Forschungszulage & De Minimis: No – And That's Good

Why This Question Matters

In my consulting practice, I repeatedly see companies not applying for funding or misclassifying it out of uncertainty. The question "de minimis – yes or no?" often determines whether you:

• can still use other aid schemes,
• face additional documentation obligations,
• or are being unnecessarily cautious.

Particularly for innovative mid-sized companies, the Forschungszulage is often the most predictable and least restrictive option for relieving the tax burden on innovation spending – provided you understand the state aid rules correctly.

What Does "De Minimis" Actually Mean?

De-minimis aid is state support considered "so minor" that it does not appreciably distort competition. As a result, it may only be granted up to a ceiling within a given period (EU state aid law). Companies frequently need to certify, document, and cumulate de-minimis aid.

Important: whether something is "de minimis" does not depend on it being "a funding instrument" – it depends on the state aid classification of individual funding components.

Is the Forschungszulage a De-minimis Aid?

Short answer: not automatically – it depends on the component. The Forschungszulage is a tax incentive under the Forschungszulagengesetz (FZulG). The procedure is two-stage: first comes the BSFZ certificate as the basis, then the application/assessment at the tax office.

Important for classification: according to BMF administrative guidance, de-minimis rules can apply in particular to the portion of the Forschungszulage that is based on eligible own-effort contributions (e.g. for sole traders or partners in a partnership). Other eligible expenditure is typically not structured as de-minimis under state aid law, but follows other EU state aid rules.

Official entry points:

• https://www.bescheinigung-forschungszulage.de/faq
• https://www.bescheinigung-forschungszulage.de/antragsverfahren/ueber-das-antragsverfahren
• https://www.bescheinigung-forschungszulage.de/

General information on the tax-based Forschungszulage (official sources):

• Federal Ministry of Finance (BMF)
• Process via the tax administration and the Bescheinigungsstelle (BSFZ)

(Practical note: anyone using other funding programs in parallel or claiming own-effort contributions should carefully document the state aid logic – this is precisely where the typical combination errors occur.)

What Companies Should Understand Instead: Innovation Funding That Scales

I recommend not thinking of the Forschungszulage as a "classic grant logic" instrument, but as a tax-based innovation tool:

• no competitive process like grants,
• no limited pot ("budget exhausted"),
• well usable for small and medium-sized companies too,
• also retroactively applicable within the deadlines.

The crucial point is: this is not about "research for research's sake," but about demonstrable innovation – i.e. new or significantly improved products, processes, or software, including technical risks and a systematic approach.

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Typical Pitfalls (That I See Regularly)

1. Innovation Project Structured Too Late

Good ideas are plentiful – but without clean project logic, demarcation, and evidence, it becomes difficult.

2. Misunderstanding of "Eligible for Funding"

Not every product development is automatically eligible. What matters is the technical degree of novelty / the uncertainty and the systematic approach.

3. Uncertainty Due to Other Funding (Including De Minimis)

Many companies have already used grants and fear conflicts. This is exactly where a clean funding and state aid logic pays off – particularly when own-effort contributions play a role or de-minimis aid is running in parallel in the company.

Why the Forschungszulage Is Often "the Best First Option"

In my view, the Forschungszulage is particularly attractive because it:

• is predictable (no pitch, no funding competition),
• can be applied for in a standardised way (BSFZ certificate + tax application),
• becomes a permanent pillar of funding for many innovative companies.

Next Step: Clarify Quickly Rather Than Deliberate Endlessly

If you are currently innovating (software, mechanical engineering, manufacturing, new processes, AI implementation with technical uncertainty), a brief comparison is usually worthwhile:

1. Does the project fit the certification logic?
2. Which expenditure can be sensibly demarcated (including own-effort contributions)?
3. Are there conflicts or opportunities in combination with other programs (including de-minimis)?

Starting point (official certificate): https://www.bescheinigung-forschungszulage.de/