and energy objectives.

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