The grant for spa resorts rises to 300,000 euro, but files without CAEN Rev. 3 submitted after 25 September are rejected outright

A spa tourism company that submits its file after 25 September 2026 with its field of activity not moved to CAEN Rev. 3 will receive no request for clarification at all: its file will be rejected on the spot. The Ministry of Economy, Digitalisation, Entrepreneurship and Tourism has published in the Official Gazette of Romania Order no. 1.259/2026, which amends in sixteen points the de minimis aid scheme for the modernisation and development of spa and climatic spa resorts, approved in 2023. The same ministry has intervened recently on another de minimis scheme, through the order that made microenterprises eligible for SME Eco-Tech.

Three of the sixteen points are mere alignments of names, but they run through the whole body of the scheme. The scheme was drafted when the ministry had a different name and the classification of economic activities was at its previous version. Throughout the text, the order replaces „Ministry of Economy, Entrepreneurship and Tourism” with the current name and the abbreviation MEAT with MEDAT, and „Ministry of Labour and Social Solidarity” with „Ministry of Labour, Family, Youth and Social Solidarity”.

Underneath these adjustments, however, sit four changes that matter for the money: the rise of the grant ceiling from 200,000 to 300,000 euro, the full move to CAEN Rev. 3, with a deadline after which no clarification is sought, the opening of payments to commercial banks for forms of organisation without legal personality, and the rewriting of the list of eligible expenditure.

The order carries opinion no. 12.865 of 5 August 2026 of the Competition Council and rests on Regulation (EU) 2023/2.831 on de minimis aid.

What it changes in practice

Another de minimis scheme changed its budget in the same period: microenterprises in six counties get 37.8 million euro more.

The eligible CAEN codes are now listed by funding category. The rewritten article 9 ties each type of investment to precise codes from CAEN Rev. 3: 5611 and 5630 for food service, 5510, 5520, 5530 and 5590 for accommodation, 5510, 8699 and 9329 for spa treatment, nine codes for cultural facilities, four for sports facilities and three for leisure, 7721, 9321 and 9329. Two codes appear in two categories each: 9329, under spa treatment and under leisure, and 5510, under accommodation and under spa treatment.

The activity must have been authorised at the place of business for at least a year. The condition is repeated for every category: the applicant must have the activity authorised at the place of business for which it seeks funding both when the application is submitted and at least one year earlier. A new code cannot be opened simply to qualify for the scheme.

The structures must be classified or authorised. For accommodation and food service, the tourist accommodation structure must be classified by the central authority for tourism. For spa treatment, the treatment facility must be authorised by the central authority for health.

A single deadline for updating the CAEN code, 25 September 2026. The date is not created by this order: it comes from article 5¹ paragraph (2) of Government Decision no. 656/1997, the general deadline for reclassification at the Trade Register. The order merely takes it over and attaches a procedural consequence to it. For files submitted up to that date, the agency asks for the update through a clarification letter, and an applicant that fails to file the document from the Trade Register is rejected. For files submitted after it, any company whose field of activity has not been updated is rejected outright, without clarification.

The grant ceiling rises from 200,000 to 300,000 euro. The rewritten article 12 provides for no more than 50% of the value of the eligible expenditure, VAT excluded, but not more than 300,000 euro, the equivalent in lei. The rate of 50% does not change. The order does not reproduce the previous wording, but it can be checked in the consolidated version of the scheme on the Legislative Portal: article 12, as it had been rewritten by Order no. 576/2024, stopped the grant at 200,000 euro. The same increase appears in the framework contract in annex no. 10, where article 2 also moves from 200,000 to 300,000 euro. The 300,000 euro is precisely the general de minimis ceiling in Regulation (EU) 2023/2.831, to which article 8 letter d) of the scheme had been aligned since February 2024. For two and a half years the scheme had an eligibility ceiling of 300,000 euro and a grant ceiling of 200,000. Only now do the two coincide.

Authorised natural persons can be paid through a bank. The rule in article 38 paragraph (1), to which the exception is made, sends the destination account to the State Treasury. Under the new exception in article 38, authorised natural persons (PFA), sole traders and family businesses set up under Government Emergency Ordinance no. 44/2008 may be paid into accounts opened with commercial banks in Romania.

The payment deadline remains 30 working days. The rewritten article 39 keeps the agency’s obligation to transfer the approved amounts within no more than 30 working days of verifying and accepting them, within the limits of the budget appropriations. The order does not change the deadline, it only adds an account with a commercial bank as a possible destination, alongside the Treasury one.

The list of eligible expenditure is rewritten in four chapters. Site preparation, including demolition, clearing of vegetation, diversion of networks and environmental works; connection to utilities; the basic investment, with construction, installations and fittings; and site organisation. Fittings under the basic investment chapter are reimbursed only if the project also covers construction, extension and rehabilitation of buildings. The condition is written into article 14 paragraph (1), which covers only the actions in article 13 paragraph (1) letters a) and b). The purchase of equipment, furniture and medical apparatus specific to spa treatments falls under article 15, rewritten by point 6, where no condition of this kind appears.

Low-value assets can also be reimbursed, not only fixed assets. Goods below the value threshold for fixed assets are eligible if their useful life exceeds one year. For these, the taxpayer may recover the expenditure through depreciation deductions, under article 21 of the Fiscal Code. Here the order cites itself inconsistently: the preamble invokes article 28 paragraph (2) letter b) of Law no. 227/2015, while the new text of articles 14 and 15 refers to article 21 of the same law.

What has changed compared with the previous situation

The biggest change is about money. The grant ceiling goes up by 50%, from 200,000 to 300,000 euro, both in article 12 of the scheme and in article 2 of the framework contract. The estimated number of beneficiaries in article 11, 60 for the period 2024-2027, 15 a year, is not touched by this order.

The second change is one of classification. The 2023 scheme referred to CAEN Rev. 2. The eligibility criteria are now written directly in CAEN Rev. 3, and the definition of the field of activity in article 7 has been rewritten to the same effect. For a company, this means that carrying out the activity is no longer enough; it must have it registered under the new code.

The third change is procedural and it has teeth. The order creates both regimes at once: up to 25 September 2026, an activity that has not been updated is settled through a clarification letter, while for files submitted after that date there is no longer a clarification stage on this point. The old scheme contained neither of the two paragraphs.

In another de minimis scheme the eligibility conditions were deleted outright: an order of the minister of culture removes the article saying who may ask for the money and moves the deadline for projects to 5 December.

The fourth change concerns the route the money takes. The obligation to hold a Treasury account remains for companies set up under Law no. 31/1990, but for authorised natural persons, sole traders and family businesses the alternative of a commercial bank account appears. The same alignment was made in the framework contract in annex no. 10.

Finally, annexes nos. 4 and 5 to the scheme, the declaration on qualification as a small or medium-sized enterprise and the calculation for partner or linked enterprises, have been replaced in full with new forms.

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