09.07.2025

New EU State Aid Rules Make Clearer That Support Can be Used When Leasing

In June, The European Commission adopted a new State aid framework supporting the Clean Industrial Deal, to enable Member States to push forward the development of clean energy, industrial decarbonisation and clean technology. The new Clean Industrial State Aid Framework (CISAF) sets out how Member States can design State aid measures to support objectives related to the Clean Industrial Deal.

Leaseurope’s input to the earlier draft CISAF rules led to improvements including new specific references to the inclusion of state aid when leasing, and the removal of a requirement that could have excluded captive lessors.

In June 2025, The European Commission adopted a new State aid framework supporting the Clean Industrial Deal, to enable Member States to push forward the development of clean energy, industrial decarbonisation and clean technology. The new Clean Industrial State Aid Framework (CISAF) sets out how Member States can design State aid measures to support objectives related to the Clean Industrial Deal.

The CISAF builds on the experience with the Temporary Crisis and Transition Framework (TCTF) transition provisions which it replaces. CISAF applies as of 25 June 2025, and remains in force until 31 December 2030.

The framework aims to simplify State aid rules in five main areas:

  1. the roll-out of renewable energy and low-carbon fuels;
  2. temporary electricity price relief for energy-intensive users to ensure the transition to low-cost clean electricity;
  3. decarbonisation of existing production facilities;
  4. the development of clean tech manufacturing capacity in the EU, and;
  5. the de-risking of investments in clean energy, decarbonisation, clean tech, energy infrastructure projects and projects supporting the circular economy.

 

Building on its work on “Access to EU Funding for leasing”, Leaseurope had contributed to the Commission’s targeted consultation in April 2025. Leaseurope broadly supports incentives for investments to achieve the ambitions of the Clean Industrial Deal. Leasing has a key role to play in supporting businesses, particularly SMEs, to transition to become more sustainable. However, it is observed that too often State aid rules include unintended barriers to the use of leasing, which at the stage of national implementation can limit policy effectiveness.

Leaseurope’s calls for equal treatment of leasing services compared to other financial products to give recipients the choice to decide which instrument is more appropriate for them. Leaseurope’s main message is that the new EU State aid rules should be focused on asset usage rather than legal ownership. In addition, EU State aid rules or guidance should ensure that the specificities of leasing services are given proper consideration so that the legal provisions are applicable at national level and so that they work for businesses that choose to lease their assets.

The CISAF refers to leasing with regards to aid provided to “support demand for clean technology equipment in form of accelerated depreciation”. Eligible assets must be (i) new, (ii) used by the beneficiary for at least five years, (iii) depreciable, (iv) be purchased or leased under market conditions, and (v) be included in the assets of the beneficiary. There are changes in the CISAF published compared to the draft presented last spring, indicating that the Leaseurope specific feedback calling for the inclusion of leasing, in addition to purchase, and for the removal of the requirement “assets purchased from third parties unrelated to the buyer” was taken on board.

Leaseurope will keep monitoring the EU funding and state aid rules and raising awareness of the importance of leasing for a competitive and sustainable EU economy.

Leaseurope can help ensure that policies intended to support sustainable business investment are as effective as possible.