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What is the de minimis rule?
De minimis is an EU regulation that sets a cap on how much public aid a company may receive without prior approval from the EU Commission. The purpose is to prevent small grants from distorting competition in the internal market.
The rule is called "de minimis" (Latin for "of insignificant size") because it assumes that aid below a certain threshold is so small that it does not affect the market. But for most Danish SMEs, 300,000 EUR is not small change — it is actually very easy to use.
The cap: 300,000 EUR over a rolling 3-year period
Your company may receive a maximum of 300,000 EUR (~2.2M DKK) in de minimis aid over a rolling 3-year period. This means: calculated from today and three years back.
Example: Calculating the cap
Important point: It is the date of the award (when you receive the commitment), not the date of payment, that counts. So if you received a commitment in 2023, it counts until 2026.
🛑 The Covid trap: Why so many companies are blocked
Here is the big surprise that hits thousands of Danish companies: Covid compensation counts as de minimis aid.
Did you receive wage compensation during the lockdown in 2020-2021? Did you receive compensation for fixed costs? Did you receive compensation for canceled events? It ALL counts towards your 300,000 EUR cap.
Example: Typical restaurant during Covid
What counts towards your de minimis cap?
Here is the complete list of programs and support schemes that count as de minimis:
- Innobooster under 1M kr.: If your Innobooster application is under 1,000,000 DKK, it counts as de minimis.
- SMV:Digital: The entire voucher (50,000-100,000 DKK) counts.
- SMV:Grøn: The entire voucher (50,000-100,000 DKK) counts.
- Regional grants: Many regional programs (via Business Houses or municipalities) are de minimis.
- Wage compensation: All forms of wage compensation during lockdowns.
- Compensation for fixed costs: The major scheme for restaurants, events, and retail.
- Compensation for canceled events: Concerts, fairs, events.
- Self-employed compensation: Also for freelancers and sole proprietorships.
- Wage refund for employees in flex jobs: Counts.
- Maternity refund above legal requirement: If you receive more than the minimum requirement, it may count.
- Certain energy tax refunds: Specific schemes may count as de minimis.
What does NOT count? (the good news)
Here is the list of programs that do <strong>not</strong> count as de minimis — and which you can therefore use even if your cap is used:
- R&D deduction: Does NOT count as de minimis. You can get 110% deduction on your R&D expenses without consuming your cap.
- Tax credit: Does NOT count as de minimis. Startups can get 135% deduction paid out in cash.
- Innobooster over 1M kr.: When the Innobooster grant exceeds 1,000,000 DKK, it switches to "block exemption" (GBER) and does NOT count as de minimis.
- Horizon Europe: EU's large research programs do not count as de minimis.
- Competence funds: Does NOT count as de minimis. It is your own money (you have paid it in).
- EIFO-garantier: Does NOT count as de minimis because they are market-based loans with interest.
How to calculate your de minimis usage
To know if you have room for a new grant, you must calculate your total de minimis usage for the last 3 years. Here are the steps:
Step 1: Make a list of all grants
Go through your bookkeeping and find all grants, wage refunds and Covid compensation you have received from January 1, 2024 to January 1, 2027 (or your current date).
Step 2: Convert to EUR
Use the official ECB rate on the date of the award (not the payment). Typically, the rate is around 7.45 DKK per EUR.
Step 3: Add up
The sum must NOT exceed 300,000 EUR. If it does, you are in breach and must repay — or cannot get a new grant.
Example: Calculation for a typical SME
Check your de minimis status before you apply
Most companies only discover they have used their de minimis cap when they are rejected for a grant application. But you can check it in advance.
Get an overview of your status
Our free CVR scan gives you an indication of whether you have room for new grants — based on publicly available data. It takes 2 minutes.
Alternatives if your de minimis cap is used
Have you used your 300,000 EUR? It is not the end. Here are your alternatives:
The R&D deduction and tax credit do NOT count as de minimis. You can get up to 110-135% deduction on your R&D expenses without consuming your cap.
Read more: R&D deduction for software companies
When the Innobooster grant exceeds 1,000,000 DKK, it switches to block exemption (GBER) and does NOT count as de minimis. If you have a large project, apply for more than 1M DKK.
Do you have a collective agreement? Then you can use competence funds to cover 100% of course expenses and wage loss — without consuming your de minimis cap.
Read more: Competence funds: Money you've never used
The de minimis cap is rolling. When aid becomes more than 3 years old, it "falls out" of your period. If you received Covid aid in 2021, it falls out in 2024. Plan your applications strategically.
Frequently asked questions about the de minimis rule
If you apply for a grant that would bring you over 300,000 EUR, the application will be rejected. If you have already received too much (e.g., if you forgot to report previous aid), you must repay the excess amount — with interest.
No. The cap applies per "single undertaking" according to EU law. If you have multiple CVR numbers but the same ultimate owner, you must share the cap. If you have a holding company with 3 subsidiaries, all four companies share the same 300,000 EUR.
No — not if they are on market terms (i.e., you pay normal interest). Only state-guaranteed loans with favorable terms count.
When you apply for a new grant, the application ALWAYS asks: "How much de minimis aid has the company received in the last 3 years?" You must report it yourself. If you lie, it is fraud — and can be punished.
Related guides
Grants for businesses 2026: Complete overview
See all grants — and which count as de minimis.
Read guide →R&D deduction: The alternative to de minimis
Get 110% deduction without consuming your de minimis cap.
Read guide →Three-layer strategy: Combine smart
How to maximize value — even with a used de minimis cap.
Read guide →Unsure about your de minimis status?
Our free CVR scan scans your company and gives an indication of your de minimis usage based on public data. The Action Plan shows which programs you can still use.