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Grant Analysis

Purpose & Target

This grant, named 'STEP – Inicjatywa dla projektów z pieczęcią suwerenności Innovation Fund', aims to provide financial support to businesses that have already received a 'Seal of Sovereignty' from the European Commission's Innovation Fund program. Its core objective is to accelerate the development and implementation of critical technologies. Target Recipients and Focus

Target Recipient Types: This grant is open to both SMEs (Małe i Średnie Przedsiębiorstwa) and large enterprises (duże przedsiębiorstwa).
Size: This covers organizations ranging from micro-enterprises (typically 0-10 employees) up to very large corporations (500+ employees), provided they meet the MŚP or large enterprise definitions.
Sector Focus: This is a SECTOR-SPECIFIC grant, exclusively targeting projects within 'critical areas and technologies' as defined in the grant's annexes (Lista obszarów i technologii SEAL). It is not open to all sectors.
Geographic Scope: While the project's territorial scope can include Poland and abroad, the primary implementation location and the applicant's business operations must be within Poland.
Key Filtering Criteria: The most crucial criterion is the mandatory possession of a valid 'Seal of Sovereignty' awarded by the European Commission under its Innovation Fund program. Without this pre-qualification, applicants are ineligible.
Grant Frequency and Context: This particular funding opportunity is announced as 'Nabór I' (Call I) within the broader 'Fundusze Europejskie dla Nowoczesnej Gospodarki' (FENG) program, specifically under Priority FENG.05 'Support for projects implementing STEP initiative goals'. While it's a specific call with a set deadline, the 'Nabór I' designation suggests there might be future calls, making it a recurring program.

Financial Structure

The financial structure of this grant is highly detailed, with various types of eligible costs and differing funding intensities based on the type of aid and your organization's size and location. Total Funding and Per-Project Limits

Total Call Budget: The total amount allocated for this call is 40,000,000 PLN.
Per-Project Funding: The grant documents do not specify a minimum or maximum grant amount per individual project. However, the requested funding and its intensity must comply with specific EU public aid thresholds for each type of support.

Eligible Costs (Examples) Funding can cover a broad range of project-related expenditures, depending on the specific aid category: - Regional Investment Aid: - Acquisition of land or rights to perpetual usufruct (up to 10% of total eligible costs, or 15% for brownfield sites). - Acquisition of developed real estate (excluding residential properties, also subject to the 10%/15% limit). - Acquisition of fixed assets (machinery, equipment), including installation and commissioning costs. - Construction works and building materials. - Acquisition of intangible assets (patents, licenses, know-how, intellectual property rights), which must be new, amortizable, acquired at market conditions from unrelated third parties, and remain with the project for 5 years (3 years for SMEs). For large enterprises, intangible assets are capped at 50% of total investment costs. - Advisory Services: Costs for advisory services provided by external advisors, essential for the project's implementation. These services must not be continuous, periodic, or relate to routine operational activities (e.g., tax, accounting, legal, advertising). - Innovation Support: Costs for services like access to databases, cloud services, market research, laboratory services, high-performance computing (HPC), testing, and quality certification. - Training Services: Costs directly related to training for project participants, including lecturer fees, travel, accommodation, facility rental, training materials, and administrative costs. Participants must be employed by the applicant. - Environmental Protection Investments: Costs related to achieving higher environmental protection levels, energy efficiency (in buildings and otherwise), promoting renewable energy sources (RES, renewable hydrogen, high-efficiency cogeneration), and resource efficiency/circular economy. - De minimis Aid: This category can cover advisory services (including legal, insurance, specialized consulting, if not continuous/operational), software subscriptions (for the project's duration), innovation support services, and notary or administrative fees for permits and authorizations (e.g., energy grid connection), as well as planning, design, engineering, commissioning, and testing costs. Ineligible Costs

VAT: Generally not eligible unless your organization has no legal right to deduct or reclaim VAT.
Internal Services: Costs for advisory, innovation, or training services provided by your own employees or related entities are not eligible.
Fossil Fuels: Investments in the production, processing, transport, distribution, storage, or combustion of fossil fuels are excluded.
Mandatory Training: Training required by national law (e.g., health and safety) or general business training (e.g., legal, IT, language) not directly linked to the project is ineligible.
Military Applications: Costs solely for military-only solutions.

Matching Fund Requirements and Funding Rates

Regional Investment Aid: Requires a minimum 25% own contribution (co-financing) of eligible costs, which must be sourced from non-public funds.
Funding Rates (Intensities): The percentage of eligible costs covered by the grant varies significantly:
- Advisory, Innovation, Training (for SMEs): Up to 50% of eligible costs, with potential increases for micro and small enterprises (e.g., training aid can be increased by 10% for medium, 20% for micro/small).
- Environmental Protection Investment Aid: Ranges from 30% to 50% of eligible costs, depending on the specific environmental objective (e.g., CCS/CCU, 100% GHG reduction). Additional increases (10% for medium, 20% for micro/small enterprises) may apply, plus regional bonuses (5% or 15% depending on location in Poland).
- De minimis Aid: Up to 50% of eligible costs, but the total amount for an enterprise cannot exceed 300,000 EUR over three fiscal years.
- Specific thresholds in EUR apply to various aid types (e.g., 2.2 mln EUR for advisory, 10 mln EUR for SME innovation, 30 mln EUR for most environmental aid types per project).

Financial Guarantees

While not explicitly stated as a separate guarantee, the requirement to demonstrate the ability to self-finance the non-grant portion of the project (own contribution) serves as a financial assurance.

Financial Reporting

You will be required to submit financial documentation, including a financial model (Załącznik nr 5) with your application. Ongoing financial reporting will be required post-award to track expenditure and compliance.

Eligibility Requirements

To be considered for this grant, your business must meet the following hard, non-negotiable criteria: Organizational Eligibility

Eligible Organization Types: You must be an SME (Małe i Średnie Przedsiębiorstwa) or a large enterprise (duże przedsiębiorstwa), as defined by Article 2 and Annex I of the European Commission's Regulation (EU) No 651/2014. This includes:
- STARTUPs (micro-enterprises).
- SMEs (small and medium-sized enterprises, up to 250 employees and certain financial thresholds).
- ENTERPRISES (large enterprises, generally over 250 employees).
Geographic Location: Your organization must conduct business in Poland. This must be confirmed by registration in the National Court Register (KRS) with a registered seat or branch in Poland, or in the Central Business Activity and Information Register (CEIDG) with at least one business activity address in Poland.
Control Requirement: Your organization must be controlled by a state or entity from the European Economic Area (EEA) or Switzerland. Control means:
- Directly or indirectly holding a majority of ownership rights or voting rights (e.g., at a shareholders' meeting).
- Having the right to appoint or dismiss a majority of members of decision-making bodies (e.g., management board, supervisory board).
- Exercising decisive influence over the applicant's activities (e.g., through a management agreement).
Financial Standing: You must not be an enterprise in a 'difficult situation' as defined by EU state aid rules (Art. 2 pkt 18 rozporządzenia Komisji (UE) nr 651/2014) or have an outstanding obligation to repay unlawful state aid to the European Commission.
Public Liabilities: You must not be in arrears with public-law payments (e.g., taxes, social security contributions).
Criminal Record: Your organization must not be excluded from receiving funding due to criminal offenses as per specific Polish laws related to employing foreign workers illegally or collective entity liability.
Sanction Compliance: Your organization must comply with all relevant EU sanction regulations related to aggression against Ukraine and trade with Russia/Belarus; funding cannot be used for prohibited activities.

Project Eligibility

Seal of Sovereignty (Mandatory): Your project must have been awarded a valid 'Seal of Sovereignty' by the European Commission within the framework of its Innovation Fund program (established under Regulation (EU) 2019/856). Projects without this seal are ineligible. The seal's validity extends for the duration of the project, losing validity if the project does not start within five years of the award or is moved outside the EU.
Project Consistency: The project you submit for this grant must be identical in scope (tasks, resources, objective) to the one that received the 'Seal of Sovereignty' from the European Commission. You cannot change the project's purpose or increase the requested funding amount.
Project Location: The project's physical implementation site must be located within Poland.

Exclusion Criteria

Excluded Activities: Projects involving the production, processing, transport, distribution, storage, or combustion of fossil fuels are strictly excluded. This includes the purchase of equipment powered by fossil fuels.
Military Use: Projects focusing solely on military applications are not eligible.

Application Process

Applying for the STEP – Inicjatywa dla projektów z pieczęcią suwerenności Innovation Fund grant involves a structured online process and specific deadlines. Application Timeline and Deadlines

Competition Announcement: July 17, 2025
Application Submission Start: July 24, 2025
Application Submission Deadline: September 4, 2025, by 16:00 (according to the PARP server time). This is the absolute latest time for submission.
- Note: The application period may be shortened (but not less than 10 days, and not earlier than 40 days from announcement) or extended. Any changes will be communicated by PARP.

Application Procedure

All applications, along with required attachments, must be submitted exclusively online via the PARP's LSI system (Local Information System) at https://lsi.parp.gov.pl.
The application must be prepared in Polish. Documents in foreign languages must be translated by a sworn translator, with specific exceptions (original EC Innovation Fund application, Evaluation Summary Report, Seal of Sovereignty certificate, and agreement with the EC).
You must complete the application form strictly according to the provided instructions (Instrukcja wypełniania wniosku o dofinansowanie). Accuracy and completeness are crucial for evaluation.
Once submitted, you will receive an automatic confirmation with a unique number and date. No changes can be made after submission, except for specific rectifications requested by PARP during the evaluation.

Required Documentation and Materials Key documents you will need to prepare and submit include: - Application Form: 'Wzór wniosku o dofinansowanie projektu' (Załącznik nr 7). - Financial Model: 'Model finansowy' and its instructions (Załącznik nr 5). - Project Regulations: Familiarize yourself with the 'Regulamin wyboru projektów' (Regulations for project selection). - Expenditure Guide: Review the 'Przewodnik kwalifikowalności wydatków' (Expenditure eligibility guide) for detailed cost rules. - EC Innovation Fund Documentation (CRITICAL): - The original application submitted to the European Commission for the Innovation Fund (final version with all annexes). - The Evaluation Summary Report (ESR) from the European Commission for that application. - The Seal of Sovereignty certificate issued by the European Commission. - The agreement signed with the European Commission, if applicable, before submitting this grant application. Evaluation Process and Timeline

The evaluation is two-stage, conducted by the Committee for Project Evaluation (KOP).
Stage I: Up to 40 days after the call closes for up to 10 applications.
Stage II: Up to 60 days after Stage I for up to 10 applications.
Overall Evaluation: For up to 10 applications, the total evaluation time is expected to be a maximum of 100 days from the call closing date. For every additional 1-10 applications, the timeline may be extended by 20 days per stage.
You will participate in a panel discussion (videoconference) with the KOP experts in both stages (approx. 60 min for Stage I, 90 min for Stage II).
You may be asked to clarify or supplement your application during the evaluation. You will have 7 days for the first request and 5 days for subsequent requests.

Types of Support Offered

This grant primarily offers financial support (dofinansowanie) in the form of non-repayable aid, covering eligible project costs based on the specified public aid categories.

Post-Award Requirements and Compliance

If selected for funding, you will need to sign a grant agreement, typically electronically. You must ensure representatives have qualified electronic signatures.
You will be required to designate a project manager and submit necessary documents for the contract within specified timelines (e.g., 5 days for manager designation, 7 days for contract documents).
Ongoing financial reporting and adherence to the project plan, as outlined in the grant agreement, will be mandatory.

Evaluation Criteria

The evaluation process for this grant is conducted in two stages, with all criteria being obligatory. A project must score '1 point' for each criterion to pass. If even one criterion receives '0 points', the project will be negatively assessed. The evaluation relies on information in your application, its annexes, public registers, and details provided during panel discussions. Stage I Evaluation (Kwalifikowalność – Eligibility) This stage focuses on the fundamental eligibility of the applicant and the project. Each criterion is scored 0 or 1 point.

Applicant Eligibility: Evaluates whether your organization meets the type, registration, and Polish operational presence requirements (as detailed in 'Eligibility Requirements').
Project Eligibility: Assesses if your project possesses the mandatory 'Seal of Sovereignty' from the EC Innovation Fund and confirms that the project submitted for this grant is consistent with the one that received the seal (same tasks, resources, and objective).

Stage II Evaluation (Detailed Assessment) Projects that pass Stage I move to this more detailed assessment, where each criterion is also scored 0 or 1 point. A minimum of 1 point is required for each.

Project Location: Confirms that the project's physical location is within Poland.
Excluded Activities: Verifies that the project does not involve any activities explicitly excluded from support (e.g., fossil fuels, solely military applications).
Project Indicators: Assesses the quality and relevance of the project's product and outcome indicators, ensuring they are consistent, measurable, verifiable, and realistic. This includes indicators specific to your project, but excludes environmental indicators (which are assessed separately).
Project Budget: Examines the proper allocation of expenses, adherence to the eligibility period (costs must be incurred by December 31, 2029), consistency with the EC Innovation Fund application, cost rationality, and alignment with funding limits and intensities from the 'Expenditure Eligibility Guide'. Crucially, it verifies that you have secured adequate financing for your own contribution.
Project Profitability and Justification: Evaluates the financial, market, and environmental viability of the project. This includes a 10-year financial forecast (NPV, IRR) and a robust market analysis for the critical technology.
Compliance with Public Aid Rules: Ensures the requested aid adheres to the specific provisions of EU state aid regulations (e.g., regional investment aid, aid for SMEs, environmental aid, de minimis aid), including intensity limits and thresholds.
Incentive Effect: Verifies that the project has not commenced before the application submission date, as defined by EU regulations (with some exceptions for de minimis costs).
Sustainable Development Principle: Assesses whether the project aligns with sustainable development goals, the 'Do No Significant Harm' (DNSH) principle, and incorporates at least one or two '6R' principles (refuse, reduce, reuse, recover, recycle, rethink), or demonstrates other positive environmental impacts with measurable indicators.
Horizontal Principles of Equal Opportunities and Non-Discrimination: Evaluates the project's positive or neutral impact on equal opportunities and non-discrimination based on gender, race, ethnicity, religion, disability, age, or sexual orientation. It also specifically checks for accessibility for persons with disabilities (universal design).
Compliance with the Charter of Fundamental Rights: Checks the project's adherence to relevant articles of the EU Charter of Fundamental Rights (Arts. 1, 3-8, 10, 15, 20-23, 25-28, 30-33), ensuring consistency or neutrality.
Compliance with the Convention on the Rights of Persons with Disabilities: Assesses the project's alignment with relevant articles of the UN Convention on the Rights of Persons with Disabilities (Arts. 2-7, 9, 27), ensuring consistency or neutrality.

Tie-Breaking Criterion In case of insufficient funding to support all equally scored projects, priority will be given to projects located in districts ('powiat') with a higher unemployment rate.

Compliance & Special Requirements

This grant has stringent compliance and unique requirements, primarily stemming from its alignment with EU initiatives and state aid rules. Regulatory Compliance

EU Law: Projects must comply with various EU regulations, including those governing European Structural and Investment Funds (e.g., Regulation (EU) 2021/1060, 2021/1058), state aid (Regulation (EU) No 651/2014, de minimis Regulation 2023/2831), and specifically the Platform for Strategic Technologies for Europe (STEP) Regulation (EU) 2024/795, the Critical Raw Materials Act (Regulation (EU) 2024/1252), and the Net-Zero Industry Act (Regulation (EU) 2024/1735).
Polish Law: Compliance with national laws, including the Public Finance Act, Public Aid Act, and Electronic Delivery Act, is mandatory.

Data Protection and Privacy

While not explicitly detailed, the use of electronic systems (LSI, e-PUAP, SL2021) implies compliance with relevant data protection and privacy regulations, including GDPR.

Environmental Compliance

Sustainable Development: Projects must adhere to the principle of sustainable development, integrating environmental considerations (Art. 9, Regulation (EU) 2021/1060).
'Do No Significant Harm' (DNSH): Your project must ensure it does not cause significant harm to environmental objectives.
Circular Economy / 6R Principles: Projects are evaluated on their contribution to at least one or two of the '6R' principles (Refuse, Reduce, Reuse, Recover, Recycle, Rethink) or other positive environmental impacts, with measurable indicators.
Fossil Fuel Exclusion: Strictly prohibits investments related to fossil fuels (production, processing, transport, distribution, storage, or combustion).

Ethical Standards and Human Rights

EU Charter of Fundamental Rights: Projects must be consistent or neutral concerning specific articles of the EU Charter of Fundamental Rights (Arts. 1, 3-8, 10, 15, 20-23, 25-28, 30-33).
UN Convention on the Rights of Persons with Disabilities: Projects must align with or be neutral towards relevant articles of this Convention (Arts. 2-7, 9, 27).
Equal Opportunities and Non-Discrimination: Projects are assessed on their positive or neutral impact on equality and non-discrimination based on gender, race, ethnicity, religion, disability, age, or sexual orientation. Accessibility for persons with disabilities is a key consideration, aligned with universal design principles.

Intellectual Property (IP) Policies

Eligible IP Costs: Costs for patents, licenses, know-how, and other intellectual property rights are eligible if they are used exclusively in the aided facility, are amortizable, acquired at market conditions from unrelated third parties, become the applicant's assets, and remain connected to the project for at least 5 years (3 years for SMEs).

Risk Management

The financial assessment includes a review of the project's profitability and financial assumptions, implying an expectation of sound risk management from the applicant.

Unique Aspects and Strategic Opportunities

Pre-qualification: Seal of Sovereignty: The most distinctive feature is the mandatory pre-qualification through the European Commission's 'Seal of Sovereignty' from the Innovation Fund. This means this grant is for projects already recognized as high-potential at the EU level, streamlining national funding.
Control by EEA/Switzerland Entity: The requirement for the applicant to be controlled by an entity from the EEA or Switzerland is a specific and crucial eligibility criterion, emphasizing European strategic autonomy in critical technologies.
Strategic Alignment: This grant directly supports the EU's strategic initiatives for critical technologies (STEP), aiming to strengthen Europe's industrial base and reduce dependencies. This presents a significant strategic alignment opportunity for businesses working in these areas.
Competitive Advantage: Having secured the Seal of Sovereignty already puts applicants in a highly competitive position, as this grant specifically targets such pre-qualified projects.

Grant Details