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RCM n.º 49/2024 stands up a dedicated aid window within the pre-existing Regime Contratual de Investimento (RCI) architecture, which operates as a project-by-project contractual negotiation between the applicant and the Portuguese state (co-represented by the Ministry of Economy and the Ministry of Finance). The window was explicitly time-boxed by the TCTF's sunset: the European Commission's TCTF framework (C(2023)1711 of 9 March 2023, extended by C(2024)1832 and C(2025)1247) allowed Member States to grant state aid for net-zero technologies and critical raw materials through 31 December 2025, provided aid decisions were notified and approved within that window.
Incentive structure: Cumulative grant equivalent (non-refundable subvention + zero-rate refundable contribution + IRC tax-credit equivalent) up to:
Açores, Madeira), or projects meeting strategic-priority thresholds
Scope (dual axis): 1. Green-transition equipment manufacturing: batteries (cells, modules, packs), solar PV panels, wind turbine nacelles/towers/blades, heat pumps, electrolysers (PEM + alkaline), CCUS equipment 2. Critical raw materials and key components feeding those value chains: lithium, cobalt, nickel, manganese, copper, REEs, graphite, anode active materials, cathode active materials, electrolyte salts, separator films — upstream through midstream to refined-chemical intermediate
Governance: Applications processed through AICEP Portugal Global (the Portuguese investment and trade promotion agency) under the RCI contractual framework. The inter-ministerial evaluation committee assesses strategic fit, job-creation commitments, and investment additionality.
as the domestic state-aid legal instrument for their funding commitments: (i) Savannah Resources Mina do Barroso (EUR 110M+ award confirmed Q4 2025 — Europe's largest hard-rock lithium project, 60 Mt at 1.0% Li₂O, 23 ktpa LiOH target); (ii) Lusorecursos Aguas Frias lithium (Norte region); (iii) Lifthium Energy Estarreja LiCO3/LiOH conversion refinery (feeds European cell-gigafactory pipelines); (iv) Bondalti Estarreja lithium-derivatives integration (sodium-sulphate + lithium-salt derivative chemistry).
projects needed to obtain formal RCI approval-decision before the TCTF window closed. This drove accelerated permitting and EIA processes for Barroso and the Estarreja cluster.
after RCM 49/2024), though the two frameworks operate in tandem: CRMA confers Strategic Project designation and accelerated permitting, while RCM 49/2024 provides the domestic state-aid financing vehicle. Portugal's four CRMA-strategic projects all sit inside the RCM 49/2024 scope.
State TCTF implementations, though Portugal's version emphasises upstream critical-minerals extraction and conversion (lithium refining, graphite) rather than Hungary's emphasis on downstream EV/battery cell assembly (CATL Debrecen).
will need to fill the aid-eligibility gap created by RCM 49/2024's 31 December 2025 sunset. Portugal has not yet (as of May 2026) published a successor RCM under successor EU state-aid frameworks — watch for NZIA-anchored implementing decree in H2 2026.
TCTF-sunset deadline and whether the Estarreja Lift One (Lifthium) award decision was also completed within the window.
frameworks to bridge the TCTF gap for projects that missed the 31 Dec 2025 sunset.
align with RCM 49/2024 incentive availability for winning bidders — relevant for Lusorecursos and Lifthium project timelines.