Minimal Financial Assistance guidance for companies

The Subsidy Control Act 2022 provides for a mechanism called Minimal Financial Assistance (MFA) to allow authorities to provide grants that are considered small enough to support individual business without giving them an unfair advantage.

If a subsidy is being provided under this mechanism, it will be described as a “Minimal Financial Assistance Subsidy”.

Minimal Financial Assistance can be provided in a number of different ways, including:

• A grant (this is the most common way to deliver MFA)
• A loan
• A guarantee
• A free or subsidised service
• Rates relief from local authorities
• Investment schemes run by HMRC

If you’ve received UK public sector support in the past, your award letters or other documentation should confirm if any of the funding constituted Minimal Financial Assistance.

You should have received a Minimal Financial Assistance notification, and a Minimal Financial Assistance confirmation detailing the amount and date of the funding.

If you’re not sure whether you’ve already received Minimal Financial Assistance, you should check your previous award letters and related documents from UK public sector bodies.

You only need to check the awards you’ve received in the current and previous two fiscal years. A fiscal year is a 12 month period beginning 1 April and ending 31 March.

So, at the moment, this means we are asking you to provide details of support received from 1 April 2020, irrespective of when your own company financial year starts and ends.

Prior to Brexit, some public funding came in the form of de minimis state aid, a mechanism designed for small amounts of funding.

If you received UK public sector support before 4 January 2023, you should have been told in your award letters or other documentation if any of the funding was de minimis funding.

The Subsidy Control Act 2022 considers Minimal Financial Assistance to include any awards made as de minimis under the European state aid regulations, or under the Trade and Cooperation Agreement from 1 January 2021.

This means that you must tell us about any award received as de minimis through any instrument, as it will count towards your total amount of Minimal Financial Assistance received.

De minimis awards under the Trade and Cooperation Agreement may sometimes be referred to by other agencies as “small amounts of financial assistance”. You only need to check the awards you’ve received in the current and previous two fiscal years.

Any subsidy or state aid given under other schemes that don’t count as de minimis (which includes any funding provided under the Temporary Framework during the coronavirus pandemic) won’t count towards your MFA total.

Read more about de minimus subsidy guidance 

We need to ask you about Minimal Financial Assistance you’ve already received to make sure any additional subsidy we give you won’t take you over the Minimal Financial Assistance limit that applies to your company.

We ask you to provide us with details in your application form. If we are considering granting funding using this mechanism, you will be provided with an offer of grant.

The offer will be conditional upon you providing us with a Minimal Financial Assistance Notification confirming that the amount of grant we are offering will not take you over the limit.

Minimal Financial Assistance is just one type of subsidy we can use. If you’ve already reached your limit or have applied for a grant that exceeds the limit, we’ll aim to use other types of subsidy funding where possible.

A company or corporate group can only receive up to £315,000 over the current and previous two fiscal years in the UK.

This limit applies to an enterprise, which is either an individual company or entity, or a group of bodies/bodies corporate under common ownership or control. This means that these limits may apply to the whole group rather than to individual companies.

If you’re part of a group or company structure that’s considered a enterprise, then any Minimal Financial Assistance received by other companies within that enterprise could count towards your limit.

An enterprise is defined in the Subsidy Control Act 2022 as a person (for example, an individual, body corporate, partnership or unincorporated association) or a group of persons under common ownership or common control engaged in an economic activity that entails offering goods or services on a market, to the extent that they are engaged in such an activity.

A group of persons is not automatically considered to constitute an enterprise just because one is a shareholder in the other.

A group of persons is considered to be under common control if they are:

• Interconnected – bodies corporate will be considered interconnected if one is a subsidiary of the other, or both are subsidiaries of the same parent company
• Have the same person/group in control – that person must be able to control or materially influence the policy of the bodies corporate carrying on an economic activity, even if they lack a controlling interest in those bodies corporate

The limit on Minimal Financial Assistance applies to the enterprise as a whole. This means the companies linked by one of the mechanisms above can’t receive separate allocations of Minimal Financial Assistance, even if they are legally separate companies with individual company registration numbers.

Minimal Financial Assistance won’t be relevant to all funding we offer. If it is relevant, we’ll ask you for some details during your application.

You’ll need to tell us about any Minimal Financial Assistance or de minimis received in the current or previous two fiscal years by:

• Your company
• Any companies currently within your enterprise
• Any companies who were within your enterprise within the current or previous two fiscal years
• Any previous entities your company has been connected to in the current or previous two fiscal years. For example, if your company has been part of a merger or acquisition, or is the result of a company or group that’s split into two or more separate entities

You’ll need to tell us:

• The date of the award (the date on the award letter, not the date the funds were received)
• The amount awarded
• The type of de minimis awarded
• The public funder
• The company who received the funding

De minimis received under European State aid rules will still count towards your Minimal Financial Assistance total.

If we decide that Minimal Financial Assistance is a potential option for funding, you will be issued with a Minimal Financial Assistance notification as part of your grant offer letter.

This will require you to confirm that the proposed funding will not cause your enterprise to exceed its Minimal Financial Assistance limit.