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De minimis aid included in Finnvera’s financing will be public from 1 January 2026
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Although the financing granted by Finnvera is not aid but financing that the client pays back, Finnvera's financing decisions may include imputed de minimis aid. The European Commission Regulation on de minimis aid was amended as from 1 January 2024. The obligation to register de minimis aid laid down in this Regulation will apply from 1 January 2026 and all financing decisions made from that date on. From the beginning of 2026, Finnvera will register information on de minimis aid associated with its financing in the Union's central register. Finnvera will still be subject to a secrecy provision similar to bank secrecy, which means that information on individual financing decisions or clients is secret in all other respects.
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.
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.
The obligation to publish de minimis aid 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 following information will be public: 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.
The publication obligation does not apply to financing granted before 1 January 2026. Neither does it apply to commercially priced financing that does not include aid.
De minimis aid is an imputed subsidy
As a rule, Finnvera's financing decisions include imputed de minimis aid, which means a lower price of financing compared to the EU's market price level. In the case of an entrepreneur loan granted to a private individual, the aid associated with the loan is accrued by the company linked to the entrepreneur loan. The aid is granted in compliance with the European Commission’s De minimis regulation (EU 2023/2831). Under this regulation, the total amount of de minimis aid granted to a single undertaking may not exceed EUR 300 000 over a period of 3 years, and in the fisheries sector, EUR 30,000 over a three-year period. De minimis aid is monitored over a three-year period.
In addition to those granted by Finnvera, de minimis aid can also be included in the grants, loans, and guarantees provided by other public bodies.
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. If the maximum limit is exceeded, the aid may be recovered in full, with interest.
More information on the topic:
Read more about State aid for financing on our legislation page.
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