The Clean Industrial Deal State Aid Framework: Between Green Ambition and Single Market reinforcement

The EESC has adopted an opinion which provides its views on how the Commission should implement the Clean Industrial Deal State Aid Framework (CISAF), the framework adopted on 25 June 2025 to accelerate and de-risk investments in decarbonisation and clean technologies.

Barely six weeks after its adoption, the CISAF was already put into practice with the approval by the Commission of a State aid measure for €11 billion in State aid to support offshore wind energy development in France.      

We welcome the CISAF as a key tool to leverage green investments in the EU and appreciates its alignment with the Net-Zero Industry Act and its complementarity with the Innovation Fund. We also value the fact that the CISAF encourages the adjustment of tax systems to promote investment in clean technologies and industrial decarbonisation through measures such as accelerated depreciation and targeted tax credits, as well as the introduction of the option to grant aid to reduce the risks associated with private investment and renewable energy, industrial decarbonisation, clean technology manufacturing and energy infrastructure.

Nevertheless, we are concerned that certain metrics and aid intensity thresholds in the CISAF may not fully reflect the diverse realities of sectors and regions across the EU. We therefore encourage the Commission to continue engaging actively with the sectors and Member States.

In particular we raise questions about the impact that CISAF can have on the level playing field within the single market. While acknowledging its ambition, we are concerned about the disparities in aid granting capacity across Member States and encourages introducing mechanisms that reward cross-border collaboration and projects generating positive spill-over effects.

Indeed, for over five years now, the Commission has been operating with temporary and non-temporary frameworks to simplify State aid for businesses, addressing crises and supporting the green transition. While the relaxation of EU State aid rules during the COVID-19 and energy crises helped Member States recover, the use of State aid has been uneven, creating a fragmented approach to European green industrial policy.

Therefore, it is essential to provide clear incentives to generate spill-over effects and reinforce European value chains, while, as suggested by Draghi, allowing higher aid intensities where EU coordination is enhanced, and ensuring that existing aid intensities in other cases are not reduced.

On this matter, it is especially relevant that the CISAF included the possibility for Member States to introduce measures to support the electricity costs for the decarbonisation of electricity-intensive sectors. Such measures have been vital, especially amid high costs and international competition. While they may be necessary in the short-term, the opinion warns that they must not delay decarbonisation. It is essential that in their design and implementation the level playing field is preserved and ensure that all eligible energy-intensive users have due access. Moreover, the public support opportunities under the CISAF should not overshadow the need for long-term investments in energy infrastructure, which are essential for ensuring a resilient and sustainable energy transition across the EU.

In this line, we acknowledge that the CISAF is a key instrument, but it cannot be understood on its own and will not work alone: the Clean Industrial Deal (CID) includes a range of investment and financing instruments to support the European industry. In this context, we call for their urgent deployment, alongside a strong Competitiveness Fund and a reinforced Multiannual Financial Framework (MFF) to ensure fair access to finance across Member States. Likewise, we call on the Commission and Member States to expedite permitting procedures, reduce administrative burdens, and adjust taxation. We acknowledge the Commission's initial steps to simplify the business environment and urge Member States to follow it.

To conclude, we express our support for the CISAF but recommend the Commission to assess the effectiveness of existing measures before 2030, and work with Member States to strengthen State aid capacity-building, improve transparency, increase coordination and knowledge-exchange, and reinforce monitoring.

Isabel Yglesias Julià, Rapporteur of ​Opinion INT/1091 and EESC Employers' Group member