The new state aid framework is intended to shorten the path from idea to project implementation. In many EU countries they already operate, a Poland, despite high energy prices and the need for rapid transformation, has still not submitted any program – results from an analysis by the Polish consulting company CRIDO.
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Within nine months, member states under the Clean Industrial Deal State Aid Framework (CISAF) prepared activities worth EUR 28 billion. This is a new support mechanism for clean industry, which is intended to make it easier for Member States to quickly notify and implement public aid for investments in renewable energy, net-zero technologies and decarbonization of production. It entered into force on June 25, 2025 and will be valid for five years.
Thematic areas of individual countries' programs
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CRIDO / CRIDO
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So far, it has already been used by, among others: Hungary, France or Spain.
CISAF is intended to give member states greater flexibility in designing support instruments for renewable energy, net-zero technologies and decarbonization. Programs may vary – from direct grants, through tax relief, to preferential loans.
Poland is left behind
Despite large projects by other Member States, Poland – as of the end of March 2026 – has not yet implemented any CISAF-based program. This is surprising given the challenges facing the domestic industry, including some of the highest energy prices in Europe.
— Failure to use the new framework means not only a loss of the opportunity to support investments in clean technologies, but also limited opportunities to compete for industrial projects on the European market. CISAF could play a special role in developed regions where access to support, especially for large enterprises, is currently limited or completely excluded – comments Magdalena Zawadzka, partner at CRIDO from the subsidies and tax relief team.
This could be a chance for Poland to enter to a higher level, e.g. for companies operating in Warsaw.
Especially since the aid provided under CISAF can be combined with EU funds. The CRIDO expert indicates that the support programs notified at CISAF could constitute an aid basis for programs such as FENG, FEnIKS, the Modernization Fund or a government grant, and even the Polish Investment Zone. This would allow for an increase in the scale of investments in net-zero technologies, renewable energy sources, energy storage and decarbonization of industry.
Hungary is focusing on net-zero
The most frequently used area of CISAF are net-zero technologies. According to CRIDO, ten out of thirteen decisions so far concerned programs supporting increasing the production capacity of components and solutions needed for the energy transformation. The total value of support in this segment is EUR 11.4 billion, and the largest allocation, EUR 4.1 billion, was provided by Hungary.
Individual countries adapt the mechanism to their own preferences. For example, Spain, France, Austria and Germany have excluded the production of components for nuclear energy from their programs, and France and Spain additionally do not support CO2 capture technology. France went one step further by also eliminating support for biogas, biomethane and alternative fuels.
Investments in renewable energy
CISAF also enables support for the decarbonization of industry and renewable energy sources, although in this case EU countries use the mechanism much less frequently. So far, only Spain has decided to implement a program in this area worth EUR 408.5 million. Its goal is to reduce greenhouse gas emissions by at least 3,000. tons of CO2 per year. It should be noted here that CISAF, unlike the GBER program, does not introduce a maximum limit on public aid for decarbonization.
They are mainly active in the area of renewable energy sources France and Denmark. Their programs focus on offshore wind energy and are based on the mechanism of contracts for difference, awarded through competitive auctions. Total the allocation in the programs prepared by these two countries exceeds EUR 16 billion and constitutes more than half of the total planned expenditure under the mechanism at the EU scale.
We asked the Ministry of Climate and Energy why Poland did not submit applications under CISAF. Both ministries referred us to the Ministry of Development and Technology, from which we have not received a response until the time of publication.
Grzegorz Kowalczyk, journalist of Business Insider Polska
