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Grant Analysis

Purpose & Target

The primary objective of this grant is to support investment projects undertaken by businesses in the digital technologies sector. The aim is to foster the manufacturing of critical digital technologies or elements of their value chains that contribute to reducing or eliminating the European Union's strategic dependencies on third countries. This funding is specifically designed for investment in production capabilities, not for research and development or the deployment of final products. This grant is SECTOR-SPECIFIC, focusing solely on digital technologies that are deemed critical for EU's independence. The target recipients are all sizes of enterprises, including micro, small, medium, and large companies. The geographic scope for project implementation is Poland. While the project's impact can extend globally, the investment itself must occur within Poland. Organizations applying must either be registered in Poland or be a Polish branch of a parent company located in an EU Member State. Key criteria for initial screening include: the project's direct contribution to reducing EU strategic dependency in digital technologies, the focus on manufacturing/production (not R&D or end-product implementation), the project's location in Poland, and the applicant's operational and financial stability. This is a specific call (Nabór I) within the broader 'Fundusze Europejskie dla Nowoczesnej Gospodarki' (FENG) program, suggesting it is part of a recurring or structured funding initiative.

Financial Structure

The financial framework for this grant provides clear parameters for project funding and associated requirements:

Total Funding Amount for the Call: The total budget allocated for projects within this specific call is 150,000,000 PLN.
Minimum Project Cost: The minimum value of eligible costs for a project to be considered for funding is 10,000,000 PLN. This means your project's total eligible expenses must be at least this amount.
Maximum Funding per Project: The maximum grant amount that can be awarded to a single project is 150,000,000 PLN.
Funding Rate: The grant can cover up to 75% of the project's eligible costs. This is the maximum co-financing rate.
Co-financing and Matching Fund Requirements: A minimum of 25% of the eligible costs must be covered by the applicant's own contribution. This contribution must come from sources free of public support. Applicants need to demonstrate their ability to finance the project and provide documents confirming external funding sources if applicable.
Eligible Costs: Funding can be obtained for a variety of investment-related expenses, including:
- Acquisition of machinery and equipment.
- Acquisition of real estate.
- Acquisition of construction works and building materials.
- Acquisition of intangible assets.
- Training services essential for project implementation.
- Advisory services related to innovation.
- General advisory services.
- Detailed eligible cost categories are specified in the 'Przewodnik kwalifikowalności wydatków' (Guide to Eligible Expenditures).
Ineligible Costs: Certain activities and expenditures are excluded:
- Activities related to fossil fuels (production, processing, transport, distribution, storage, burning).
- Solutions with exclusively military applications.
- The project's primary purpose cannot be industrial research or experimental development work.
- Installation or implementation of end products are not eligible. The grant supports the manufacturing capabilities for critical technologies, not their final deployment or use.
Financial Reporting and Audit Requirements: While specific detailed requirements are not listed, the grant mentions the need to submit a financial model (Model finansowy) and implies regular reporting as part of the project's implementation and final settlement (submission of the final payment application).
Financial Guarantees: Applicants must provide credible proof of their financial capacity to realize the project, including external funding sources if relied upon. This is assessed in the 'Zdolność do finansowej realizacji projektu' (Financial Capacity for Project Implementation) criterion.

Eligibility Requirements

To be considered for this grant, your business must meet several mandatory criteria:

Eligible Organization Types: Micro, Small, Medium Enterprises (MŚP) or Large Enterprises ('przedsiębiorstwa inne niż MŚP'), as defined by Article 2 of Annex I to Commission Regulation (EU) No 651/2014. This means businesses of all sizes are eligible.
Legal Presence and Activity: Your organization must conduct business operations in Poland. This must be confirmed by registration in the National Court Register (KRS) or the Central Registration and Information on Business (CEIDG).
- For companies registered in KRS, the registered office or at least one branch must be in Poland. If it's a branch of a foreign entity, the parent company must be based in an EU Member State.
- For companies registered in CEIDG, at least one address of economic activity must be in Poland.
Operational History: You must have been actively operating for at least 36 months and have completed 3 closed financial years. If the applicant is a 'spółka celowa' (special purpose vehicle), this requirement applies to the parent company ('spółka dominująca').
Financial Capacity: Your operating revenue must have been at least 20% of the project's eligible costs, calculated as an average over the last 3 closed financial years. Again, for 'spółka celowa', this applies to the parent company.
Project Scope: The project must be an investment project focused on the manufacturing of critical digital technologies or elements of their value chain. It must contribute to reducing or combating the EU's strategic dependency on third countries.
- This includes: creating production lines, establishing 'first-of-its-kind' plants, expanding or repurposing existing plants, increasing process scale, and implementing quality control mechanisms.
- Crucially, the project cannot involve the installation or implementation of end products. The focus is on producing the critical technology or its components, not deploying the final consumer product.
Control: Your organization must be controlled by a state or an entity from an EU Member State. 'Control' is defined as:
- Directly or indirectly holding the majority of ownership rights or voting rights (e.g., at shareholder meetings).
- The right to appoint or dismiss the majority of members of decision-making bodies (e.g., management board, board of directors, supervisory board).
- Exercising decisive influence over the applicant's operations (e.g., through a management agreement or profit disposal arrangement), either alone or jointly with another entity.
Exclusion Criteria: The project cannot fall into any of the following categories:
- Activities explicitly excluded by various EU regulations (e.g., 651/2014, 2023/2831, 2021/1058) or national regulations.
- Production, processing, transport, distribution, storage, or combustion of fossil fuels.
- Solutions with exclusively military applications. However, dual-use products are permitted if they also have a civilian application, which must be clearly justified and quantified (proportion of civilian vs. military use in revenue forecasts).
- The primary object of the project cannot be industrial research or experimental development work (B+R). While B+R results can be utilized, the investment itself must be for production.

Application Process

Applying for this grant involves a structured process with specific deadlines and documentation:

Application Submission Window:
- Applications open: July 31, 2025, 00:00.
- Application deadline: October 2, 2025, 16:00 (Warsaw time).
- Note: The application period may be shortened (but no less than 10 days, and no earlier than 40 days from call announcement, with 7 days prior notice) or extended by the Intermediate Body (IP) under certain circumstances.
Application Procedure and Platform:
- All applications, along with supporting documents, must be submitted online through the Local Information System (LSI) at lsi.parp.gov.pl.
- The application form (Wzór wniosku o dofinansowanie) and instructions (Instrukcja wypełniania wniosku o dofinansowanie) are available on the grant website.
- You will use the 'Generator Wniosków' (Application Generator) within the LSI system to prepare and submit your application.
- After submission, you will receive a confirmation with a unique number and date. No changes can be made after submission, except for specific corrections/clarifications requested by the IP.
Required Documentation and Materials:
- Completed application form (Wzór wniosku o dofinansowanie).
- Financial Model (Model finansowy) and its instructions (Model finansowy – instrukcja).
- List of areas and critical technologies for the digital technology sector.
- Guide to Eligible Expenditures (Przewodnik kwalifikowalności wydatków).
- Project Selection Criteria (Kryteria wyboru projektów).
- Glossary (Słownik).
- Draft Grant Agreement (Wzór umowy o dofinansowanie projektu).
- Various annexes/statements required for contract signing (e.g., VAT qualification statement, control statement, non-criminality certificate).
- Documents confirming the acquisition of external funds for co-financing, if applicable.
- Documents related to parent company status if the applicant is a special purpose vehicle or dependent company.
- Documents in foreign languages must be accompanied by a certified Polish translation.
Evaluation Process and Timeline:
- The evaluation is conducted in two stages by a Project Assessment Committee (KOP).
- Stage I: An initial assessment of basic eligibility criteria (pass/fail). Expected to take 40 days (for up to 60 applications).
- Stage II: Detailed scoring, including a panel meeting with the applicant's representatives. Expected to take 60 days (for up to 60 applications).
- The total assessment period is approximately 100 days from the application deadline for up to 60 applications. This period may be extended if more applications are submitted.
- Applicants may be asked to supplement or correct their applications. Panel meetings for Stage II are conducted via videoconference.
Types of Support Offered: The primary support type is non-repayable grant funding (bezzwrotna dotacja).
Project Implementation Timeline:
- The full project scope, both substantive and financial, must be completed, and the final payment application submitted no later than December 31, 2029.
- Applicants should factor in time for obtaining necessary permits (e.g., construction permits) and certifications when planning their project end date.
Reporting Obligations and Post-Award Requirements: Not explicitly detailed in the provided text beyond the general obligation to submit a final payment application by the end of 2029. However, it's implied that regular reporting and compliance with the grant agreement terms (Umowa o dofinansowanie) will be required.
Application Assistance Availability:
- Queries can be submitted via a contact form on the grant website.
- Email support: [email protected].
- Phone support: +48 22 574 07 07 or +48 801 332 202 (Monday-Friday, 8:30-16:30).
- An FAQ section with common questions and answers is available on the grant website.

Evaluation Criteria

The evaluation process is structured in two stages, with specific scoring criteria at each step. Only projects that pass all Stage I criteria proceed to Stage II. Stage I Evaluation (Obligatory - 0 or 1 point per criterion) To pass Stage I, a project must receive 1 point for each of the following five criteria:

Applicant Eligibility: Checks compliance with requirements for operating in Poland, the 36-month business activity, 3 closed financial years, and the 20% operating revenue ratio (relative to eligible project costs). Failure in any of these means 0 points.
Project Location: Confirms that the project implementation location is within Poland.
Digital Technology Sector: Verifies that the project falls within the digital technology sector as defined by EU Regulation 2024/795, including deep technologies, and is related to critical technologies or their value chains as listed in the regulations.
Manufacturing of Critical Technologies: Assesses if the project specifically concerns the manufacturing of critical technologies or elements of their value chains (e.g., creating production lines, 'first-of-its-kind' plants, expanding existing facilities, scaling processes, quality control). Projects involving installation or implementation of end products will receive 0 points.
Excluded Activities: Confirms that the project does not involve any activities explicitly excluded from support, such as fossil fuel-related activities or solutions with exclusively military applications. (Projects with dual-use potential are allowed if civilian application is demonstrated).

If a project scores 1 point on all 5 criteria, it moves to Stage II. Stage II Evaluation (Scored) In Stage II, projects are assessed against a set of obligatory and optional criteria. To be selected for funding, projects must meet all obligatory criteria and score at least 1 point in each. Obligatory Criteria (Minimum 1 point required for each, unless otherwise specified):

Potential of Critical Technology in the Project (0, 1, 3, 5, or 10 points):
- Assesses how well the project addresses a strategic need or challenge at the EU level regarding critical technologies and strategic dependencies.
- Evaluates the project's contribution to reducing EU dependency (e.g., enhancing EU leadership in digital technology, securing critical infrastructure access, increasing production capacity, improving supply security, promoting cross-border effects within the internal market).
- Examines the project's economic potential, including market analysis, target clients, market size estimation, competitiveness of the project's output within the EU internal market, and identification/mitigation of risks.
Applicant's Potential for Project Implementation (0, 1, 2, or 3 points):
- Checks preparedness for planned investment activities (e.g., necessary permits, intellectual property rights).
- Evaluates the adequacy of technical and human resources, including the management team's experience and the project's management structure.
- Assesses the clarity and realism of the project's schedule.
- Additional points can be awarded for possessing a valid building permit (if applicable) or demonstrating prior successful implementation of another project in the digital technology sector. For special purpose vehicles, parent company experience can be considered.
Project Expenditures and State Aid Compliance (0 or 1 point):
- Verifies that requested costs and funding limits comply with grant regulations (e.g., minimum eligible costs of 10 million PLN and maximum funding of 150 million PLN).
- Ensures all expenditures are necessary, rational, justified, and properly categorized according to the 'Guide to Eligible Expenditures'.
- Confirms compliance with specific state aid rules applicable to the project (e.g., regional investment aid, de minimis aid, aid for SME advisory services, training, environmental protection, energy efficiency, renewables, circular economy).
Financial Capacity for Project Implementation (0 or 1 point):
- Evaluates the adequacy and reliability of proposed funding sources, including own contribution (min. 25% of eligible costs) and external financing (e.g., loans).
Project Profitability (0 or 1 point):
- Assesses whether the project is profitable based on financial forecasts (Net Present Value - NPV, Internal Rate of Return - IRR) provided in the financial model.
Project Indicators (0 or 1 point):
- Verifies that product and outcome indicators are adequate, measurable, consistent, objectively verifiable, and realistic, with clearly defined baseline and target values.
Incentive Effect (0 or 1 point):
- Confirms that the project has not started before the application submission date (with exceptions for certain de minimis costs).
Sustainable Development Principle (0 or 1 point):
- Ensures the project complies with environmental regulations, supports sustainable development goals (including Paris Agreement and 'do no significant harm' principle).
- Requires demonstration of positive environmental impact, for example, by adhering to at least two '6R' principles (refuse, reduce, reuse, recover, recycle, rethink) or other environmental aspects, supported by measurable indicators.
Equal Opportunities and Non-Discrimination (0 or 1 point):
- Verifies the project's positive impact on equal opportunities and non-discrimination based on gender, race, ethnicity, religion, disability, age, or sexual orientation.
- Ensures accessibility for people with disabilities, aligning with universal design principles.
Charter of Fundamental Rights Compliance (0 or 1 point):
- Confirms project compliance with specific articles of the EU Charter of Fundamental Rights (e.g., human dignity, freedom, equality, solidarity, citizens' rights, justice).
UN Convention on the Rights of Persons with Disabilities Compliance (0 or 1 point):
- Confirms project compliance with specific articles of the UN Convention on the Rights of Persons with Disabilities.

Optional Criterion (Scored, Not Obligatory - 0, 3, 6, or 9 points):

Project Impact Scope:
- Assesses if the project contributes to the applicant's global market position (significant scale increase).
- Evaluates the potential for the critical technology to impact internal and external markets (market growth, technology adoption, influence on market competitiveness).
- Considers broader positive social, economic, environmental, or climate impacts at least at the EU level.

Tie-Breaking Criteria: If multiple projects achieve the same total score and funding is insufficient for all, the following criteria will determine priority: 1. National Key Cluster Membership: Applicant has been a member of a National Key Cluster for at least 6 months prior to application submission. 2. Female Management/Co-management: The applicant organization has been managed or co-managed by a woman for at least 6 months (woman as partner representing the company, or as partner/shareholder and management board member).

Compliance & Special Requirements

Compliance and special requirements are paramount for this grant, extending beyond just financial aspects:

Regulatory Compliance: Projects must strictly adhere to both European Union and Polish regulations. This includes, but is not limited to:
- Regulation (EU) 2024/795 establishing the Platform for Strategic Technologies for Europe (STEP).
- Commission Regulation (EU) No 651/2014 (General Block Exemption Regulation - GBER) for state aid.
- Commission Regulation (EU) 2023/2831 on de minimis aid.
- Regulation (EU) 2021/1058 on the European Regional Development Fund (ERDF) and Cohesion Fund.
- Polish legal acts related to the 'Fundusze Europejskie dla Nowoczesnej Gospodarki' (FENG) program, public finances, and electronic delivery services.
Environmental Compliance and Sustainable Development: A core requirement is compliance with the principle of sustainable development. This involves:
- Adhering to relevant environmental protection laws.
- Actively contributing to environmental improvement, for instance, by implementing at least two of the '6R' principles (refuse, reduce, reuse, recover, recycle, rethink), or demonstrating a positive impact on other environmental aspects.
- Projects must demonstrate a minimum 10% improvement in at least one environmental indicator compared to the baseline, if not directly applying '6R' principles.
- Compliance with the 'do no significant harm' (DNSH) principle is mandatory, meaning the project should not cause any significant harm to environmental objectives.
Ethical Standards and Social Inclusion: The grant mandates adherence to high ethical standards and promotes social inclusion:
- Compliance with the EU Charter of Fundamental Rights (specifically Articles 1, 3-8, 10, 15, 20-23, 25-28, 30-33). Applicants must describe how their project aligns with these rights or is neutral to them.
- Compliance with the UN Convention on the Rights of Persons with Disabilities (specifically Articles 2-7, 9, 27). Similarly, applicants must detail their project's alignment or neutrality.
- Adherence to horizontal principles of equal opportunities and non-discrimination. This includes promoting accessibility for persons with disabilities (e.g., via universal design) and ensuring gender equality in all project aspects.
Intellectual Property (IP) Policies: If the project involves intellectual property, the applicant must demonstrate regulated legal matters concerning these rights. This means having the necessary rights for commercialization, such as transferred copyrights, licenses for use, or patent rights.
Risk Management Expectations: Applicants are expected to identify and outline actions to mitigate potential risks during project implementation. This is assessed as part of the project's overall potential.
Unique Aspects and Strategic Alignment Opportunities:
- The grant's core focus is on reducing the EU's strategic dependencies in digital technologies. Projects must clearly demonstrate how they contribute to this goal, e.g., by enhancing EU industrial leadership, securing critical supply chains, or increasing production capacities within the EU.
- Emphasis is placed on manufacturing capabilities (e.g., creating production lines, 'first-of-its-kind' plants, scaling processes), differentiating it from pure R&D or end-product deployment.
- While not obligatory, projects demonstrating a wider impact (e.g., significant increase in global market presence for the applicant, positive broader social/economic/environmental effects at EU level) may gain competitive advantage during evaluation.
Cross-cutting Themes: Gender equality, inclusion, and sustainability are cross-cutting themes that are explicitly evaluated through dedicated criteria, emphasizing their integral role in project design and implementation.
Control Requirement: A distinctive requirement is that the applicant organization must be controlled by a state or an entity from an EU Member State. This ensures alignment with EU strategic goals.

Grant Details