How companies with state aid for new factories get paid: a file in seven folders, 60 days of checks and an on-site inspection

The money promised through the state aid scheme for factories that make goods Romania imports in bulk has had, since Friday, a reimbursement route written down on paper. Order of the Minister of Finance no. 1.112/2026 approves the Guide on the payment of the state aid granted under Government Decision no. 486/2026, and the guide itself, 37 pages, appears in a separate edition of the Official Gazette of Romania. It is the second large state aid scheme with a tax credit component to be given settlement rules this summer, after the TechUp România scheme.

State aid for investment comes in two forms, and the company picks one of them at the moment of the financing agreement. The first is the non-repayable amount, that is, money actually transferred into an account. The second is the tax credit, that is, a sum by which the company reduces the profit tax it has to pay, calculated by the ministry through a decision and used through the annual profit tax return, form 101.

The guide does not change who receives aid, nor how much. It only changes what has to go into the file in order to receive it, and in state aid matters that is precisely what decides whether the money arrives or not.

What it changes in practice

The first effect is the mandatory timetable that follows the agreement. The company has to start the investment within 6 months of the date on which the financing agreement was issued and to incur the eligible expenditure between the start date and 31 December of the year in which the investment is completed, but no later than 31 December 2037. The guide also gives an example: a company holding an agreement for expenditure over the 2026-2028 period may claim payment only for eligible expenditure incurred by 31 December 2028, and the assets have to be recorded in the accounts by that same date.

The second effect is that filing is done exclusively online, through the „Big Project 486” application on the website of the Ministry of Finance. The guide says expressly that requests submitted to any other address will not be taken into consideration. There is no paper route and no e-mail route.

The third effect is the order of the documents. The file is organised into seven numbered folders. The first holds the payment request, the settlement form and the documents issued by other authorities. The second holds everything to do with the purchase from suppliers. The third holds, for each machine separately and in this order, the invoice, the bank statement validated by the bank, the works progress statement where applicable, the accounting note and the photograph. The guide expressly forbids grouping by type of document, that is, all the invoices together and all the bank statements together. The fourth holds the declarations, the fifth the fixed assets register, the sixth the commissioning report, only for the tax credit, and the seventh any other relevant documents. All pages are numbered in ascending order, and the first sheet of the file is the payment request.

The fourth effect concerns procurement. The company has to have a written internal award procedure in place before it signs the contracts and to have sent an invitation to tender to at least three economic operators. Transparency means, as the guide defines it, a notice in a newspaper or on the company’s own website plus the invitations to those three. If the market holds no three suppliers capable of delivering, the company gives a declaration on its own responsibility to that effect, with every payment request.

The fifth effect is the list of what is not reimbursed. For construction, only the expenditure under subchapter 4.1 „Construction and installations” of the estimate for the object is eligible, that is, the erection of new buildings. The purchase, modernisation or refurbishment of an existing building is not reimbursed, nor are the additional works needed to change its use. For equipment, what is not reimbursed is furniture, including industrial furniture, decorations, means of transport subject to registration, computers that are not part of the technological flow, office equipment, tool kits and tool cabinets. Nor is the transport and installation of plant and machinery reimbursed, even though it forms part of their real cost.

The sixth effect is the on-site check, which becomes a condition of payment and not a formality. The inspectors travel to the site of the investment and, where applicable, to the registered office, and the company is obliged to designate by e-mail the persons who will accompany them. The assets have to exist physically, with an inventory number applied to each one. The guide states in capital letters that assets which cannot be identified physically at the site of the investment will NOT be reimbursed.

The seventh effect concerns debts to the State. Payment is made only if the company has no outstanding debts to the general consolidated budget, evidenced by a tax clearance certificate from ANAF and by certificates for the local budgets, for the registered office and for every secondary establishment listed in the trade register certificate. Nor is payment made if the company is under investigation by the Competition Council, by the European Commission or by the criminal investigation bodies, or if it is under enforcement, insolvency, bankruptcy, a restructuring agreement, a composition with creditors, judicial reorganisation, dissolution, operational closure, liquidation or temporary suspension of activity.

The eighth effect is the block that applies while the analysis lasts. For as long as a payment request is under analysis at the ministry, the company cannot ask for a change to the investment timetable and cannot file a new payment request. If both reach the ministry at the same time, the payment request is returned until the change of timetable is approved.

What has changed compared with the previous situation

Until now the scheme existed but the settlement procedure did not. Government Decision no. 486/2026 had established who may receive aid and on what conditions, and Article 42 of it required the Minister of Finance to approve a payment guide. Order no. 1.112/2026 does exactly that, almost two months after the report of the Directorate-General for State Aid, drawn up on 9 July 2026.

The level of detail has also changed compared with what was practised under earlier schemes. The guide does not stop at the list of documents: it says what each of them has to contain, in what order they are presented and what happens if something is missing. Works progress statements have to be signed by the company, by the contractor and by the site supervisor. Accounting notes have to be signed by whoever drew them up and endorsed by the financial director. Invoices in foreign currency call for a separate box with the equivalent in lei. Photographs have to show the whole machine and the inventory number.

The guide carries the mention „Revision 0”, so it is the first version of the document, and it applies to payment requests filed from the date of publication in the Official Gazette of Romania onwards.

Finally, a mechanism appears for the case where the financing agreement is corrected and the aid intensity changes. The eligible expenditure already paid and that recognised in the request under analysis are added together, the intensity from the corrected agreement is applied, and the aid already paid is deducted from the result. The difference is paid in the current instalment or adjusted in the following ones.

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