FAQ – De minimis aid

The imputed aid included in Finnvera’s financing is primarily provided as so-called de minimis aid. If the price or terms of Finnvera’s financing are below the EU’s market price level, the price difference is considered imputed aid. A company may receive a maximum of EUR 300,000 in de minimis aid from different state or municipal actors over a three-year period. For the fisheries sector, the maximum amount of de minimis aid is EUR 30,000 over a three-year period. 

Read more on our Legislation page.

The European Union State aid rules include a transparency obligation, which refers to the Member States' obligation to register certain types of aid granted to undertakings in a public register. The purpose of the public register is to increase the transparency of the aid received, making it easier for both the aid authorities and companies to monitor the aid. The obligation to publish de minimis aid information will enter into force on 1 January 2026. For Finnvera, the publication obligation concerns financing decisions made on or after 1 January 2026 (new financing and changes).

The information published in the register comprises the beneficiary’s name, business ID, the amount of aid granted, date of the decision, and the provider of the financing. In practice, the publication obligation only means registering these individual pieces of information in the aid register. In all other respects, Finnvera’s client data will continue to be confidential. 

Under the De minimis regulation, Member States must ensure that de minimis aid is registered in a centralised national or Union level register. Finland has opted to use the Union level central register for this purpose, obliging the beneficiaries to report their aid information to it.

It is the company’s responsibility to ensure that the total amount of de minimis aid paid by different parties does not exceed these maximum amounts. As the monitoring period of de minimis aid is three years, the register will be fully up to date from the perspective of aid monitoring three years after the registration of the information starts, in other words from 1 January 2029 onwards. 

The De minimis regulation comprises mandatory regulation in the EU, and no national derogations from it can be made by passing statutes inconsistent with it or by any other means.

Aid information will not be published regarding financing decisions made on or after 1 January 2026 that are priced commercially and do not include aid.

Only individual pieces of information relating to the de minimis aid included in the financing will be revealed in the register. No other information relating to an individual beneficiary will be disclosed through the register. Finnvera will additionally still be subject to the bank secrecy obligation, which means that all information concerning the client is secret. 

Regulation at Union level is directly applicable in the Member States. This is why the European Commission's De minimis aid regulation and the transparency obligation contained in it must be applied uniformly in the Member States, despite any national secrecy provisions. 

The publication obligation does not apply to financing granted before 1 January 2026. Neither does it apply to decisions on commercially priced financing that does not include aid made after 1 January 2026

The fact that the aid information is accessible in a public register will help both the aid authorities and companies to monitor the aid granted. In particular, the aid register will help companies to monitor de minimis aid, which is primarily their responsibility by law. If the accumulation of de minimis aid received by a company exceeds the limit, any aid received in excess of the limit will be recovered. 

An undertaking/group may accumulate at maximum EUR 300,000 of de minimis aid over a three-year period. In the fisheries sector, the maximum amount is EUR 30,000 over a three-year period. The aid accumulation is examined retrospectively, counting back three years from the date on which the aid was granted.

For more information on de minimis aid you can, for example, visit  the Ministry of Economic Affairs and Employment's pages on de minimis aid.