New “de minimis” aid register: Entry obligation from 2026

From January 1, 2026, aid granted in Germany under the De Minimis Regulations must be entered in a central aid register maintained by the European Commission. The aim of introducing this publicly accessible register is to create transparency and clarity in the granting of these aids and to ensure easy compliance with the de minimis thresholds. 

De minimis and agricultural de minimis regulations: thresholds and new obligations 

Under the De Minimis Regulation, a company may be granted aid of up to EUR 300,000.00 within three years without this having to be notified to and approved by the European Commission. For services of general economic interest (SGEI), the permissible threshold under the SGEI De Minimis Regulation is EUR 750,000.00. 

From January 1, 2026, de minimis aid granted in Germany in accordance with the above regulations must be entered by the granting authority (e.g., ministries or local authorities) in the European Commission's central aid register (known as the eAIR register). For aid granted on the basis of the Agricultural De Minimis Regulation (with a permissible threshold of up to EUR 50,000.00), the registration requirement applies from January 1, 2027.  

Content and scope of the entry 

The aid must be entered in the aid register within 20 working days of the aid being granted, i.e. the date on which entitlement to the aid arose (not the date of payment). Working days are Monday to Friday. Only Germany-wide public holidays are not considered working days. 

The following information must be entered in the aid register: 

• Details of the aid recipient 
• Amount of aid 
• Date of granting 
• Granting authority 
• Aid instrument (e.g., guarantee) 
• Economic sector concerned according to the NACE classification 

Local authorities, ministries, etc. should prepare for additional work 

After a three-year transition period, the aid register will replace the current practice, according to which beneficiary companies must submit de minimis declarations and aid granting authorities must issue de minimis certificates for beneficiary companies. 

Only after the three-year transition period has expired will the obligation for aid granting authorities to issue de minimis certificates cease to apply. The entry obligation therefore initially represents an additional task for aid granting authorities. They should promptly address the internal responsibilities and technical details required for entries in the aid register (EU login, user account for eAIR, etc.). 

Continuous monitoring by companies is essential 

Affected companies should carefully monitor their entries in the aid register from next year onwards in order to avoid unintentionally exceeding the de minimis threshold. Otherwise, they may face the recovery of aid, including interest. 

In the aid register, affiliated companies are likely to be recorded separately and not as a single entity, even though the de minimis thresholds apply to the group of companies (corporate group) and not to the individual companies. Continuous monitoring of aid received is therefore essential, not only but especially in the case of affiliated companies.