It is therefore advisable to check, even before preparing the application, how much de minimis aid we have previously received and how much of the available ceiling the new project is expected to use.
How much de minimis aid is available?
As a general rule, the total amount of de minimis aid received by an undertaking may not exceed EUR 300,000 during the three years preceding the granting of new aid. The reference period is rolling: whenever new aid is granted, the preceding three years, i.e. 3 × 365 days, must be taken into account.
Importantly, the assessment of the available ceiling is not limited to aid received by the applicant itself. Under the de minimis Regulation, aid granted to undertakings forming part of the same single undertaking must also be assessed together.
Timing is also important: the relevant date is not when the aid is actually paid, but when it is granted. Therefore, aid that has already been granted counts towards the ceiling even if it has not yet been disbursed.
The full amount of the aid or financing does not always count
De minimis aid does not only take the form of non-repayable grant funding. It may also be linked to preferential financing, interest subsidies, guarantees, tax advantages or other subsidised schemes.
In such cases, it is not necessarily the full amount of the financing or transaction that counts towards the de minimis ceiling, but the calculated aid element associated with it. The aid provider issues a certificate specifying the amount of aid and confirming its de minimis nature.
Therefore, when planning a new application, it is not sufficient simply to add up the amounts of grants or financing previously received. What needs to be assessed is how much of these amounts qualified as de minimis aid.
What types of costs may be covered?
De minimis aid is not linked to a single type of funding scheme or cost category. Based on both previous and current calls, a wide range of development activities may be financed under this aid category.
In R&D projects, de minimis aid often covers activities supporting research and development, such as project management, publicity, overheads, intellectual property protection, certain hardware and software costs, cloud services or market launch activities.
In other schemes, de minimis aid may also cover equipment, intangible assets, IT developments, consultancy or expert services, training, and other investment-related costs.
The EUR 300,000 ceiling therefore does not mean that this amount of aid can automatically be obtained under a single funding application. Each call for proposals separately defines which activities may be supported under de minimis aid and what aid intensity applies to them.
How is the amount of de minimis aid calculated?
In R&D calls, certain costs eligible for de minimis aid may be determined not on an itemised basis, but as a percentage-based flat rate. In such cases, the flat-rate amount is calculated using a specified cost base, referred to as the calculation base. The composition of the calculation base is always defined by the relevant call for proposals. In some schemes, for example, personnel costs form the calculation base, while in others a broader range of direct costs may be taken into account.
For example, if a call specifies a flat rate of 15% and the calculation base is HUF 100 million, the eligible flat-rate cost will be HUF 15 million. However, this is not necessarily the same as the amount that counts towards the de minimis ceiling: that amount must be determined on the basis of the aid intensity applicable to the relevant cost.
It is therefore important to distinguish between the calculation base, the eligible cost calculated from that base and the actual amount of aid.
How can we find out how much of the ceiling is still available?
From 1 January 2026, new de minimis aid granted in Hungary is recorded in a central register, the National Aid Monitoring System (OTR), and the relevant data can also be accessed through the Public Finance Portal.
However, the system is being introduced progressively and currently contains aid granted from 1 January 2026 onwards. De minimis aid received before this date must therefore still be taken into account, and the related aid certificates should be retained and collected.
Before submitting a new application, it is therefore advisable to review previously received de minimis aid, check the scope of the single undertaking and calculate how much of the remaining ceiling would be used by the new project. Checking the available de minimis ceiling is therefore not merely an administrative step when preparing the application: it should already be taken into account when planning the project content and budget.
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