Subsidy Control Information
What is a subsidy?
A subsidy is financial support from a public body, such as government or a publicly funded organisation, that gives an organisation an advantage it could not get through normal commercial arrangements.
Subsidies can take different forms, including grants, loans, guarantees, tax reliefs, or access to services or facilities on favourable terms.
Why are we asking about subsidy?
Some of the funding we provide may be classed as a subsidy under UK Subsidy Control rules. We need to make sure any funding we provide is awarded correctly and in line with legal requirements.
How do we assess subsidy?
As part of our assessment, we will determine whether the funding is classed as a subsidy under UK Subsidy Control rules.
If it is, we will award it either as:
- Minimal Financial Assistance (MFA), or
- A subsidy permitted under the Subsidy Control Act 2022 or an approved subsidy scheme.
If funding is awarded, we will tell you:
- whether it is a subsidy;
- the value of the subsidy; and
- the legal basis on which it has been awarded.
If subsidy is awarded under MFA
An organisation can receive up to £315,000 of Minimal Financial Assistance (MFA) during the current and the previous two financial years combined.
To check compliance, we may ask you to tell us about any relevant subsidies your organisation (or group, if applicable) has received during:
- the current financial year; and
- the previous two financial years.
For subsidy control purposes, a financial year runs from 1 April to 31 March.
Note: If your organisation is part of a Group, your previous relevant subsidy must be aggregated with the other members of the Group. Group = when one or more companies are owned or controlled (directly or indirectly) by a single parent company.
What subsidy should you include?
If you have previously received support from a public body, please check your funding agreements or offer letters to see if it was awarded as:
- De Minimis Aid (under EU State Aid rules);
- Small Amounts of Financial Assistance (SAFA) under the UK-EU Trade and Cooperation Agreement; or
- Minimal Financial Assistance (MFA) or SPEI Financial Assistance under the Subsidy Control Act 2022.
What does not need to be included?
You do not need to include support received through:
- Coronavirus Business Interruption Loan Scheme (CBILS);
- Coronavirus Large Business Interruption Loan Scheme (CLBILS);
- Recovery Loan Scheme (RLS) 1 and 2 (for loans offered before 30 June 2022); or
- Bounce Back Loan Scheme (BBLS) support awarded under the Temporary Framework.
However, BBLS support awarded under the de minimis rules should be included.
If the value of a subsidy was provided in euros (€), please convert it to pounds sterling (£) using €1 = £0.85.
If we ask for details of previous subsidy, please provide only the total amount of the subsidy types listed above that your organisation (or group, if applicable) has received during the current and previous two financial years. You do not need to include support received under other schemes or outside of this period.
What happens next?
To help avoid delays, we recommend that you start gathering this information now, so it is available if we request it later in the application process.
We’ll review the information you provide.
If your funding award is classed as a subsidy, we’ll confirm in the funding documents:
- Whether it is a subsidy;
- its value; and
- the legal basis on which it has been awarded.
If we award subsidy under MFA, we will ask you to sign a declaration confirming that the value of our proposed award, together with any relevant subsidy already received by your organisation (or group, if applicable) during the current and previous two financial years, does not exceed the £315,000 MFA limit.
Need help?
We understand that Subsidy Control can be unfamiliar terminology for many charities and social enterprises. If you’re unsure whether previous funding should be included, or you are concerned that you have already breached the £315,000 MFA limit, please contact your Relationship Manager (once you have submitted your application and it has been assigned to them) and they will be happy to help.