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You applied for energy compensation when the bills doubled, a digitalization voucher when you replaced the till system, maybe a hiring premium for your first permanent hire, and an investment grant for the new kitchen. Four applications, four different agencies, four decisions that each made sense on their own — and nobody ever lined them up next to each other.
That lining-up is exactly what the European Union does do, through a rule that rarely gets explained out loud because it doesn't live in the application form — it lives in the fine print of every approval letter: the "de minimis aid" rule. In essence, it says that every undertaking — your restaurant included — may receive no more than a fixed amount of this type of public support within a rolling window of three fiscal years, no matter which agency, which level of government, or under which name that support arrives.
The rolling window is exactly why almost nobody tracks it correctly. It isn't a calendar year that resets to zero every January 1st — it slides forward, fiscal year by fiscal year, and support you received three years ago still counts right up until the moment that year drops out of the window. Meanwhile new support keeps arriving through channels that never talk to each other: a regional energy measure, a national or regional digitalization call, a sector hiring premium, an investment grant from a completely different agency. Every approval letter states "this is de minimis aid" somewhere in a paragraph nobody reads, and none of those four agencies knows what the other three already granted.
The result is a ceiling that stays completely invisible right up until it isn't: a new, perfectly legitimate grant application gets rejected, or worse, a grant gets approved and later — sometimes years later — clawed back because it pushed the shared total over the line. And since this year there's no more "nobody sees it" either: every EU member state now has to keep a central register where every award shows up within weeks.
This guide walks through the seven numbers that actually govern this rule: how high the ceiling is, how much it recently changed, how the rolling window works, and what's now being logged centrally. At the bottom you'll put your own grant history into a calculator that works out how much room you have left — before you start a new application, not after. Everything runs in your own browser: nothing is sent anywhere and nothing is stored.
Why nobody ever adds this ceiling up
Every other cost line on this site has one clear source: one lease, one energy supplier, one payment processor. Grants are the opposite — they arrive through a patchwork of regional, national and EU channels, each with its own application form, its own approval letter, and its own way of saying "this falls under de minimis aid" (sometimes stated plainly, sometimes buried in a reference to "Regulation (EU) 2023/2831").
That fragmented landscape is exactly why an owner who received four different premiums almost never sees them as one number. The energy premium came from the region, the digitalization voucher from a national call, the hiring premium from the employment agency or a regional jobs fund, the investment grant from yet another body. For your bookkeeping, they're four separate line items. For EU state-aid rules, they're four pieces of exactly the same total.
And unlike a VAT audit or a food-safety inspection, breaching it rarely produces one visible moment that forces a decision — until a new application gets rejected on a rule you'd never heard of, or a grant already paid out gets clawed back later. This guide is the moment you finally put those four letters side by side.
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They run in the order the rule itself works: first the ceiling and what falls under it, then how the window moves through time, and finally what's now being logged centrally — and what a breach actually costs you.
1. €300,000 — the shared ceiling you've probably never looked up
Commission Regulation (EU) 2023/2831 sets the maximum amount of "de minimis aid" a single undertaking may receive at €300,000, per Member State, over a rolling window of three fiscal years. "De minimis aid" is the EU's term for public support considered small enough not to distort competition, and which can therefore be granted without the heavy prior European approval process — exactly the kind of support an independent restaurant runs into most often: energy compensation, digitalization vouchers, hiring premiums, smaller investment grants, and the aid element inside a cheap government-backed loan or guarantee.
The figure applies "per undertaking", and that term is broader than most owners assume: it covers every legally connected entity under common control. Two restaurants sharing the same owner or the same holding structure count together toward one shared €300,000 ceiling — not one each. That is exactly the kind of detail that sits in an approval letter and never comes up in conversation.
This number is the whole foundation of this guide: it isn't a limit per grant, per agency or per year — it's one shared pot for all aid of this type, combined. The next six numbers are what actually fills that pot, moves it, and makes it visible.
2. 5 — the number of different aid types quietly falling into the same pot
The five forms an independent hospitality business runs into most often all count: energy compensation or crisis aid, a digitalization premium or voucher, a hiring or wage subsidy, an investment or renovation grant, and the aid element inside a discounted-rate loan or a government guarantee. That last one is the least intuitive: it isn't the full amount borrowed that counts, only the benefit compared with what a normal bank would charge — the so-called "gross grant equivalent". A €200,000 loan at an interest rate 2 percentage points below market can easily work out to a few thousand euros of aid equivalent, not €200,000.
The graphic below lines up five such awards — a realistic profile for a business that has actively applied for support over the last three fiscal years — against the €300,000 ceiling. Together they land at roughly 57% of it, which is exactly the point: none of the five feels risky on its own, and yet more than half the room is already used before a single new application is even considered.
This is also where the lack of communication between agencies shows most clearly: none of the five bodies that granted them knew about the other four. Every approval letter listed its own amount and its own de-minimis statement, and none of them added it up for you.
Five realistic awards to the same business, added up against the €300,000 ceiling.
This example lands at roughly 57% of the ceiling — five entirely ordinary awards, from four different agencies, that have quietly used up more than half the shared pot. Plug in your own numbers in the calculator below.
3. 3 fiscal years — why the counter never resets to zero on January 1st
The three-fiscal-year window is rolling, not fixed: at any moment, the current fiscal year and the two before it count, and as soon as a new fiscal year begins, the oldest one drops out automatically — not because you apply for or report anything, simply because time passes. That's fundamentally different from an annual grant cap that resets every January 1st; here, aid builds up across three years at once, and nothing ever fully resets.
The graphic below shows four consecutive fiscal years for the same business: the oldest year (three years ago) has just fallen out of the window — it used to count, it no longer does — while the two years that followed it, plus the current year, together form the window that counts today. Next fiscal year, today's oldest year in turn drops out, and everything shifts forward by one.
The practical trap is obvious: an owner who thinks "I haven't applied for anything this year, so I'm well under the ceiling" forgets that last year and the year before still count in full. The calculator further down handles this automatically — you enter what you received in total over the last three fiscal years, not just this calendar year.
What counts today, and what just dropped out — for the same business, four fiscal years in a row.
Window of 3 fiscal years counting today: €170,000
Next fiscal year, the "2 years ago" figure drops out in turn and the window automatically shifts forward one year — with nothing to apply for or report. This is an illustrative example; your own amounts and years are what count.
4. 50% — how big the jump was when the ceiling changed on January 1st, 2024
Before January 1st, 2024, the general de minimis ceiling stood at €200,000. The new regulation — Commission Regulation (EU) 2023/2831 of 13 December 2023, applicable from 1 January 2024 through 31 December 2030 — raised that figure by 50%, explicitly to account for years of inflation and price increases. That is the figure used throughout the rest of this guide, and it is newer than what many advisors, accountants and even some government websites still quote.
That jump is more than a technical footnote: it means a business that hit the old €200,000 ceiling exactly three years ago has since gained an extra €100,000 of headroom — room few have consciously noticed, let alone used. Conversely, anyone who still hears "€200,000" quoted as the ceiling today is being told a figure that has been wrong for more than two years.
It's also a signal that these rules do get revised periodically — the regulation runs until the end of 2030, which means a future adjustment is due somewhere along that timeline. Anyone adding up their own grant history today should do so against the current €300,000 figure, and check it again whenever the next revision makes the news.
5. 1 January 2026 — the year every Member State had to switch on a central register
As of the 1st of January this year, every EU Member State is required to keep a national register of de minimis aid, logging every award and reporting to the European Commission annually. Before this date, keeping track of your own ceiling was largely a matter of your own paperwork — filing your approval letters and adding them up yourself, with little chance any single agency would ever notice a breach unless it went looking for one.
That has now changed. Every award appears centrally, which means an agency assessing a new application can in principle see what you already received elsewhere — something that was technically possible before but rarely happened in practice, simply because the data wasn't in one place. For an owner who stays comfortably inside the ceiling, nothing changes. For anyone who never added it up, "I didn't know" is a much weaker defence.
It's also why this guide is being written now rather than three years ago: the rule itself is older, but the moment it moved from a bookkeeping formality to a visible, cross-checked system is this year.
6. 20 working days — how fast your award now appears in that register
The body granting the aid — the region, the national government, the sector fund — has to log the award in the national register within 20 working days of the decision. That's faster than most owners expect: a grant approved this month is registered centrally within about a month, well before your next year-end close.
In practice this means your own paperwork — the approval letters you keep yourself — is no longer the only source of truth, but it's still the fastest one. The register is built for agencies to check against each other, not as a self-service portal where you as an owner can pull your own running total; in practice, the approval letter, with its explicit statement of the amount granted and the regulation it falls under, remains your own most reliable source.
So it isn't a replacement for keeping your own records — it's a guarantee that what you keep yourself and what's registered centrally now have to match within a few weeks, a discrepancy that used to stay unnoticed for years and now surfaces much faster.
7. 10 years — how long a breach stays provable, and what you repay
The registration data has to be kept for ten years from the date of the final payment — not from the date of the award, but from the moment the money was actually paid out. That's a long window: a breach that happens today can still be checked well into the next decade, even if the business has since changed hands or the original applicant is no longer active.
What happens in a breach is less clear-cut than most of the other numbers in this guide, and that's exactly why this guide isn't legal or tax advice: the consequences depend on national implementing rules and on how the breach is established. Under most frameworks, the granting authority can demand repayment of the amount above the ceiling, plus interest; in some cases, an entire award wrongly treated as de minimis aid can be reclaimed — not just the part above the line.
That's what makes the calculator below worth more than a one-off check: it's meant as a habit, something you consult before every new application, not a test you run once and forget. A business comfortably under the ceiling today may not be in two years — not because anything went wrong, but simply because the window keeps sliding and the counter never stands still.
The De Minimis Headroom Calculator
Enter what you received over the last three fiscal years across each of the five aid types, plus the amount of a new grant you're now considering. The calculator adds it up, holds it against the €300,000 ceiling, and shows how much room you have left — or how far over you'd be.
Use the figures from your own approval letters, not from memory: the gross grant equivalent of a favourable loan is usually stated explicitly in there, and it's often very different from the amount actually borrowed.
How much room do you have left under the €300,000 ceiling?
Six numbers from your own files, added up into one answer: check this before you file a new application.
How much of the €300,000 ceiling is already used
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This calculator gives an indication based on Regulation (EU) 2023/2831; it doesn't replace advice from your accountant or the granting body itself, especially for the gross grant equivalent of loans and guarantees. Everything runs in your browser; nothing is sent or stored.
A negative result doesn't automatically mean the new application is impossible — some support falls outside de minimis aid entirely (for example under a separate, individually approved scheme with its own ceilings), and it's up to the granting body to confirm that. It does mean you're better off asking that question before you apply than after.
Keep every approval letter, even long after the money has been paid out — it's the one place where both the amount granted and the applicable regulation are stated in black and white, and with a ten-year retention period on the authorities' side, it's worth archiving your own copies for at least as long.
What to do this week, this month and this quarter
Seven numbers and a rule you've never looked up isn't something you tackle in one sitting. This order starts with what you can already add up today.
This week — put your own approval letters side by side
- Gather every grant decision from the last three fiscal years and find the sentence on each one referencing "de minimis aid" or "Regulation (EU) 2023/2831" — not every form of public support falls under it, but most smaller premiums do.
- Enter the amounts from those letters into the calculator above, including the aid equivalent of any favourable loan or guarantee where it's stated.
- Read the "room before this application" tile — is it closer to the full €300,000, or closer to zero?
- Note whether your business is part of a larger structure with other locations under the same owner — those count toward the same ceiling.
This month — check in with whoever is paying the money out
- For every application in progress or planned, contact the granting body directly and ask explicitly whether it's treated as de minimis aid and what the exact aid equivalent is.
- Ask your accountant whether they're already tracking your grant history separately from ordinary bookkeeping — most accounting software doesn't surface it as one added-up figure automatically.
- If you're close to the ceiling, ask explicitly whether a planned grant could run under a separate, individually approved scheme instead of de minimis aid.
- Revisit the point about the real cost of "free money": many investment grants only cover part of the cost, and the rest has to come from your own financing plan.
This quarter — plan new applications with the ceiling in mind
- Rerun the calculator before every new grant application, not after — the three-fiscal-year window keeps moving, so a number from today is out of date again in six months.
- Read this guide alongside our guide to restaurant financing — a grant is one source of capital next to a loan, own equity and investors, never the only one.
- Build expected grant income into your business plan as conditional, not certain — an application that breaches the ceiling gets rejected or clawed back.
- Before a major energy investment, check our guide on cutting energy costs first: a smaller, cheaper fix often needs less aid, and leaves more room under the ceiling.
The number nobody adds up for you
No single agency funding you is responsible for adding up what the other three already granted — until today, that has always been your own responsibility, usually without anyone ever telling you it existed. The register that went live this year changes that partly, but it doesn't replace your own records: it's a cross-checking tool for governments, not a service that shows you your own balance.
The good news is that the ceiling itself, €300,000 across three rolling fiscal years, is comfortable enough for most of the smaller grants an independent business normally applies for — the problem only shows up when several larger awards land inside the same window at once, like an investment grant for a renovation in the exact year that energy compensation and a hiring premium were also running.
So build the habit, not just the one-off add-up: every time you're considering a new grant, open this calculator first with your most recent numbers. It takes two minutes, and those two minutes are the difference between an award you get to keep and one you have to repay years later.