The €300,000 ceiling that disqualifies a grant in full
Most founders meet the de minimis ceiling for the first time in a clawback letter. It is the single most consequential rule in small-grant funding across the EU, and almost nothing that hands out the money explains it at the point you apply.
What the rule says
Under Commission Regulation (EU) 2023/2831, Art. 3(2), a single undertaking may receive up to €300,000 of de minimis aid per member state over a rolling 36 months. Rolling, not per calendar year: the window moves with today's date, so aid granted 36 months and one day ago has left it and aid granted yesterday is in it.
The part that catches people
The intuition is that going over the ceiling means the excess is refused. It does not. Article 3(7) is explicit that aid exceeding the ceiling does not benefit from the Regulation at all — not the excess, the whole award. A company with €280,000 already counted that accepts a €40,000 grant has not received €20,000 of usable aid and €20,000 of trouble. It has received an award that falls outside the exemption entirely, and the granting authority is obliged to recover it.
Why nobody warns you
Because no single authority can. The ceiling is per company across every de minimis source in that member state — a regional innovation voucher, a national training subsidy, a municipal rent rebate. The body handing out the third one has no visibility of the first two. That is why the declaration exists: the applicant is the only party who can see the whole picture, and signing the declaration is how the burden gets transferred to them.
What to do about it, concretely
- Keep the ledger before you need it. Date, amount in euros, granting body, member state. The date matters more than people expect, because it determines when headroom frees up again.
- Check the ceiling before the effort, not before the signature. A major bid is six weeks of work. Discovering the ceiling problem at the offer stage means those six weeks are gone.
- Watch the group, not the company. "Single undertaking" includes linked companies. A holding structure does not create a second allowance.
- Know that the clock helps you. If you are over, the oldest award in the window will drop out on a specific date. Sometimes the right answer is to apply in March instead of January.
Of the 1,684 startup funding programmes in our dataset, a substantial share are explicitly de minimis, and they are the small, fast, easy-to-win ones — which is exactly why companies accumulate them without noticing.
Every number above is computed, not typed. They come from the 2,216 records behind this site at the moment the page was built, so the post cannot drift away from the data. Where a programme publishes no figure we count it as zero rather than estimate — which makes the totals here understatements, and deliberately so.