EU / Hungary — CISAF Cleantech Manufacturing Capacity Scheme SA.120705: EUR 4.1 billion state aid for batteries, solar, wind, electrolysers, heat pumps and CCUS

Mechanism

Hungary notified the Commission under Section 6.1 of the CISAF — the successor framework to the Temporary Crisis and Transition Framework (TCTF), which the Commission adopted on 25 June 2025 — of a €4.1 billion horizontal scheme to support strategic investments that add manufacturing capacity for clean technologies. Aid takes the form of grants and tax advantages, is open to companies across the entire Hungarian territory, and may be granted until 31 December 2030.

Eligible products are defined by reference to CISAF Annex II — the same net-zero technology list used across the CISAF cohort (batteries, solar PV, wind turbines, electrolysers, heat pumps, CCUS equipment, and their main specific components) — plus the production or recovery of related critical raw materials. The Commission found the scheme necessary, appropriate and proportionate under Article 107(3)(c) TFEU and approved it on this basis. The non-confidential decision text is to be published under case number SA.120705 in the DG COMP State Aid register.

At €4.1 billion this is the largest individual CISAF cleantech-manufacturing-capacity approval on record, exceeding Germany's SA.121215 (€3 billion, 2026-02-05) — reflecting Hungary's outsized industrial exposure to the EV-battery FDI wave rather than its economic size.

Downstream implications

• CISAF as the TCTF-to-CISAF bridge for Hungary's gigafactory cluster: This scheme is the

direct institutional successor to the 2023 Hungarian TCTF net-zero scheme (EUR 2.36bn, 2023-08-30-hungary-tctf-net-zero-state-aid-scheme), whose aid deadline expired 31 December 2025. SA.120705 extends and enlarges (2.36bn → 4.1bn) the horizontal state-aid architecture that has channelled CATL Debrecen, BYD Szeged, EVE Power Debrecen, Samsung SDI Göd, and Sunwoda Nyíregyháza gigafactory investment into Hungary — none of these individual projects has yet received a standalone SA.XXXXX case number, so this horizontal scheme remains the operative aid vehicle for the cluster.

• Largest CISAF cleantech tranche to date: The €4.1bn quantum is the largest single CISAF

Section 6.1 approval in the register (vs. Germany €3bn, Greece €400m, Luxembourg €500m, France — see the CISAF cohort table below), underscoring Hungary's position as the EU's largest per-capita recipient of Chinese and Korean battery-supply-chain FDI.

• China-EU industrial-policy interlock: Because Hungary's cleantech-manufacturing base is

disproportionately Chinese- and Korean-owned (CATL, BYD, EVE, Samsung SDI, SK On), an EU state-aid scheme of this scale effectively subsidises non-EU-headquartered battery manufacturers building EU-based capacity — a structural tension with the EU Foreign Subsidies Regulation's scrutiny of the same companies' non-EU state support.

• ETF exposure: ICLN and QCLN hold EU-listed cleantech manufacturers with Hungarian operating

or supply-chain exposure; FAN and TAN capture wind and solar manufacturers among CISAF Annex II eligible beneficiaries.

CISAF cohort (Section 6.1 cleantech-manufacturing approvals)

Open questions

• Will CATL Debrecen, BYD Szeged, or other named gigafactory projects receive individual

large-aid SA.XXXXX case numbers referencing SA.120705 as the enabling horizontal scheme?

• What is the interaction with Hungary's national investment-incentive instruments (Decree

81/2025 EKD amendment, Act L/2025 strategic-companies FDI screening) that already apply to the same gigafactory projects?

• Will the Commission publish the non-confidential SA.120705 decision text, and will it disclose

a beneficiary register or per-project aid ceilings?