Does aid received in another EU country count?

Yes. The ceiling applies per single undertaking under EU law, so de minimis aid granted to your group in any Member State counts towards the EUR 300,000.

Which date counts, approval or payment?

The date on which your company obtains the legal right to the aid, usually the date of the grant decision, not the payment date.

Do I still need to sign a de minimis declaration in 2026?

In most cases yes. Until the central register covers a full three-year period, funding bodies continue to ask for your declaration. According to the economics ministry of Baden-Württemberg, this applies until the end of 2028.

De Minimis Aid in Germany: EUR 300,000 Rule

De minimis aid (De-minimis-Beihilfen) is small-scale state support that the EU considers too minor to distort competition. Under Regulation (EU) 2023/2831, in force since 1 January 2024, a company may receive no more than EUR 300,000 of such aid over any three-year period. If you apply for grants in Germany, you will meet this rule often: many consulting, start-up and innovation programmes use it, and each time you must disclose the de minimis aid your group has already received.

Where you will encounter it

German federal and state programmes like the de minimis route because it requires no notification to the European Commission. Common examples:

Grants for consulting, trade fairs, digitalisation or start-ups.
Feasibility studies in the ZIM programme, which have been granted as de minimis aid since the 2025 guideline (see our ZIM guide).
Under the research allowance, the own work of sole proprietors and partners is treated as de minimis aid.
Subsidised loans and guarantees, counted at their aid value (gross grant equivalent), not their nominal amount.

The programme guideline and your grant decision state whether de minimis rules apply. Look for the term „De-minimis-Beihilfe“ and for the de minimis certificate (De-minimis-Bescheinigung) attached to the decision.

The ceiling and the single undertaking

The EUR 300,000 limit applies per single undertaking (einziges Unternehmen), not per legal entity. Companies form one single undertaking if one of them:

holds a majority of the shareholders’ voting rights in another;
can appoint or remove a majority of another’s management or supervisory body;
exercises dominant influence through a contract or the articles of association; or
controls a majority of voting rights through an agreement with other shareholders.

If you own several German companies through a holding, they share one ceiling. Services of general economic interest (SGEI) have their own regulation, (EU) 2023/2832, with a higher ceiling; agriculture and fisheries also have separate rules.

How the rolling period works

Before 2024, the rule looked at three fiscal years. Now any period of three years counts, so each new grant is checked against the three years immediately before it.

Step	Example (invented figures)
Planned grant date	15 March 2027
Period checked	16 March 2024 to 15 March 2027
De minimis aid already received	EUR 180,000
Remaining headroom	EUR 120,000
New grant requested	EUR 150,000
Result	not possible as de minimis aid (total EUR 330,000)

If a new grant would push you over the ceiling, the whole grant falls outside the regulation, not just the excess. Whether a funding body can instead approve a lower amount depends on its guideline.

How the aid value is measured

What counts is the aid value as a gross grant equivalent, before tax. For a grant this is simply the amount awarded. For a subsidised loan or a guarantee, only the advantage compared with market terms counts; the funding body calculates it under the regulation’s rules and states it on the certificate. The regulation only covers so-called transparent aid whose value can be calculated precisely in advance (Art. 4).

Some activities cannot be supported as de minimis aid at all, including aid directly linked to export quantities or to setting up a distribution network abroad, and aid conditional on using domestic rather than imported goods (Art. 1).

Declaration and certificate

When you apply, you sign a de minimis declaration (De-minimis-Erklärung) listing all de minimis aid your single undertaking received in the relevant period, with date, funding body and amount or aid value. With the approval, you receive a de minimis certificate. Keep every certificate: you need them for each future application, and incomplete declarations can lead to repayment.

The central register from 2026

Art. 6 of the regulation requires Member States to record de minimis aid in a central register at national or EU level from 1 January 2026 at the latest. According to a factsheet by the economics ministry of Baden-Württemberg, Germany uses the Commission’s eAIR system, and granting authorities enter aid within 20 working days of granting it. As long as the register does not yet cover a full three-year period, your own declaration remains necessary; the ministry states this applies until the end of 2028.

Cumulation

De minimis aid can be combined with other de minimis aid up to the ceiling. It may only be combined with aid under the General Block Exemption Regulation or a Commission decision for the same eligible costs if the maximum aid intensity allowed there is not exceeded (Art. 5). Our guide on funding rates and own contribution explains those intensities. For planning several applications in a row, an adviser from our grant consultant directory or your tax adviser can help you track the remaining headroom.

Sources

This guide does not replace tax or legal advice; the programme guideline and the grant decision of the funding body are binding.

De minimis aid: the EUR 300,000 ceiling, the rolling three-year period and the new central register