Guide · State aid

The de minimis rule: the EUR 300,000 ceiling on small state aid, explained

De minimis is the EU rule that lets a government give a company small amounts of aid without asking Brussels first. The ceiling is EUR 300,000 per company over any period of three years, in each EU country. The current regulation applies from 1 January 2024 to 31 December 2030. Farming has its own, lower ceiling of EUR 50,000.

Two details matter to a foreign investor. The ceiling belongs to the single undertaking, so the Portuguese companies of one group share it. And many small Portuguese supports draw on it, including the reduced corporate tax rates for SMEs. Large investment grants usually rest on other state aid rules and leave your de minimis allowance alone.

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Figures checked against the official sources between 18 and 19 September 2026. We never promise approvals.

Ceiling
EUR 300,000 per single undertaking, per EU country
Period
Any three years, counted back from each new award
In force
From 1 January 2024 to 31 December 2030
Farming
EUR 50,000 over three years, under a separate regulation in force until 31 December 2032
Loans and guarantees
Count by their aid value. The regulation gives safe harbours
Register
Central register mandatory from 1 January 2026. Portugal has run one for years, through AD&C

What the rule is for

EU law bans state aid that distorts competition, and governments have to notify the European Commission before they give it. The de minimis regulation carves out amounts too small to matter: below the ceiling, the aid needs no notification and no approval.

For a company, de minimis is a label on a support measure. The call or the regulation of the measure says so, in the section on state aid. When you see the label, the amount counts towards your ceiling.

How the ceiling works

  • EUR 300,000 over any three years. The period rolls. For each new award, the authority looks back three years from that date and adds up what you received.
  • The date that counts is the award, the day you gain the legal right to the aid, whenever the money arrives.
  • Per single undertaking, and the ceiling is per country. Companies linked by control count as one, and each EU country adds up only the de minimis aid it granted itself. Your Portuguese companies share one Portuguese ceiling. Aid that the parent received in Germany or France sits in those countries' ceilings.
  • All forms of aid count: grants, tax reductions, cheap loans, guarantees. The authority converts each one into its grant equivalent.

An award that would take you over the ceiling cannot go ahead under de minimis as it stands. The authority refuses it, or reduces it until the whole award fits, before it grants anything.

What counts in Portugal, and what usually does not

Counts. The reduced corporate tax rates: article 87 of the tax code places the 15% SME rate and the 12.5% startup rate on the first EUR 50,000 of profit under the de minimis rules, and the Tax Benefits Statute does the same for the 12.5% interior rate. Many smaller national and regional supports carry the label too. Read the state aid section of each one.

Usually does not count. Large investment grants, such as Portugal 2030 Productive Innovation, normally rest on the General Block Exemption Regulation, with its own ceilings by region and company size. The same applies to RFAI, a regional aid scheme. The call or the law names the rule it uses.

The practical effect: a group that has filled its de minimis allowance with small supports can still apply for a large investment grant. The reverse also holds, and a large grant leaves the allowance untouched.

Loans and guarantees

A subsidised loan or a public guarantee contains aid, and the regulation tells the authority how to measure it. It also sets safe harbours, amounts the authority can treat as within the ceiling without a full calculation:

  • A loan of up to EUR 1.5 million over five years, with collateral covering at least half of it.
  • A guarantee of up to EUR 2.25 million over five years, covering no more than 80% of the loan behind it.

Bank credit lines with a mutual guarantee often use these rules. The bank or the guarantee society tells you the de minimis amount attached to your loan.

Sectors with other rules

  • Primary farm production has its own regulation: EUR 50,000 over three years, in force until 31 December 2032. See farm grants in Portugal.
  • Fisheries and aquaculture have a separate regulation as well.
  • Export aid and aid that depends on using domestic goods instead of imported ones are outside the rule.

How to check what you have used

Before an authority awards de minimis aid, it asks you to declare the de minimis aid your single undertaking received in the previous three years. From 1 January 2026 the regulation requires each country to record every award in a central register, within 20 working days of the award.

Portugal already has that register. The Cohesion and Development Agency (AD&C) runs it, the system is called SircaMinimis, and companies consult their own records through Balcão dos Fundos. The authority that grants the aid checks the register before it awards anything.

What foreign groups get wrong

  • Thinking the ceiling caps every grant. It caps de minimis aid. Large investment grants follow other rules.
  • Counting per company. Two Portuguese subsidiaries of the same parent share one ceiling.
  • Counting by calendar year. The three years roll, from the date of each award.
  • Forgetting the tax rate. A reduced corporate tax rate is aid, and it uses the allowance year after year.
  • Importing the group's history. Aid received in other EU countries stays in those countries' ceilings.

Frequently asked questions

What is the de minimis limit in 2026?

EUR 300,000 per single undertaking over any period of three years, in each EU country. Primary farm production has a separate ceiling of EUR 50,000.

Does the ceiling apply to Portugal 2030 grants?

To some small ones, when the call says the support is de minimis. The large investment grants normally use the General Block Exemption Regulation, which has its own limits. The state aid section of the call tells you.

Does aid received by our parent company abroad count?

No. The ceiling applies per EU country. In Portugal you add up the aid received by the linked companies established in Portugal.

How do I find out how much de minimis aid my company has received?

In Portugal, the AD&C central register records the awards, and beneficiaries consult it through Balcão dos Fundos. Your certified accountant can also identify tax reductions granted under de minimis.

What happens if an award takes us over the ceiling?

The authority cannot make that award under de minimis as it stands. It reduces the amount until it fits, refuses it, or grants the support under another state aid rule if one fits. Aid given over the ceiling by mistake has to be recovered.

Official sources

The official texts are in Portuguese. The figures on this page were checked against them.

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