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De minimis aid explained simply: What it means for BAFA and INQA funding

AuthorMuhamed Alahmed
Published on
Reading time4 min

Image: AI-generated

In short

De minimis aid is a form of state funding granted in such a small amount that it may be awarded without approval from the European Commission. A company may receive no more than €300,000 in de minimis aid within three years. Both BAFA consulting funding and INQA-Coaching are de minimis aid; when applying, you must therefore declare any previous aid received.

A de minimis aid is a form of state aid granted in such a small amount that, in the view of the European Commission, it does not have a noticeable effect on competition in the EU and may therefore be awarded without separate approval. Under the current Regulation (EU) 2023/2831, a company may receive no more than €300,000 in de minimis aid within three years. The BAFA consulting grant and the INQA-Coaching are both de minimis aid; when applying, you must therefore state which such funding you have received in the last three years.

As of: October 2026. Definition also in the glossary under de minimis aid.

Rules at a glance

Rule

Content

Legal basis

Regulation (EU) 2023/2831, in force since 1 January 2024

Maximum amount

€300,000 per “single undertaking”

Period

three years, rolling (no longer three fiscal years)

Reference date

The date on which the entitlement to the aid arises (approval), not the payment

Linked enterprises

are added together

Proof

De minimis declaration with the application, keep the certificate for ten years

Until the end of 2023, the limit was €200,000 over three fiscal years. Older information sheets therefore still mention this figure.

How the €300,000 limit is calculated

The following is countedSubsidy amount of all de minimis aid your company has been granted in the three years prior to the new application, regardless of the source: federal government, state, municipality, or chamber. For a grant, this is the grant amount; for subsidized loans or guarantees, it is a calculated benefit stated in the respective certificate.

Example: Two years ago, a company received a state digitalization grant of €15,000 as de minimis aid and is now applying for BAFA consulting funding. In the de minimis declaration, it lists the state grant. Together with the new grant, it is well below €300,000, so the funding can be approved.

For typical SMEs that use consulting and digitalization funding, the limit is rarely a problem. It can become critical if a company has also received larger investment grants or subsidized loans as de minimis aid.

What this means for BAFA and INQA

  • BAFA consulting funding: With the application, you submit the “EU SME and de minimis declaration.” BAFA only grants the funding once it is clear that the threshold will not be exceeded. Applications are still possible until 31/12/2026; the process is described in the article Apply for BAFA consulting funding.
  • INQA-Coaching: Here too, a de minimis declaration must be submitted during the application process; in the case of affiliated companies, only one company from the group can receive funding. The process is described in the article INQA-Coaching process.

Both programs may not be combined for the same consulting engagement. Which is the better fit is compared in the article INQA-Coaching or BAFA funding?.

The central register from 2026

Since 1 January 2026, de minimis aid is to be recorded in a central, publicly accessible register. Until the register covers the full three-year period, the company’s declaration remains required. Therefore, continue to keep all de minimis certificates properly filed.

Typical mistakes

  • Forgetting previous aid: Even small grants from the state, municipality or chamber count if they were granted as de minimis aid. This is stated in the respective certificate.
  • Not counting affiliated companies: If several companies belong to the same owner, the limit may apply to all of them together.
  • Discarded certificates: They must be retained for ten years.

Which funding program is eligible for your project is shown by the Funding Check in just a few minutes.

Frequently Asked Questions

What is a de minimis aid?

A state aid measure of a low amount that may be granted without approval from the European Commission because it does not noticeably affect competition. Per company, a maximum of €300,000 is allowed within three years.

What is the de minimis threshold?

Under Regulation (EU) 2023/2831, €300,000 within three years, calculated on a rolling basis. Until the end of 2023, it was €200,000 over three fiscal years.

Is the BAFA consulting grant a de minimis aid?

Yes. When submitting the application, you provide a de minimis declaration covering all de minimis aid received in the last three years.

Is INQA-Coaching a de minimis aid?

Yes. A de minimis declaration must also be submitted during the application process for INQA-Coaching.

How long do I have to keep de minimis certificates?

Ten years from the date of approval. You need them for later applications and possible audits.

Next step

We work as consultants for BAFA- and INQA-funded projects and clarify the funding requirements with you before the start. Contact us via the contact page an.

Sources: BAFA glossary: de minimis aid, BAFA: funding for management consulting, INQA: Information for SMEs.

Portrait of Muhamed Alahmed, founder of bettersorted
About the author

Muhamed Alahmed

With over 10 years’ experience in IT, I develop solutions that not only work from a technical perspective, but also create real added value and open up new possibilities.

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