covid 19 coronavirus update: european commission state aid … · 2 days ago · 107(2)(b) tfeu)...

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© Allen & Overy LLP 2020 allenovery.com Covid–19 coronavirus update: European Commission State aid decisions Last updated 21/08/20 Under State aid rules, UK and EEA Member State governments may not generally provide selective assistance to businesses without prior approval from the European Commission (EC). This includes assistance in the form of government direct grants, interest and tax reliefs, loans, guarantees, forbearance of existing loan terms, export credit insurance and equity investment. If these measures are provided selectively and on terms that the market would not provide (eg to a borrower in financial difficulty), or that are not being provided on arm’s-length commercial terms, they qualify as State aid and require prior approval from the EC. Transactions involving unapproved State aid are unenforceable. If an entity participates in/is a beneficiary of a scheme that is subsequently found to have involved unapproved State aid, it may be required to repay that aid potentially affecting its credit risk and solvency. The EC has adopted a ‘Temporary Framework’ to give national governments greater flexibility under the State aid rules to support their economies during the Covid-19 outbreak. The Temporary Framework continues to require notification to and prior approval of specific aid measures by the EC. The EC has so far approved most Covid-19-related aid schemes very rapidly mostly in a matter of days. Once an aid scheme has received approval, the relevant government is free to support businesses within the scope of the scheme. For further information on the Temporary Framework, please see this note, our subsequent update, and the July edition of our monthly newsletter Antitrust in focus. The table below provides an overview of the State aid decisions adopted by the EC. Except where indicated otherwise, each of these decisions has been adopted under the Temporary Framework. The table will be updated regularly to track the situation as it evolves. For more information on the potential impact of Covid-19 on the State aid issues relevant to your business, please speak to your usual A&O antitrust contact.

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Page 1: Covid 19 coronavirus update: European Commission State aid … · 2 days ago · 107(2)(b) TFEU) State guarantee scheme supporting the insurance of domestic trade. All EUR10bn SA.56903

© Allen & Overy LLP 2020 allenovery.com

Covid–19 coronavirus update: European Commission State aid decisions Last updated 21/08/20

Under State aid rules, UK and EEA Member State governments may not generally provide selective assistance to businesses without prior approval from the

European Commission (EC). This includes assistance in the form of government direct grants, interest and tax reliefs, loans, guarantees, forbearance of existing

loan terms, export credit insurance and equity investment. If these measures are provided selectively and on terms that the market would not provide (eg to a

borrower in financial difficulty), or that are not being provided on arm’s-length commercial terms, they qualify as State aid and require prior approval from the EC.

Transactions involving unapproved State aid are unenforceable. If an entity participates in/is a beneficiary of a scheme that is subsequently found to have

involved unapproved State aid, it may be required to repay that aid – potentially affecting its credit risk and solvency.

The EC has adopted a ‘Temporary Framework’ to give national governments greater flexibility under the State aid rules to support their economies during the

Covid-19 outbreak. The Temporary Framework continues to require notification to and prior approval of specific aid measures by the EC. The EC has so far

approved most Covid-19-related aid schemes very rapidly – mostly in a matter of days. Once an aid scheme has received approval, the relevant government is

free to support businesses within the scope of the scheme. For further information on the Temporary Framework, please see this note, our subsequent update,

and the July edition of our monthly newsletter Antitrust in focus.

The table below provides an overview of the State aid decisions adopted by the EC. Except where indicated otherwise, each of these decisions has been

adopted under the Temporary Framework. The table will be updated regularly to track the situation as it evolves.

For more information on the potential impact of Covid-19 on the State aid issues relevant to your business, please speak to your usual A&O antitrust contact.

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Covid–19 coronavirus update: EC State aid decisions | August 2020

2 © Allen & Overy LLP 2020

Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Austria Liquidity scheme providing support in the form of direct grants, repayable advances, guarantees and subsidised loans.

All EUR15bn SA.56840 – COVID-19: Austrian liquidity assistance scheme (08.04.20)

Guarantee scheme for working capital loans.

SMEs EUR9bn SA.56981 – COVID-19: Austrian scheme for guarantees on bridge loans (17.04.20)

Regional aid schemes to support companies and to support investment in R&D, testing and production of Covid-19-relevant products.

All EUR84m SA.57148 (2020/N) – COVID-19: Support Measures by the States (Länder) of Carinthia, Upper Austria, Styria, Tyrol and Vienna under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (19.05.20)

Compensation in the form of direct grants for certain damages suffered as a result of the Covid-19 outbreak.

All EUR8bn SA.57291(2020/N) – COVID-19: Compensation Scheme: Directive for fixed cost subsidies (23.05.20) (adopted under Article 107(2)(b) TFEU)

Subordinated loan (convertible into a grant) for damages suffered due to the Covid-19 outbreak.

Airlines EUR150m SA.57539 – COVID-19: Aid to Austrian Airlines (06.07.20) – Press release

Aid measure to support to Covid-19-relevant research and development projects by micro biotech company Apeptico in the form of a direct grant of approx. EUR840,000.

Research and development relevant to the Covid-19 outbreak – Apeptico

EUR840,000 SA.57340 – COVID-19: Individual aid to Apeptico – Emergency Call for the research of COVID-19 (06.07.20) – Press release

Aid measure to support Covid-19-relevant research and development projects by micro biotech company

Research and development relevant to the

EUR1.2m SA.57345 – COVID-19: Individual aid to Panoptes – Emergency Call for the research of COVID-19 (06.07.20) – Press release

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© Allen & Overy LLP 2020 allenovery.com

Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Panoptes in the form of a direct grant of EUR1.2m.

Covid-19 outbreak – Panoptes

Scheme providing aid in the form of direct grants for liquidity support.

Non-profit sector EUR665m SA.57928 – Scheme supporting non-profit organisations and their related entities (06.08.20)

Belgium Guarantee scheme for working capital and investment loans to support companies active in the Flemish region.

Companies active in the Flemish region

EUR3bn SA.56919 – The COVID-19 – loan guarantee – Flemish Region (09.04.20)

Scheme deferring payment by Walloon airports of concession fees.

Walloon airports Unknown SA.56807 – COVID19: Mesures de soutien en faveur des aéroports wallons – Moratoire sur les redevances de concession (11.04.20)

Scheme to provide state guarantees on new short-term loans.

All EUR50bn SA.56819 – COVID-19 – Loan guarantee scheme in response to the COVID-19 crisis (11.04.20) (adopted under Article 107(3)(b) TFEU – Temporary Framework is not applicable to the measure)

Direct grants to support agricultural and aquaculture sectors in Brussel-Capital region.

Agriculture and aquaculture

EUR200,000 SA.57056 – COVID-19: Decision of the Brussels Capital Government relating to aid in the context of the Covid-19 health crisis for companies active in the primary production of agricultural products and in aquaculture for the food sector (24.04.20)

Direct grants to support Covid-19-related R&D.

Products relevant to the Covid-19 outbreak

EUR4m SA.57057 – R&D scheme of Brussels Capital Region "R&D Projects - Covid-19" under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (27.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Scheme providing loan guarantees. Companies active in the Walloon region

EUR530m SA.57083 – COVID-19: Guarantee scheme – Walloon Region (30.04.20)

Flemish scheme providing subordinated loans to start-ups, scale-ups and SMEs.

Flemish start-ups, scale-ups and SMEs

EUR250m SA.57132 – COVID-19: Flemish subordinated loan scheme for start-ups, scaleups and SMEs (05.05.20)

Scheme to support Covid-19-related R&D activities in Wallonia.

All EUR25m SA.57173 – Walloon scheme for Covid-19 relevant research and development (“Régime d’aides à la recherche”) (12.05.20)

State guarantees on loans - will be accessible to companies whose exports represent at least 30% of their annual turnover.

Exporting companies

EUR500m SA.57187 – Credendo Bridge Guarantee (14.05.20)

Measure in the form of a quota-share reinsurance of short-term credit and surety risks.

Trade credit and surety insurers

EUR903m SA.57188 – COVID-19: Reinsurance of short-term credit and surety risks (15.05.20) (adopted under Article 107(3)(b) - Temporary Framework is not applicable to the measure)

Scheme to support the production of Covid-19-relevant medical products, equipment, technologies and raw materials in the Flemish region.

Products relevant to the Covid-19 outbreak

EUR21m SA.57605 – COVID-19: Strategic transformation aid to undertakings in the Flemish region for investments in COVID-19 related products (19.06.20)

Scheme to support the social tourism sector in Flanders.

Tourism EUR6.35m SA.57797 – COVID-19: Support to the social tourism sector (09.07.20)

Scheme providing aid in the form of repayable advances for companies active in the Flemish events sector in

Events sector EUR50m SA.58081 - Besluit van de Vlaamse Regering tot instellen van een terugbetaalbaar voorschot ter ondersteuning van de opstart van de evenementensector (27.07.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

order to fund the restart of their activities.

Scheme providing aid in the form of direct grants.

Potato and floricultural sectors in Flanders

EUR35m SA.58014– Aid scheme to support potato growers and ornamental plant growers affected by COVID-19 (27.07.20)

Scheme providing aid in the form of an exemption from the annual contribution to the Federal Agency for the Safety of the Food Chain (AFSCA).

Horeca and retail food trade

EUR11m SA.58165 – COVID-19: Exemption from the payment of the annual fee due to the Agence Fédérale pour la Sécurité de la Chaîne Alimentaire (AFSCA) for 2020 (HORECA contribution) (05.08.20)

Bulgaria Guarantee scheme on existing or new loans to SMEs.

SMEs BGN500m (approx. EUR255m)

SA.56933 – Bulgaria – COVID-19: intermediated SME loan guarantee program (08.04.20)

Employment aid scheme allowing the Bulgarian authorities to finance 60% of wage costs.

Sectors most affected by the outbreak, such as retail, tourism, passenger transport, culture, sports activities, amusement and recreation activities

BGN1.5bn (approx. EUR770m)

SA.56905 – COVID-19- Employment scheme for preserving jobs in most affected sectors (14.04.20)

Scheme providing direct grants co-financed by the European Regional Development Fund.

SMEs BGN173m (approx. EUR88m)

SA.57283 – State aid in the form of direct grants under Operational Programme Innovation and Competitiveness 2014-2020 to support micro and small enterprises to

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

overcome the economic impact of the COVID-19 pandemic outbreak (12.05.20)

Scheme providing aid in the form of direct grants.

Subsequently amended.

Medium-sized undertakings

BGN200m (approx. EUR102m)

SA.57795 – State aid in the form of direct grants under Operational Programme Innovation and Competitiveness 2014-2020 to support medium-sized enterprises to overcome the economic impact of the COVID-19 pandemic outbreak (26.06.20)

Amendment: SA.57938 – Amendment of SA.57795 Bulgaria, State aid in the form of direct grants to support medium-sized enterprises to overcome the economic impact of the COVID-19 pandemic outbreak (possible increase of the individual amount per undertaking)c (09.07.20)

Scheme providing support in the form of grants.

Tour operators BGN55m (approx. EUR28m)

SA.58050 – COVID-19: State aid for tour operators (24.07.20)

Public support in the form of a deferral of payments of concession fees.

Airports – Burgas and Varna

EUR4.4m SA.58095 - COVID-19: concession fee deferral Burgas and Varna airports (14.08.20) – Press release

Croatia Guarantee scheme covering up to 50% of losses incurred on operating loans with a limited maturity and size.

Companies whose export activities represent 20% of yearly revenue

HRK6bn (approx. EUR790m)

SA.56877 – Portfolio insurance of liquidity loans for exporters under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (06.04.20)

Two schemes providing public support in the form of zero-interest loans and loans with subsidised interest rates, respectively.

All EUR1bn SA.56957 – COVID-19: Interest free loans scheme and subsidised loans scheme (09.04.20)

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© Allen & Overy LLP 2020 allenovery.com

Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Direct grant scheme to support fishery and the aquaculture sector.

Fishery and aquaculture

EUR4m SA.56998 – State aid in fisheries and aquaculture supporting the economy under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (17.04.20)

Scheme providing loan guarantees and subsidised loans.

SMEs EUR322m SA.57175 – COVID-19: Guarantee schemes and subsidised loans scheme (12.05.20)

Scheme providing support in the form of public guarantees on loans.

SMEs active in the field of culture and creative industries

EUR40m SA.57595 – Guarantee scheme on loans for undertakings active in the field of culture and creative industries (17.06.20)

Scheme providing support in the form of public guarantees on loans.

Maritime, transport, transport infrastructure, tourism and related sectors

EUR80m SA. 57711 – State aid Scheme to support the maritime, transport, transport infrastructure, tourism, and related sectors impacted by the COVID-19 outbreak (30.06.20)

Cyprus Deferral of VAT payment obligations until 10 November 2020.

All except sectors which continued to operate during the lockdown

EUR33m SA.57511 – COVID-19: Waiver of interests and penalties for late payment of VAT (10.06.20)

Scheme providing support in the form of direct grants.

Primary agricultural sector

EUR1.8m SA.57587 – Aid to agricultural sector (17.06.20) – Press release

Incentive scheme providing support in the form of direct grants in order to re-establish air routes from/to Cyprus.

Airlines EUR6.3m SA.57691 – Incentive scheme towards airlines (01.07.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Scheme in the form of direct grants to support newspaper companies.

Newspaper companies

EUR106,000 SA.57762 – Support scheme for newspapers (06.07.20)

Czech Republic

Scheme to support investments in the production of Covid-19-relevant products.

SMEs producing products relevant to the Covid-19 outbreak

CZK1bn (approx. EUR37m)

SA.56961 – Scheme for investment aid for the production of COVID-19 relevant products (14.04.20)

Guarantee scheme for loans to large exporting companies.

Large companies for which exports amount to at least 20% of revenues and their suppliers

CZK142bn (approx. EUR5.2bn)

SA.57094 – COVID-19 – Loan guarantee scheme to support the economy in response to the COVID-19 crisis (05.05.20)

Aid in the form of direct grants for Covid-19-relevant R&D projects.

All CZK200m (approx. EUR7.3m)

SA.57071 – COVID-19 – Support to R&D projects (07.05.20)

State guarantee scheme. SMEs CZK500bn (approx. EUR18.5bn)

SA.57195 (2020/N) – COVID-19: Aid in the form of guarantees on loans for enterprises of up to 500 employees (15.05.20)

Rent compensation scheme. Retail businesses and service companies renting premises

CZK5bn (approx. EUR184m)

SA.57464 (2020/N) – COVID-19: Program to support entrepreneurs affected by the spread of the COVID 19 (rent payments) (02.06.20)

Scheme providing direct grants intended to partially reduce the outstanding amounts of operating bank loans to these SMEs and will

SMEs in the primary agricultural sector

CZK1bn (approx. EUR36.3m)

SA.57475 – COVID-19: Opex 2020 – Loan Principal Reduction (03.06.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

cover up to 50% of the unpaid loan amount.

Wage subsidy scheme. All CZK22.9bn (approx. EUR886m)

SA.57102 – COVID-19 – Wage subsidies in Czechia (27.07.20)

Scheme providing aid in the form of direct payments to cover discounts applied to consumers from the EEA that reserve a minimum package of overnight stays and spa rehabilitation treatments at beneficiaries’ facilities.

Health spa facilities

CZK1bn (approx. EUR38m)

SA.58018 – COVID-19: Support for Health Spas (adopted under Article 107(3)(b) TFEU) - Temporary Framework is not applicable to the measure) (07.08.20) – Press release

Scheme providing aid in the form of direct grants.

Cultural events operators

CZK900m (approx. EUR34m)

SA.58213 - COVID-19: Aid to the cultural sector (19.08.20) – Press release

Denmark

Guarantee scheme for SMEs covering up to 70% of losses incurred on new operating loans.

SMEs DKK1bn (approx. EUR130m)

SA.56708 – Danish guarantee scheme for SMEs affected by COVID-19 (21.03.20)

Scheme to compensate damage caused by cancellations of large public events.

Events DKK91m (approx. EUR12m)

SA.56685 – Compensation scheme for cancellation of events related to COVID-19 (12.03.20) (adopted under Article 107(2)b TFEU)

Scheme to compensate self-employed for damage suffered due to the Covid-19 outbreak up to DKK23,000 (approx. EUR3,000) per month per person.

Self-employed DKK10bn (approx. EUR1.3bn)

SA.56791 – Temporary compensation scheme for self-employed financially affected by COVID-19 (25.03.20) (adopted under Article 107(2)b TFEU)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Prolongation and adjustment: SA.57199 – Amendment to State Aid SA.56791 (2020/N) on temporary wage-compensation scheme for self-employed financially affected by the COVID-19 (07.05.20)

Liquidity guarantee scheme for SMEs with a level of exports of at least 10% of their yearly revenue and their sub-suppliers.

SMEs with export activities

DKK1bn (approx. EUR130m)

SA.56808 – Liquidity guarantee scheme under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (30.03.20)

State loan with subsidised interest rates to the Danish Travel Guarantee Fund for travel cancellations.

Travel DKK1.5bn (approx. EUR200m)

SA.56856 – State loan for the Danish Travel Guarantee Fund as a result of COVID-19 (01.04.20)

Compensation for companies particularly affected by the Covid-19 outbreak up to DKK60m (approx. EUR8m) per company.

All DKK40bn (approx. EUR5.4bn)

SA.56774 – Compensation for companies particularly exposed to COVID-19 outbreak (08.04.20) Amendment: SA.57151 - Amendment and prolongation of compensation scheme SA.56774 for companies particularly exposed to COVID-19 outbreak (05.05.20)

Public guarantee to compensate airline SAS for damage caused by the Covid-19 outbreak.

Airlines - SAS DKK1bn(approx. EUR137m)

SA.56795 – Compensation for the damage caused by the COVID-19 outbreak to Scandinavian Airlines (15.04.20) (adopted under Article 107(2)b TFEU)

Scheme providing support in the form of tax deferrals and similar measures in relation to VAT and payroll tax liabilities.

SMEs EUR130m SA.57027 – Tax deferrals and similar measures (30.04.20)

Scheme providing loans to start-ups. Start-ups EUR296m SA.57164 – Loan scheme for early stage and companies in the venture segment (05.05.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Scheme to provide aid in the form of a first-loss guarantee on the portfolio of insurance claim exposures of participating trade credit insurers.

Trade credit insurance providers

Unknown SA.57112(2020/N) – COVID-19: First-loss portfolio guarantee on trade credit insurance (15.05.20) (adopted under Article 107(3)(b) - Temporary Framework is not applicable to the measure)

Scheme to compensate for damage caused by decrease in advertising revenues.

Media companies EUR32m SA.57106 – Compensation scheme for the Danish media sector related to COVID-19 (27.05.20)

Scheme to compensate travel operators up to 100% of losses suffered as a consequence of reimbursing consumers.

Travel operators EUR97m SA.57352 – COVID-19 compensation scheme to travel operators for losses incurred by cancellations (29.05.20) (adopted under Article 107(2)(b) TFEU)

Scheme to compensate self-employed for damage suffered due to the Covid-19 outbreak.

Self-employed EUR66.5m SA.57919 – COVID-19: Limited amounts of aid scheme for self-employed (13.07.20)

Scheme to compensate self-employed and freelancers related to large events and seasonal work for damage suffered due to the Covid-19 outbreak.

Self-employed and freelancers related to large events and seasonal work

EUR26.8m SA.57920 – COVID-19: Limited amounts of aid scheme for self-employed and freelancers related to large events and seasonal work (13.07.20)

Scheme to compensate for damages suffered by companies whose activities are still subject to restrictive measures implemented due to the Covid-19 outbreak.

Various EUR148m SA.57930 – Temporary targeted compensation scheme for companies affected by COVID-19 prohibitions (bans and cancelled events) (13.07.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Compensation scheme for undertakings affected by travel restrictions and closure of borders.

All EUR148m SA.57932 – Covid-19 :Temporary targeted compensation scheme for undertakings affected by closure of borders and travel restrictions (adopted under Article 107(2)(b) TFEU) (22.07.20)

Recapitalisation measure by Denmark and Sweden comprising of an equity participation through subscription of new shares, the subscription and underwriting of new shares in a rights issue and newly issued State hybrid notes.

Airlines - SAS EUR1bn SA.57543 – COVID19 recapitalisation of SAS (17.08.20) – Press release

Estonia

Support scheme implemented by the public Foundation Kredex for the provision of public guarantees on existing or new loans and the granting of loans at favourable terms.

All (except agriculture, tobacco, cloning and genetic modification)

EUR1.75bn (for both schemes combined)

SA.56804 – Loan guarantee scheme of Estonia under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (30.03.20)

Support scheme implemented by the public Rural Development Foundation for the provision of public guarantees on existing or new loans and the granting of loans at favourable terms.

Agriculture, fisheries, food processing and undertakings in rural areas

EUR1.75bn (for both schemes combined)

SA.56804 – Loan guarantee scheme of Estonia under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (30.03.20)

Eight schemes providing support in the form of direct grants and payment advantages to companies active in certain sectors affected by the Covid-19 outbreak.

Various EUR75.5m SA.57014 – Estonian aid schemes in the form of grants and payment advantages under Section 3.1 of Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (21.04.20) Amendment: SA.57234 – COVID-19: Amendment to SA.57014 (2020/N) – Estonian aid schemes in the form of

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

grants and payment advantages under Section 3.1 of the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (07.05.20)

Scheme implemented and administered by the public Foundation KredEx providing support in the form of public guarantees, loans and subsidised interest rates for loans.

All EUR1.55bn SA.57028 – Estonian aid schemes in the form of guarantees on loans, loans and subsidised interest rates for loans under Section 3.1 of the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (28.04.20)

Scheme implemented and administered by the public Rural Development Foundation providing liquidity through public guarantees and loans.

Agriculture, fishery, food processing and companies in rural areas

EUR200m SA.57028 – Estonian aid schemes in the form of guarantees on loans, loans and subsidised interest rates for loans under Section 3.1 of the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (28.04.20)

Rent compensation scheme to support business renting premises in shopping centres.

Businesses located in shopping centres

EUR4m SA.57403 – COVID-19: Support for rent payments for trade and service operators negatively affected by the coronavirus outbreak (28.05.20)

Support scheme for companies active in international maritime passenger transport.

International maritime passenger transport

EUR20m SA.57643 – COVID-19: Aid to companies active in international maritime passenger transport (10.07.20)

Aid measure to provide a share capital increase and subsidised interest loan.

Airlines - Nordica EUR30m SA.57586 – Estonia COVID19 - Recapitalisation of Nordica (11.08.20) – Press release

Finland Scheme providing support in the form of: (i) state guarantees on new investment and working capital loans;

All EUR2bn SA.57059 – COVID-19: Loan guarantee and subsidised interest rate loan scheme for undertakings most affected by COVID-19 (20.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

or (ii) subsidised investment and working capital loans with favourable interest rates.

Scheme providing support in the form of direct grants, equity injections, selective tax advantages and advance payments, as well as repayable advances, State guarantees and loans.

All EUR3bn SA.56995 – COVID-19: Framework Scheme for State aid measures (Section 3.1 of the Temporary Framework) (24.04.20)

Scheme providing direct grants to cover immediate liquidity needs.

Primary agricultural production

EUR30m SA.57231 – COVID-19: Temporary aid to undertakings in primary agricultural production (06.05.20)

Scheme providing direct grants to cover immediate liquidity needs.

Fishery and aquaculture

EUR10m SA.57221 – Temporary aid in favour of undertakings in the fishery and aquaculture sector affected by the Covid-19 outbreak (06.05.20)

90% state guarantee on EUR600m loan to Finnair.

Airlines - Finnair Unknown SA.56809 – COVID-19: State loan guarantee for Finnair (18.05.20)

Loan guarantee scheme. Maritime enterprises

EUR600m SA. 57192 (2020/N) – Loan guarantee scheme for maritime enterprises under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (28.05.20)

Scheme to compensate loss of revenues during the two-month period of lockdown.

Restaurants, bars or cafes

EUR120m SA.57284 (2020/N) – COVID-19: Finnish damage compensation scheme for restaurants (28.05.20) (adopted under Article 102(b) TFEU)

Recapitalisation measure through which the State will receive rights to

Airlines – Finnair EUR286m SA.57410 – COVID-19: recapitalisation of Finnair (10.06.20) – Press release

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Jurisdiction State aid measure Sector/specified beneficiary

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subscribe for new shares in an amount of EUR286m.

France Scheme enabling French public investment bank Bpifrance to provide State guarantees on commercial loans.

Enterprises with up to 5,000 employees

EUR300bn (for the three guarantee schemes combined)

SA.56709 - COVID-19: Plan de sécurisation du financement des entreprises (21.03.20)

Scheme enabling French public investment bank Bpifrance to provide State guarantees on credit lines.

Enterprises with up to 5,000 employees

EUR300bn (for the three guarantee schemes combined)

SA.56709 – COVID-19: Plan de sécurisation du financement des entreprises (21.03.20)

Scheme to provide State guarantees to banks on portfolios of new loans for all types of companies.

All EUR300bn (for the three guarantee schemes combined)

SA.56709 – COVID-19: Plan de sécurisation du financement des entreprises (21.03.20)

Amendment: SA.57502 – Amendement de la décision SA.56709 (2020/N) – France – COVID-19: Plan de sécurisation du financement des entreprises (04.06.20)

Amendment: SA.57989 – Amendement de la décision SA.56709 – COVID-19: Plan de sécurisation du financement des entreprises (28.07.20)

"Fonds de solidarité" scheme providing direct grants for small and micro-enterprises and self-employed in temporary financial difficulties.

Small and micro-enterprises and self-employed

EUR1.7bn (March 2020), EUR2.9bn (April 2020)

SA.56823 – COVID 19 - French Solidarity Fund - Scheme for enterprises in temporary difficulties due to COVID-19 (30.03.20)

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Subsequently prolonged and modified.

Amendment: SA.57010 - Prolongation et modification des modalités d’intervention du Fonds de solidarité à destination des entreprises particulièrement touchées par les conséquences économiques, financières et sociales de la propagation de l’épidémie COVID-19 et des mesures prises pour limiter cette propagation. (15.04.20)

French scheme deferring payment by airlines of certain aeronautical taxes.

Airlines Unknown

SA.56765 – CODIV-19 Moratoire sur le paiement de taxes et redevances aéronautiques en faveur des entreprises de transport public aérien (31.03.20) (adopted under Article 107(2)(b) TFEU)

State guarantee scheme supporting the insurance of domestic trade.

All EUR10bn SA.56903 – COVID-19: State guarantee for the reinsurance cover of domestic trade credit insurance risks (12.04.20) (adopted under Article 107(3)(b) – Temporary Framework is not applicable to the measure)

Umbrella scheme allowing for the provision of aid in the form of: (i) direct grants, equity injections, repayable advances and subsidised loans up to an amount of EUR800,000; (ii) state guarantees for loans; (iii) public loans with favourable interest rates.

All EUR7bn SA.56985 – Régime cadre temporaire au soutien des entreprises dans la crise du Covid 19 (20.04.20)

Scheme providing guarantees on loans for exporting companies.

SMEs with export activities

EUR4m SA.56868 – COVID-19: Garanties des préfinancements des entreprises françaises exportatrices (24.04.20)

Loan guarantee to the Renault group providing 90% loan coverage.

Automotive - Renault

EUR5bn SA.57134 – COVID 19 : Aide sous forme de garanties de prêts au profit du groupe Renault (29.04.20)

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State guarantee and shareholder loan to Air France to provide urgent liquidity.

Airlines – Air France

EUR7bn SA.57082 – COVID-19: Cadre temporaire 107(3)(b) – Garantie et prêt d’actionnaire au bénéfice d’Air France (04.05.20) – Press release

Scheme providing state guarantees. SMEs with export activities

EUR3m SA.57219 – COVID-19: Garanties des cautions (11.05.20) (adopted under Article 107(3)(b) – Temporary Framework is not applicable to the measure)

90% state guarantee for a EUR71m loan to the NOVARES group.

Automotive - NOVARES

EUR64m SA.57405 - Covid-19 - Groupe Novares (26.05.20)

Umbrella scheme to support R&D, construction and testing infrastructures and investment in production of Covid-19-relevant products

Products relevant to the Covid-19 outbreak

EUR5bn SA.57367 – COVID-19: Aid for COVID-19 relevant R&D projects, investment into relevant testing and upscaling infrastructures, and investment into COVID-19 relevant production capacities (05.06.20)

Scheme providing aid in the form of wage subsidies for employees.

Catering, restauration, hotel and accommodation industry, tourism,

passenger transport, event organisation, production of films, videos and

television programmes, arts, culture and sports

EUR207m SA.57754 – COVID-19: Dispositif d'activité partielle ad hoc (29.06.20)

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Subordinated loan scheme. All EUR30bn SA.57695 – COVID-19: Régime d'aides sous la forme de prêts publics subordonnés (30.06.20)

Germany Subsidised loan programme implemented through the Kreditanstalt für Wiederaufbau (KfW) covering up to 90% of risk for loans up to EUR1bn with a maturity of up to 5 years.

All Unknown SA.56714 – COVID-19 measures (22.03.20)

Subsidised loan programme in which KfW participates together with private banks to provide larger loans as a consortium.

All Unknown SA.56714 – COVID-19 measures (22.03.20)

Scheme for guarantees on loans. All Unknown SA.56787 – COVID-19: Bundesregelung Bürgschaften 2020 (24.03.20)

Scheme "Bundesregelung Kleinbeihilfen 2020", providing direct grants, repayable advance or tax and payment advantages. This scheme was subsequently amended to also allow for aid in the form of loans, guarantees and equity.

All Unknown SA.56790 – Federal Framework "Small amounts of aid 2020" - COVID-19 (24.03.20) Amendment: SA.56974 - Amendment to the approved schemes SA.56790 (2020/N) – Federal Framework “Small amounts of aid 2020” (“Bundesregelung Kleinbeihilfen 2020”) and SA.56863 (2020/N) Federal Framework for subsidised loans 2020 “Bundesregelung Darlehen 2020” (11.04.20)

Subsidised loan scheme to be provided by other regional authorities and promotional banks (extension of KfW scheme).

All Unknown SA.56863 – COVID-19 - Federal framework for subsidised loans 2020 (02.04.20) Amendment: SA.56974 – Amendment to the approved schemes SA.56790 (2020/N) – Federal Framework “Small

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This scheme was subsequently amended to allow for subsidised interest rates for loans provided either directly by a granting authority together with private banks in a consortium or indirectly in the form of risk-sub-participations.

amounts of aid 2020” (“Bundesregelung Kleinbeihilfen 2020”) and SA.56863 (2020/N) Federal Framework for subsidised loans 2020 “Bundesregelung Darlehen 2020” (11.04.20)

Guarantee scheme to support the trade credit insurance market.

All EUR30bn SA.56941 – COVID-19: First-loss portfolio guarantee on trade credit insurance (adopted under Article 107(3)(b) – Temporary Framework is not applicable to the measure) (14.04.20)

Umbrella scheme to support R&D, testing and production of Covid-19-relevant products.

Products relevant to the Covid-19 outbreak

EUR5bn SA.57100 – COVID-19 – Federal Framework Scheme “Aid for Covid-19 related R&D, investments in testing infrastructures and production facilities” (“Bundesregelung Forschungs-, Entwicklungs- und Investitionsbeihilfen”) (28.04.20)

State-guaranteed public loan granted via KfW.

Airlines – Condor EUR550m SA.56867 – COVID 19 – Support for Condor (26.04.20) (adopted under Article 107(2)(b) TFEU) – Press release

Recapitalisation measure comprising: (i) equity participation through the subscription of new shares by the State, corresponding to 20% of share capital; (ii) silent participation with the features of a non-convertible equity instrument; and (iii) silent participation with the features of a convertible debt instrument.

Airlines – Lufthansa

EUR6bn SA.57153 – COVID-19: Aid to Lufthansa (25.06.20) – Press release

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Measures (liquidity and capital support) of the newly set up Wirtschaftsstabilisierungsfonds (Economic Stabilization Fund) to remedy a serious disturbance in the economy.

All EUR500bn SA.56814 – COVID-19: Measures of the Wirtschaftsstabilisierungsfonds (08.07.20) – Press release

Guarantee scheme to cover vouchers issued by travel operators for cancelled travel packages prior to 8 March 2020.

Tour operators EUR840m SA.57741 - Aid in the form of guarantees on vouchers issued for package tours (adopted under Article 107(2)(b) TFEU) (31.07.20)

Scheme providing aid in the form of direct grants to compensate public transport companies.

Public transport EUR6bn SA.57675 – COVID-19 - scheme for regional and local public passenger transport (adopted under Article 107(2)(b) TFEU) (07.08.20)

Scheme compensation for revenue losses in the form of direct grants and liquidity support in the form of grants, loan guarantees, subsidised interest rates and tax deferrals.

Airports Unknown SA.57644 – Covid 19 - German airport scheme (partly adopted under Article 107(2)(b) TFEU) (11.08.20)

Aid in the form of a fund providing liquidity and capital support to enterprises in Bavaria, in the form of (i) guarantees; (ii) subordinated loans; (iii) recapitalisation instruments and hybrid capital instruments.

Medium sized enterprises

EUR46bn SA.57447 - COVID-19 measures of the BayernFonds (20.08.20) – Press release

Greece Scheme providing guarantees on loans implemented by the Hellenic

All EUR2.25bn SA.56857 – COVID-19: Capped business loans portfolio guarantees for new working capital loans in the current COVID-19 outbreak (03.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

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Development Bank and co-financed by EU structural funds. Modified to increase budget and extend scope to subsidise guarantee premiums for loans.

Amendment: SA.57048 – Amendment of the Capped Business Loan's Portfolio Guarantees for New Working Capital Loans for the period until 31 December 2020 (30.04.20)

Scheme providing repayable advances to companies having temporary financial difficulties.

Modified to increase budget and extend scope.

All EUR2bn SA.56815 – Greek COVID-19 measure – Repayable Advance Scheme (RAS) for enterprises affected by the COVID-19 outbreak (07.04.20)

Amendment: SA.58047 - COVID-19 - Amendment to SA.56815 Repayable Advance Scheme (31.07.20)

Scheme providing repayable advances.

SMEs EUR1.2bn SA.56839 - Greek COVID measure: support to SMEs loan obligations (08.04.20)

Scheme providing support in the form of direct grants.

Floriculture primary production sector

EUR10m SA.57194 – COVID-19: Aid in the form of direct grants in the floriculture sector under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (05.05.20)

Scheme providing aid in the form of direct grants as compensation to self-employed.

Self-employed EUR500m SA.57165 – Wage subsidies to self-employed under the Temporary Framework to support the economy in the current COVID-19 outbreak (11.05.20)

Various schemes providing grants to support companies active in agricultural and related markets.

Primary agriculture, producers, open air market sellers and livestock

EUR51m SA. 58029 - COVID-19: ‘State aid support to primary sector farmers, producers and open air markets’ sellers under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak’, SA. 58048 - COVID-19: ‘State aid support to the sheep and goat farming primary sector under the Temporary Framework for State aid

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measures to support the economy in the current COVID-19 outbreak’ and SA. 58069 - ‘State aid support to the asparagus primary production sector the under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak’ (23.07.20)

Hungary Scheme providing support in the form of direct grants adjusted to the volume of the investment made by the beneficiary.

Medium and large enterprises active in defined sectors

EUR140m SA.56926 – Aid measures for increasing competitiveness of undertakings in relation with the COVID-19 outbreak (08.04.20)

Scheme financed from EU Structural Funds to support companies in temporary financial difficulties.

All EUR1bn SA.56994 – Scheme financed from Structural Funds for enterprises in temporary financial difficulties due to the COVID-19 (17.04.20)

Wage subsidies support scheme for researchers and developers in all affected sectors.

All EUR88m SA.57007 – COVID-19 - Employment scheme for supporting the employment of researchers and developers in all sectors affected by coronavirus outbreak (17.04.20)

Scheme providing support through guarantees issued by: (i) the semi State-owned Garantiqa Credit Guarantee Company Ltd. on loans up to EUR14m; and (ii) the State-owned MFB Ltd. on loans up to EUR28m.

All EUR1.5bn SA.57121 – Loan guarantee scheme under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (28.04.20)

Support in the form of (i) direct grants; (ii) guarantees on loans, and (iii) subsidised interests for loans.

All EUR900m SA.57064 – COVID-19: Grants, guarantee and subsidised interest measures (29.04.20)

Scheme providing aid in the form of guarantees on loans administered by

SMEs in the agri-food value chain

Unknown SA.57198 (2020/N) – COVID-19: Crisis Rural Guarantee Programme by AHVGA (07.05.20)

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the Rural Credit Guarantee Foundation.

Scheme providing aid in the form of grants.

Agri-food, aquaculture and forestry

EUR99m SA.57329 (2020/N) – COVID-19: Temporary aid scheme for the agri-food sector, aquaculture and forestry affected by the coronavirus outbreak (19.05.20)

Scheme providing support in the form of equity injections and convertible loans of up to EUR800,000.

All EUR156m SA.57269 – COVID-19: CAPITAL FUNDS (20.05.20)

Support in the form of direct grants intended to cover part of financial costs (interests and handling fees) in raltion to loans taken out under a number of loan programmes.

SMEs EUR60m SA.57285 – COVID-19: Grant Scheme Related To The Széchenyi Card Programme (20.05.20)

Amendment: SA.58288 - Amendment of the scheme SA.57285 (2020/N) as amended by SA.58065 (2020/N) concerning COVID-19: Grant Scheme related to the Széchenyi Card Programme (13.08.20)

Umbrella scheme providing aid under certain existing schemes in the form of direct grants to cover investments aimed at preserving jobs or creating new job opportunities.

All EUR155m SA.57468 – COVID-19: Umbrella scheme of direct grants provided from the appropriations managed at the level of ministries’ budgetary chapters (09.06.20)

Scheme to compensate large companies for damages suffered due to the Covid-19 outbreak.

Large enterprises EUR145m SA.57375 – COVID-19 Compensation scheme related to the recovery of the Hungarian economy (23.06.20) (adopted under Article 107(2)(b) TFEU)

Scheme to provide aid in the form of direct grants.

Products relevant to the Covid-19 outbreak

EUR143m SA.58202 - COVID-19 related research, development and production support scheme (10.08.20)

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Ireland Scheme providing repayable advances to companies experiencing a decline in turnover of at least 15%.

Certain manufacturing sectors and/or internationally traded sectors

EUR200m SA.56845 – Repayable Advances Scheme - COVID-19 (31.03.20)

Scheme providing support in the form of direct grants, repayable advances, equity injections and subsidised loans.

All EUR200m SA.57036 – Sustaining Enterprise Scheme supporting undertakings affected by the economic repercussions of the COVID-19 outbreak (21.04.20)

Scheme to provide support in the form of direct grants equivalent to the company’s local commercial property tax for the year 2019.

SMEs EUR250m SA.57509 – COVID-19 - Irish Restart Grant (03.06.20)

Scheme to support R&D, testing and production of Covid-19-relevant products.

Products relevant to the Covid-19 outbreak

EUR200m SA.57453 – Scheme to facilitate COVID-19 relevant research and development, to support construction and upgrade of testing and upscaling facilities of COVID-19 relevant products and to support investments into the production of COVID-19 relevant products (03.06.20)

Scheme providing support in form of direct grants to cover costs of adapting businesses to the requirements for re-opening.

Tourism and hospitality

EUR26m SA.58214 – COVID 19 Adaptation Fund for the Re-Opening of Tourism and Hospitality businesses (14.08.20) – Press release

Scheme providing guarantees on new loans provided by financial intermediaries.

Companies with up to 499 employees

EUR2bn SA.57465 - COVID-19: Credit Guarantee Scheme (14.08.20)

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Italy Direct grant to support production of medical equipment and masks.

Production and supply of medical devices and personal protection equipment

EUR50m SA.56786 – Production of medical equipment and masks (22.03.20)

State guarantee scheme supporting a debt moratorium for SMEs.

SMEs SA.56690 – State guarantee to support debt moratorium by banks to SME borrowers (25.03.20)

State-owned 'Guarantee Fund' for SMEs granting support through financial institutions in the form of: (i) state guarantees on investment and working capital loans; and (ii) direct grants in the form of waiving the applicable fee on the guarantees awarded.

Modified to increase budget and increase maximum maturity of fully guaranteed loans.

Self-employed workers and companies with up to 499 employees

EUR25bn SA.56966 – COVID-19: Loan guarantee schemes under the Fondo di garanzia per le PMI (13.04.20)

Amendment: SA.57625 – Fondo di garanzia per le PMI (17.06.20)

Guarantee scheme for new working capital and investment loans granted by banks.

All EUR200bn SA.56963 – Guarantee scheme under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (13.04.20)

Scheme providing state guarantees on investment and capital loans and direct grants in the form of waiving of

SMEs in the agriculture, forestry, fishery

EUR100m SA.57068 – Loan guarantees and grants under the ISMEA Guarantee Fund according to the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (21.04.20)

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the applicable fee on guarantees awarded.

and aquaculture sectors

Scheme providing interest-free loans granted directly by ISMEA (Istituto di Servizi per il Mercato Agricolo alimentare).

SMEs in agriculture, fishery and aquaculture

EUR30m SA.57185 – COVID-19: Loans provided by ISMEA in favour of undertakings of the agricultural and fishery sector affected by the COVID-19 outbreak (04.05.20)

Scheme providing aid in the form of direct grants.

Agriculture, fishery, acquaculture, buffalo livestock and floriculture

EUR70m SA.57349(2020/N) – COVID-19: Plan for the socio-economic emergency in the Campania region – Aid measures in favour of undertakings in the agricultural sector, in the fishery and aquaculture sector, in the buffalo livestock sector and in the floriculture sector (19.05.20)

Umbrella scheme providing support in the form of: (i) direct grants, guarantees and subsidised interest rates; (ii) aid for Covid-19-related R&D, production and testing; and (iii) wage subsidies.

All EUR9bn SA.57021 (2020/N, ex 2020/PN) – COVID-19: Regime Quadro (21.05.20)

Scheme providing liquidity support in the form of direct grants.

Agriculture EUR12m SA.57439(2020/N) – COVID-19: Interests on the anticipation of the amounts payable to farmers in the framework of the CAP support schemes (28.05.20)

Aid schemes waiving certain taxes for an providing tax credits to companies and self-employed workers.

All EUR7.6bn SA.57429 – Tax exemptions and tax credits adopted as a consequence of the economic crisis caused by COVID-19 (26.06.20)

Grant scheme to support small businesses and self-employed affected by the Covid-19 outbreak.

Small businesses and self-employed

EUR6.2bn SA.57752 – COVID-19: Italy - Grants to small businesses and self-employed (08.07.20)

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Schemes providing incentives to the recapitalisation by private investors of SMEs.

SMEs EUR6bn SA.57289 – COVID-19: Capital-strengthening measures for medium-sized companies (31.07.20)

Scheme providing direct grants to support internationally active companies.

Internationally active companies

EUR300m SA.57891 - Direct grants to Italian companies engaging in international activities and operations (31.07.20)

Guarantee scheme for the reinsurance of trade credit risks.

All EUR2bn SA.57937 – Covid-19 – Guarantee on portfolio of trade credits (adopted under Article 107(3)(b) TFEU) - Temporary Framework is not applicable to the measure) (13.08.20) – Press release

Scheme providing support in the form of 100% free State guarantees on loans with subsidised interest rates.

Sports associations

EUR1.6m SA.58208 - Aid in the form of guarantees on loans and subsidised interest rates managed by the “Istituto per il Credito Sportivo” as provided by Article 14, Para 1 and 2 of Law Decree of 8 April 2020, no. 23. (19.08.20) – Press release

Latvia Scheme providing guarantees of up to 50% at reduced guarantee fees on loans with limited maturity and size.

All EUR50m SA.56722 – COVID-19: Loan guarantee scheme and subsidised loan scheme (23.03.20)

Scheme providing working capital loans at reduced interest rates.

All EUR200m SA.56722 – COVID-19: Loan guarantee scheme and subsidised loan scheme (23.03.20)

Direct grant scheme to support companies in specific sectors affected by the Covid-19 outbreak.

Agriculture, fishery, food and school catering

EUR35.5m SA.56932 – Procedure for administration and monitoring of emergency support measures in the sector of agriculture and food due to a negative impact of COVID-19 virus spread (16.04.20) Amendment: SA.57125 – Procedure for granting, administration and monitoring of State support to agriculture

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and food in order to alleviate the negative impact of the COVID -19 outbreak (30.04.20)

Scheme providing support in the form of zero-interest loans by the Rural Support Service.

Agriculture EUR1.5m SA.57287 – COVID-19: State aid for short-term loans in agriculture to relieve the negative impact of the COVID-19 outbreak (12.05.20)

Direct grants to cover the financial costs for the repatriation to Latvia of travellers who were on holiday abroad in the course of the outbreak.

Tour operators EUR800,000 SA.57423 (2020/N) – COVID-19: Grants for the benefit of tourism operators (29.05.20)

Direct grants to help airBaltic recapitalise.

Airlines – airBaltic EUR250m SA.56943 – COVID-19: Recapitalization of airBaltic – Latvia (03.07.20) – Press release

Recapitalisation fund to invest through debt and equity instruments in large enterprises active in Latvia affected by the Covid-19 outbreak.

Large enterprises EUR100m SA.57409 – COVID-19: Recapitalization Fund (06.07.20)

Reduction of lease payments for lessees of publicly-owned property.

Lessees of publicly-owned property

EUR58m SA.57740 – COVID-19: Reduction of the lease payments for lessees of publicly-owned property (10.07.20)

Scheme providing aid in the form of grants.

Tourism EUR19.2m SA.58072 – COVID-19: Aid to performers of economic activities in the tourism sector (27.07.20)

Scheme providing aid in the form of direct grants to support cooperatives active in the forestry sector.

Forestry EUR114,000 SA.58117 – Aid for forestry cooperatives affected by the coronavirus outbreak (30.07.20) – Press release

Scheme providing aid in the form of direct grants to cover up to 25% of

Companies with exporting activities

EUR51m SA.58104 – Limited amounts of aid (direct grant scheme) to support the employer's mandatory State social security

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mandatory social security contributions.

contributions for undertakings whose exporting activities are affected by COVID-19 outbreak (03.08.20)

Lithuania Guarantee scheme for working capital and investment loans granted by commercial banks.

All EUR110m SA.56927 – State aid measures to support the economy in the current COVID-19 outbreak - LT (08.04.20)

Two schemes providing liquidity in the form of: (i) subsidised loans via financial intermediaries; (ii) subsidised loans for outstanding invoices directly to companies.

SMEs EUR150m SA.56980 – COVID-19: Loans to undertakings most affected by COVID-19 (10.04.20)

Direct grants to cover interest on loans.

SMEs active in road freight transport

EUR5m SA.57066 – COVID-19: Direct grants to cover interest on loans of SMEs active in road freight transport (24.04.20)

Rent compensation scheme. Defined sectors including retail, hotels, restaurant, culture and sports with a turnover not exceeding EUR50m

EUR101.5m SA.57135 – COVID 19: Partial Rent Compensation for the Enterprises Most Affected by COVID-19 (30.04.20)

Scheme providing aid in the form of direct grants for the creation of new products and/or services.

Cultural and art institutions and organisations

EUR10m SA.57342 – COVID-19: Program to fund new cultural products and services (20.05.20)

Fund with a target size of EUR1bn that will invest through debt and equity instruments in enterprises affected by the Covid-19 outbreak.

Medium-sized and large enterprises

EUR1bn SA.57008 – COVID-19 - Aid Fund for Business (26.05.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Scheme providing support in the form of direct grants.

Bovine animal and milk producers

EUR30.5m SA.57514 – COVID-19: Temporary State Aid to bovine animal producers and milk producers facing economic difficulties caused by the outbreak of Covid-19 (05.06.20)

Scheme providing support in the form of direct grants and guarantees on loans.

Agricultural, food, forestry, rural development and fishery sectors

EUR59m SA.57529 – COVID-19: Aid to agricultural, food, forestry, rural development and fishery sectors (17.06.20) – Press release

Scheme providing aid in the form of direct grants.

Processing of agricultural products in the poultry and eggs sectors

EUR20m SA.57508 - Aid to undertakings engaged in the processing of agricultural products in the poultry and eggs sectors and which have incurred losses due to the epidemic of COVID-19. (adopted under article 107(2)(b)TFEU) (29.07.20)

Luxembourg Scheme to support companies and liberal professions through a repayable advance of up to EUR500,000 per company.

Trade, craft or industry and liberal professionals

EUR300m SA.56742 – Scheme for enterprises in temporary financial difficulties due to COVID-19 (24.03.20)

Scheme for providing loan guarantees of up to 85% of the eligible instrument.

All except the promotion, renting and sale of buildings and holding of investments

EUR2.5bn SA.56805 – Loan guarantee scheme of Luxembourg under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (27.03.20)

Scheme to support research and development and investments in the production of Covid-19-relevant products.

Products relevant to the Covid-19 outbreak

EUR30m SA.56954 – COVID-19: LU – Scheme for R&D aid and investment aid for the production of COVID-19 relevant products (08.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Scheme providing aid in the form of direct grants to support investments.

All EUR30m SA.57305 – COVID-19: Investment aid for certain sectors (20.05.20)

Solidarity fund aiming to provide liquidity to undertakings with a significant decrease in turnover.

Certain defined sectors including hotels, restaurants and tour operators

EUR200m SA.57304 (2020/N) and SA.57338 (2020/N) – COVID-19: Solidarity Fund for undertakings affected by the COVID19 outbreak and Aid for commercial shops affected by the COVID-19 outbreak (29.05.20)

Scheme to provide liquidity to undertakings with a significant decrease in turnover.

SMEs operating retail shops

EUR60m SA.57304 (2020/N) and SA.57338 (2020/N) – COVID-19: Solidarity Fund for undertakings affected by the COVID19 outbreak and Aid for commercial shops affected by the COVID-19 outbreak (29.05.20)

Scheme providing support in the form of direct grants and repayable advances.

Audio-visual production companies

EUR7m SA.57530 – COVID-19: Aid scheme for audio-visual

production companies (18.06.20)

Reinsurance scheme to support the trade credit insurance market.

Trade credit insurance

EUR145m SA.57708 – COVID-19: Reinsurance of short term credit and surety risks (01.07.20)

Malta Scheme providing guarantees of up to 90% of the loan amount.

All EUR350m SA.56843 – COVID-19: Loan guarantee scheme (02.04.20)

Scheme providing direct grants to support R&D related to the Covid-19 outbreak.

Products relevant to the Covid-19 outbreak

EUR5.3m SA.57075 – COVID-19 – Scheme for R&D (22.04.20)

Wage supplement scheme. All EUR215m SA.57076 – Wage Supplement Scheme under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (24.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Scheme to support investments in the production of Covid-19-relevant products.

Products relevant to the Covid-19 outbreak

EUR11.5m SA.57204 – COVID-19: Investment Aid for the Production of COVID-19 Relevant Products (12.05.20)

Scheme to grant interest rate subsidies.

All EUR40m SA.57163 – MDB COVID-19 Interest Rate Subsidy Scheme (CIRSS) (14.05.20)

Bond subscription facility in the form of public loan by Malta Development Bank to support bond issue by real estate developer Mediterranean Investment Holdings plc.

Real estate EUR18.7m SA.57574 – Bond subscription facility by the Malta Development Bank (06.07.20)

Scheme providing grants for Bluefin tuna fishers.

Fishery EUR720,000 SA.57984 – COVID-19: Support to Bluefin tuna fishers (20.07.20)

Scheme providing aid in the form of guarantees on loans up to EUR250,000.

SMEs EUR67.5m SA.57961 MDB COVID-19 Small Loan Guarantee Scheme (CSLG) (29.07.20)

Netherlands Direct grants for providers of social and health care providers for the purpose of allowing them to purchase, lease, license and implement e-health applications.

Social support, youth care and healthcare

EUR23m SA.56915 – Direct grant scheme for e-Health services at home under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (03.04.20)

Scheme providing guarantees for working capital and investment loans.

All EUR10bn SA.56914 – COVID-19: GO-C Guarantee Scheme (22.04.20)

Subsidised interest rates on loans for SMEs whose main source of financing derives from external equity, venture capital or microcredit.

SMEs EUR100m SA.57107 – COVID-19: Subsidised interest rates scheme (24.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Compensation for damages covering up to 70% of loss of revenue or additional costs.

Floricultural sector, horticultural sector and potato growers

EUR650m SA.57217 – NL LNV AGRI Compensation scheme agricultural and horticultural undertakings COVID-19 (adopted under Article 107(2)b TFEU) (08.05.20)

Guarantee scheme to support the trade credit insurance market.

Trade credit insurers

Unknown SA.57095 – COVID-19: Portfolio guarantee on trade credit insurance (25.05.20) (adopted under Article 107(3)(b) - Temporary Framework is not applicable to the measure)

State guarantee scheme for loans with a nominal amount between EUR10,000 and EUR50,000.

SMEs EUR713m SA.57397 – COVID-19: Dutch temporary guarantee scheme for small bank loans for medium sized and small enterprises due to the COVID-19 outbreak (27.05.20)

Scheme providing support for fixed costs in the form of direct grants.

SMEs EUR1.4bn SA.57712 – COVID-19: direct grant scheme to support the fixed costs for small and medium-sized enterprises affected by the COVID-19 outbreak (26.06.20)

Scheme providing compensation for undertakings offering special transport services.

Special transport services

EUR160m SA.57554 – COVID-19: Compensation scheme special transport for special groups due to the COVID-19 outbreak (adopted under Article 107(2)(b) TFEU) (29.06.20)

State loan guarantee and state loan for KLM to provide urgent liquidity to the company in the context of the Covid-19 outbreak.

Airlines - KLM EUR3.4bn SA.57116 – COVID-19: State loan guarantee and State loan for KLM (13.07.20) – Press release

Measure providing subsidised loans to the five Dutch Travel Guarantee Funds that offer package travel guarantee schemes in the Netherlands.

Travel EUR165m SA.57985 – COVID-19 - State loan for Dutch Travel Guarantee Funds (28.07.20)

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34 © Allen & Overy LLP 2020

Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Poland Provision by the Polish National Development Bank, Bank Gospodarstwa Krajowego, of public guarantees on investment loans and working capital loans.

All EUR22bn SA.56876 – COVID-19: Polish anti-crisis measures - guarantee scheme (03.04.20)

Scheme co-financed by the European Regional Development Fund and the European Social Fund, providing liquidity support in the form of guarantees on loans and subsidised interest rates.

All EUR700m SA.56896 – COVID-19 - Anti-crisis measures in the form of loans and guarantees financed from EU funds (08.04.20)

Scheme providing support in the form of direct grants, intended to partially cover interest on loans.

All PLN527m (approx. EUR115m)

SA.56979 – COVID-19: Interest rate subsidy scheme (10.04.20)

Scheme providing liquidity support in the form of guarantees on loans and subsidised interest rates for loans.

All PLN500m (approx. EUR110m)

SA.57065 – COVID-19: anti-crisis measures in the form of loans and guarantees financed from the re-use of resources returned from 2007-2013 financial instruments (22.04.20)

Eleven schemes providing support in the form of (i) direct grants, (ii) repayable advances, (iii) tax and payments advantages, (iv) deferrals of tax payments and (vi) wage subsidies.

All PLN35.1bn (approx. EUR7.8bn)

SA.56922 – Polish anti-crisis measures – direct grants, repayable advances, tax and payments advantages, tax deferrals and wage subsidies schemes related to COVID-19 (23.04.20)

Scheme providing support in the form of grants and repayable advances, using EU structural funds.

All PLN3bn (approx. EUR700m)

SA.57015 – State aid in the form of grants or repayable assistance under operational programmes for 2014 - 2020 to support the Polish economy in connection with the occurrence of the COVID-19 pandemic outbreak (24.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Repayable advances providing liquidity to SMEs which report a 25% decrease in revenues.

SMEs PLN75bn (approx. EUR16.6bn)

SA.56996 – COVID-19: repayable advance scheme for micro, small and medium-sized enterprises (27.04.20)

Scheme providing loans and public guarantees on loans, co-financed by the ESIF.

All PLN2bn (approx. EUR450m)

SA.57191 – State aid in the simplified repayable form from financial engineering instruments resources subject to re-use and from financial instruments under operational programmes for 2014-2020 perspective to support the Polish economy in connection with the COVID-19 pandemic outbreak (11.05.20)

Subsidised loan scheme. Large enterprises PLN10bn(approx. EUR2.2bn)

SA.57306 (2020/N) – COVID-19: Financial shield for large enterprises: Liquidity loans (25.05.20)

Scheme to partially compensate undertakings for the losses suffered due to the Covid-19 outbreak and providing direct liquidity through loans.

All PLN 7.5bn (approx. EUR1.6bn)

SA.57054 (2020/N) – COVID-19: The Polish anti-crisis measures – aid for damage compensation and to improve the liquidity of undertakings affected by the COVID-19 outbreak (29.05.20) (adopted partly under Article 107(2)(b) TFEU)

Recapitalisation scheme to enable capital support to SMEs and large enterprises.

All PLN7.5bn (approx. EUR1.65bn)

SA.57055 – anti-crisis measures - COVID-19 – equity instruments (11.06.20)

Scheme providing support in the form of interest rate subsidies.

Primary agricultural sector

PLN40m (approx. EUR9m)

SA.57568 – COVID-19: Interest rate subsidies for farmers (12.06.20)

Scheme to support R&D and production of Covid-19-relevant products.

Products relevant to the Covid-19 outbreak

PLN2bn (approx. EUR449m)

SA.57519 – R&D aid for COVID-19 relevant research and development (18.06.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

State guarantee of factoring products. All PLN11.5bn (approx. EUR2.6bn)

SA.57452 - Guarantees on factoring (23.07.20)

Scheme providing aid in the form of reduction of the annual fee for perpetual usufruct and relief in rent, lease and usufruct fees to support entrepreneurs affected by the COVID-19 outbreak.

All PLN545m (approx. EUR123m)

SA.57726 – COVID-19: State aid in the form of reduction of the annual fee for perpetual usufruct and relief in rent, lease and usufruct fees to support entrepreneurs affected by the COVID-19 pandemic outbreak (28.07.20)

Scheme providing support in the form of direct grants.

SMEs in the primary agricultural sector

PLN420m

(approx. EUR95m)

SA.58105 - COVID-19: Aid scheme for agricultural producers who are at risk of liquidity loss as a result of agricultural market restrictions due to Covid-19 (31.07.20)

Portugal Four schemes (one for each of the sectors mentioned in the next column) for providing loan guarantees of up to 90%.

SMEs and midcaps active in: (i) tourism; (ii) restaurants; (iii) extractive and manufacturing; and (iv) travel agency, touristic animation, event organisation.

EUR3bn SA.56755 – Guarantee schemes related to COVID-19 (22.03.20)

Two schemes providing support through: (i) direct grants; and (ii) state guarantees for investment and working capital loans granted by commercial banks.

All EUR13bn SA.56873 – Direct grant and loan guarantee scheme (04.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Credit line scheme consisting of the provision of loans with subsidised interest rates.

SMEs active in fishery and aquaculture

EUR20m SA.56886 – COVID-19 Credit line with subsidised interest rates addressed to undertakings active in the fishery and aquaculture sector (08.04.20)

Scheme to support investment in research, development, testing and production of Covid-19-relevant products.

Products relevant to the Covid-19 outbreak

EUR140m SA.57035 – COVID-19: Support scheme for R&D, testing and production of coronavirus relevant products (17.04.20)

Scheme providing wage subsidies with the aim of preserving employment in the Azores.

Sectors particularly affected by the Covid-19 outbreak

EUR18m SA.57049 – COVID-19: Temporary Framework measure to preserve employment on the Azores Islands I (20.05.20)

Scheme providing wage subsidies with the aim of preserving employment in the Azores.

Companies particularly affected by the Covid-19 outbreak

EUR25m SA.57050 – COVID-19: Temporary Framework measure to preserve employment on the Azores Islands II (20.05.20)

Rescue loan aimed at providing liquidity support.

Airlines - TAP EUR1.2bn SA.57369 – Aid to TAP (10.06.20) (adopted under Article107(3)c TFEU)

Scheme providing support in the form of direct grants and guarantees on loans to companies in the autonomous region of Madeira.

All EUR40m SA.57494 – Direct grant and loan guarantee scheme – Autonomous Region of Madeira (22.06.20)

Individual aid in the form of a public guarantee on a temporary loan.

Airlines – SATA EUR133m SA.58101 - COVID 19- Rescue aid to SATA (adopted under Article 107(3)(b) TFEU – Temporary Framework is not applicable to the measure) (18.08.20) – Press release

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Romania Scheme providing support in the form of direct grants and state guarantees for investment and working capital loans.

SMEs RON16bn (approx. EUR3.3bn)

SA.56895 – COVID-19: Support scheme for SMEs (10.04.20)

Amendment: SA.57572 COVID-19: Amendment of SA.56895 (2020/N) - Romania - Support scheme for SMEs (07.08.20)

Scheme providing support in the form of subsidised loans and state guarantees on loans to companies affected by the Covid-19 outbreak.

SMEs RON4bn (approx. EUR800m)

SA.57408 – COVID-19: Framework scheme for State aid in the form of subsidised loans and guarantees on loans (01.07.20)

Scheme providing aid in the form of grants for airlines starting or resuming operations at Oradea airport.

Airlines EUR1m SA.57817– COVID-19 - Oradea airport support scheme to airlines (27.07.20)

Scheme providing aid in the form of a direct grant to compensate for damage caused by the Covid-19 outbreak.

Timișoara Airport RON4.8m (approx. EUR1m)

SA.57178 – COVID-19: Aid for Timișoara Airport (adopted under article 107(2)(b) TFEU) (05.08.20) – Press release

Aid measure providing support in the form of a loan guarantee.

Airlines – Blue Air RON301m (approx. EUR62m)

SA.57026 – Loan guarantee for Blue Air (20.08.20) – Press release

Slovakia Wage subsidy scheme to cover wage costs and social security contributions to self-employed and employers affected by the Covid-19 outbreak.

All EUR2bn SA.56986 – COVID-19: Temporary Framework aid for preserving employment and self-employment (21.04.20)

Rent compensation scheme. Companies affected by the

EUR200m SA.57599 – COVID-19: Rent rebate for tenants (16.06.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

lockdown measures

Three schemes providing support in the form of direct grants and guarantees on loans.

All EUR4bn SA.57485 – COVID-19: ESIF Basic Level Liquidity Needs Support State Aid Scheme – SIH (18.06.20)

SA.57484 – COVID-19 Government Resources Basic Level Liquidity Needs Support State Aid Scheme – SIH (18.06.20)

SA.57483 - Covid-19 Government Resources Higher Level Liquidity Needs Support State Aid Scheme – Eximbanka (18.06.20)

Scheme to support research, development and testing infrastructure for Covid-19-relevant products.

Products relevant to the Covid-19 outbreak

EUR80m SA.57829 – COVID-19: State aid scheme for temporary aid to support COVID-19 research, development and testing (13.07.20)

Scheme providing aid in the form of convertible loans with maturities between 18 to 36 months.

Innovative companies

EUR25m SA.58054 - COVID 19:ESFI Liquidity Support State Aid Scheme for Innovative Companies with Limited Access to Credit Facilities (10.08.20)

Slovenia Umbrella scheme including various measures providing support in the form of direct grants, wage subsidies, exemption from paying social security contributions, reduction of certain taxes and water fees, bank guarantees deferred payment of

All EUR2bn SA.56999 – Intervention measures to mitigate the effects of the SARS-CoV-2 (COVID-19) infectious disease epidemic on the economy (24.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

certain credits and compensatory payments.

Two schemes providing support in the form of: (i) rent rebates and rent exemptions for tenants of commercial real estate managed by Slovenian public bodies; and (ii) public guarantees on investment and working capital loans.

All EUR2bn SA.57143 – COVID-19: Liquidity guarantee scheme and rent relief (30.04.20)

Various measures providing support in the form of direct grants, payment advantages and wage subsidies.

All EUR600m SA.57558 – COVID-19: Additional intervention measures scheme (Short-time work scheme, wage subsidies for June, cableways, agriculture land) (26.06.20)

Compensation scheme for damage caused by the Covid-19 outbreak.

Large undertakings

EUR200m SA.57459 – Compensation scheme for damage caused by the COVID-19 outbreak (adopted under Article 107(2)(b) TFEU) (30.06.20)

Schemes providing support in the form of: (i) direct grants and zero interest rate loans to SMEs; and (ii) direct grants for R&D and the production of products relevant to the Covid-19 outbreak.

SMEs / Products relevant to the Covid-19 outbreak

EUR100m SA.57782 COVID-19 – Support for SMEs and for COVID-19 related RDI and investment projects (14.08.20)

Spain Scheme providing guarantees of up to 80% of the loan amount.

SMEs and self-employed

EUR60bn (for both schemes combined)

SA.56803 – COVID-19: Guarantee scheme to companies and self-employed to support the economy in the current COVID-19 outbreak (24.03.20)

Amendment: SA.58096 - COVID-19: Amendments to SA.56803 – Guarantee scheme (05.08.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Scheme providing guarantees of up to 70% of the loan amount.

All EUR60bn (for both schemes combined)

SA.56803 – COVID-19: Guarantee scheme to companies and self-employed to support the economy in the current COVID-19 outbreak (24.03.20)

Amendment: SA.58096 - COVID-19: Amendments to SA.56803 – Guarantee scheme (05.08.20)

Umbrella scheme providing direct grants, repayable advances, tax and payment advantages, public guarantees on loans and loans at favourable terms.

All - SA.56851 – ECON - Umbrella Scheme - National Temporary Framework for State aid in the form of direct grants, repayable advances, tax advantages, guarantees on loans and subsidised interest rates for loans to support the economy in the current COVID outbreak. (02.04.20)

Umbrella scheme to provide support in the form of: (i) aid for Covid-19-relevant R&D; (ii) investment aid for testing and upscaling infrastructures; (iii) investment aid for the production of Covid-19-relevant products; (iv) aid in the form of deferrals of tax and/or of social security contributions; and (v) aid in the form of wage subsidies.

All EUR3.5bn SA.57019 – Second National Temporary Framework for State aid related to the containment of the COVID-19 outbreak (24.04.20)

State fund providing debt and capital support to strategic enterprises active in Spain.

All EUR10bn SA.57659 - COVID 19 - Recapitalisation fund (31.07.20)

Sweden Scheme providing guarantees on new loans of up to 70% of the loan amount.

SMEs SEK100bn (approx. EUR9.1bn)

SA.56860 – COVID-19: Government guarantee programme for companies (02.04.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Scheme providing guarantees on loans of up to 90% of the loan amount.

Airlines SEK5bn (approx. EUR 455m)

SA.56812 – COVID-19: Loan guarantee scheme to airlines (11.04.20)

Rent rebate scheme supporting half of the reduction in rent as negotiated with the relevant landlord.

Sectors deemed to have been particularly affected by the Covid-19 outbreak

SEK5bn (approx. EUR453m)

SA.56972 – COVID-19: Rent rebate for tenants (15.04.20)

Scheme to compensate damages caused by cancelled or postponed cultural events.

Cultural events SEK420m (approx. EUR38m)

SA.57051 – COVID-19: Aid for cancelled or postponed cultural events (adopted under Article 107(2)b TFEU) (22.04.20)

Compensation for damage caused by the Covid-19 outbreak.

Airlines - SAS EUR137m SA.57061 – Compensation for the damage caused by the COVID-19 outbreak to Scandinavian Airlines (24.04.20) (adopted under Article 107(2)(b) TFEU)

Scheme to compensate for damages caused by the Covid-19 outbreak.

All SEK39bn (approx. EUR3.7bn)

SA.57372 – Compensation scheme for undertakings faced with turnover losses due to COVID-19 (adopted under Article 107(2)(b) TFEU) (11.06.20)

Scheme to compensate passenger ferries for damages suffered due to the Covid-19 outbreak.

Water transport SEK100m (approx. EUR9.5m)

SA.57710 – Compensation for damages suffered by passenger ferries due to COVID-19 (06.07.20)

Recapitalisation measure by Denmark and Sweden comprising of an equity participation through subscription of new shares, the subscription and underwriting of new

Airlines - SAS EUR1bn SA.58342 – COVID19 recapitalisation of SAS (17.08.20) – Press release

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

shares in a rights issue and newly issued State hybrid notes.

UK Coronavirus Business Interruption Loan Scheme (CBILS) – scheme to support SMEs through loan facility guarantees.

SMEs GBP45m (approx. EUR49m)

SA.56792 – UK COVID 19 measure CBILS Guarantee (25.03.20)

Coronavirus Business Interruption Loan Scheme (CBILS) – scheme to support SMEs through direct grants.

SMEs GBP600m (approx. EUR654m)

SA.56794 – Coronavirus Business Interruption Loan Scheme (CBILS) Grant - COVID-19 (25.03.20)

Umbrella scheme providing aid in the form of (i) direct grants, equity injections, selective tax advantages and advance payments; (ii) state guarantees for loans; (iii) subsidised public loans; (iv) support for Covid-19-related R&D; (v) support for construction and upscaling of testing facilities; and (vi) support for production of products relevant to tackling the Covid-19 outbreak.

All GBP50bn (approx. EUR57bn)

SA.56841 – COVID-19: Temporary Framework for UK authorities (06.04.20)

Scheme providing aid in the form of direct grants.

Self-employed GBP9bn (approx. EUR10.3bn)

SA.57152 – Self-Employed (including members of partnerships) Income Support Scheme under the Temporary Framework for State aid measures to support the economy in the current COVID-19 outbreak (11.05.20)

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Jurisdiction State aid measure Sector/specified beneficiary

Value of total aid package

Decision

Trade credit insurance support scheme.

Trade credit insurance

GBP10bn (approx. EUR11bn)

SA.57451– Trade credit insurance support scheme (adopted under article 107(3)(b)TFEU – Temporary Framework is not applicable to the measure) (28.07.20)

Allen & Overy means Allen & Overy LLP and/or its affiliated undertakings. Allen & Overy LLP is a limited liability partnership registered in England and Wales with registered number OC306763. Allen & Overy (Holdings) Limited is a limited company registered

in England and Wales with registered number 07462870. Allen & Overy LLP and Allen & Overy (Holdings) Limited are authorised and regulated by the Solicitors Regulation Authority of England and Wales.

The term partner is used to refer to a member of Allen & Overy LLP or a director of Allen & Overy (Holdings) Limited or, in either case, an employee or consultant with equivalent standing and qualifications or an individual with equivalent status in one of Allen & Overy LLP’s affiliated undertakings. A list of the members of Allen & Overy LLP and of the non-members who are designated as partners, and a list of the directors of Allen & Overy (Holdings) Limited, is open to inspection at our registered office at One Bishops Square, London E1 6AD.

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