BMF Letter on Forschungszulage: What Applies 2026?
The BMF letter (07/02/2023) is the official Forschungszulage guidance. What it covers, key changes since then and what rules apply today.
If your company is classified as an SME, this can lead to higher funding rates under the Forschungszulage (Public Funding). You must check and document whether you qualify as an SME yourself – the classification depends not only on headcount and financial metrics, but often also on ownership and control structures (e.g., holding structures, sister companies, investors, family shareholders).
You can also find more about the funding and the practical application process directly at zeitmaker.com (internal info and entry point): /
A company qualifies as an SME if it:
Important in practice:
For the SME definition, an "enterprise" is any entity, regardless of legal form, that carries out an economic activity (e.g., selling products or services on the market). This includes, for example, self-employed persons, family businesses, partnerships, or associations with regular economic activity.
More on calculating personnel costs for the Forschungszulage.
The headcount corresponds to the full-time equivalents (FTE) over a year:
More on this in detail: Forschungszulage in corporate groups.
Before checking turnover/balance sheet total/employees, you must clarify your company status:
Depending on the status, metrics must be included only from you, proportionally from partner enterprises, or in full from linked enterprises – including indirect shareholdings.
A company is considered autonomous if:
Then, for the SME assessment, only your own figures count.
Exceptions: Even if the 25% threshold is reached/exceeded, the company can still be considered autonomous under certain conditions, e.g., with certain investor groups (including public investment corporations, venture capital companies, business angels up to certain limits, universities/non-profit research centres, institutional investors, small local authorities) – provided that no link arises within the meaning of the SME rules.
Partner enterprises exist when shareholdings between 25% and up to and including 50% exist (in either direction).
Consequence:
Remember: Partner enterprises of the partner enterprise (i.e., "one level further") do not have to be taken into account in certain constellations – the exact delineation is decisive here.
Linked enterprises are constellations involving control/dominant influence, e.g.:
Important: A link can also arise through natural persons or groups of natural persons acting jointly if multiple companies operate (in whole or in part) in the same or adjacent market.
Consequence:
A company is not an SME if 25% or more of its capital or voting rights are directly or indirectly controlled by public bodies (with certain narrowly defined exceptions).
The thresholds refer to the annual financial statements of the financial year for which the Forschungszulage is applied for. In group structures, consolidated accounts may also be relevant.
If you want to apply for the Forschungszulage (Public Funding), it is worth doing a clean preparation of the documentation (structure, shareholdings, evidence). On zeitmaker.com you get a structured process and support that typically saves time and avoids mistakes.
Benefits with zeitmaker.com (numbers):
More here: /
For detailed assessment and calculation logic, these official documents are particularly helpful:
< 250 employees (FTE) and either ≤ €50m turnover or ≤ €43m balance sheet total (EU SME definition under the GBER).
No. It is sufficient to meet one of the two financial limits (turnover or balance sheet total). The employee limit, however, is strict.
Part-time and seasonal employees are converted pro rata. Certain groups (e.g., apprentices, employees on parental leave) are not counted.
As soon as shareholdings or control rights are relevant. Partner enterprises (25–50%) are considered proportionally; linked enterprises (control/dominant influence) are attributed in full.
Generally, no: SME status is only lost or gained if thresholds are exceeded or undercut in two consecutive financial years.
A good starting point is zeitmaker.com, especially if you want to properly document the SME assessment and implement the application efficiently.
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The BMF letter (07/02/2023) is the official Forschungszulage guidance. What it covers, key changes since then and what rules apply today.
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