In brief
- Cultural projects funded under the Ministry of Culture’s de minimis scheme now have until 5 December, not until 5 November. That is 30 extra days to finish all activities, within the year of the call for which the project was submitted. It is the only change that gives applicants anything more.
- The order also repeals, however, the article that said who may apply for the money. Article 6(1) of the scheme contained all the cumulative eligibility conditions for the applicant, from the two years’ standing and the CAEN codes to the exclusion of political parties, religious institutions and companies in insolvency. It has been deleted without being replaced by anything.
- The list of eligible partners has gone the same way. Article 8(2) defined the categories of partner; it has been repealed, even though paragraph (1) keeps the possibility of implementing projects in partnership, and paragraph (3) still requires „partenerilor eligibili”, eligible partners, to submit the declaration on the type of undertaking.
Published: Official Gazette of Romania, Part I, no. 814 of 24 September 2026, page 5
In force from: 24 September 2026, the date of publication, because the order does not set a later date
On 21 September 2026 the Minister of Culture signed a one-page order changing three things in the de minimis aid scheme for the independent cultural sector, approved in July 2026 and intended to fund private cultural projects. The scheme runs on the same European rules as the other national de minimis programmes, for instance the one for microenterprises in the counties undergoing a just transition: a ceiling of 300,000 euro per single undertaking, over any three-year period assessed on a rolling basis. The text appeared on 24 September 2026 in the Official Gazette of Romania (Monitorul Oficial).
The visible amendment is in Article 16. The implementation deadline for projects moves from 5 November to 5 December of the year of the call for which the project is submitted, the date by which all activities have to be completed. That is exactly 30 extra calendar days, in a scheme where the minimum grant is 10,000 euro and the maximum 100,000 euro, both converted at the InforEuro rate of the month in which the contract is signed.
The other two amendments are repeals, and they leave the scheme without rules precisely where it used to have its most detailed pages. Article 6(1) listed thirteen cumulative conditions the applicant had to meet: to be a non-governmental organisation, a company, a cooperative company, an authorised natural person, a sole trader or a family business, set up at least two years before the launch of the call; to be active in one of the cultural and creative sectors listed, from architecture and libraries to the performing arts; to hold the corresponding CAEN codes; not to be the subject of a decision recovering State aid; not to be in insolvency, with tax debts or with final convictions for fraud or conflict of interest; and not to be a religious institution or a political party. That whole article has been repealed.
Article 8(2) did the same for partners, with an almost identical list of conditions and a slightly wider set of CAEN codes. It too has been repealed. What remains standing is paragraph (1), which allows partnerships with entities in Romania and requires the cumulation rules to be analysed for all partners, and paragraph (3), which obliges „partenerilor eligibili”, eligible partners, to complete the declaration on the type and category of undertaking, set out in Annex no. 1 to the scheme.
What it changes in practice
From 24 September 2026, future calls under the scheme are launched without the scheme itself saying who may apply. Article 4(1) continues to provide that the scheme applies to „solicitanților eligibili, așa cum sunt aceștia definiți în cadrul acesteia”, to eligible applicants as defined within it, and Article 6(2) continues to require eligible applicants to complete the declaration in Annex no. 1. Both refer to a text that no longer exists.
The effect carries further, to the subject matter of the project. Article 9(1) requires the objectives and activities funded to be carried out „în sectoarele culturale și creative prevăzute la art. 6 lit. b)”, in the cultural and creative sectors provided for in Article 6(b), that is, in the list that contained architecture, libraries, museums, cinema, multimedia, tangible and intangible cultural heritage, design, festivals, music, literature, the performing arts, books and the visual arts. That list sat in the repealed paragraph, so the eligibility condition for the activity has been left without content.
Procedures under way are protected. Article II says that selection procedures under way on the date of publication remain subject to the legal provisions in force when they started. Calls launched before 24 September 2026 therefore keep both the old eligibility conditions and the implementation deadline of 5 November. Anyone applying in such a call does not gain the extra month.
What remains untouched is the scheme’s financial architecture. The total budget is 7,342,868 euro, or 37,431,004 lei at the April 2026 InforEuro rate of 5.0976 lei to the euro, and checking the multiplication comes out exactly. The money comes from the State budget, through the budget of the Ministry of Culture, within the 2026 allocation and the estimates for 2027 to 2029. Contracts are signed by 30 September 2029 at the latest, payments are made by 31 December 2029, and the scheme covers at most 15 calls for projects. The aid intensity is up to 80% of the eligible expenditure, the rest being cash co-financing by the beneficiary. Submission, evaluation and contracting are carried out exclusively through the SDFC platform at fonduri-cultura.ro.
What has changed compared with the previous situation
Compared with the version published on 3 July 2026, the scheme loses two blocks of text and gains a month. The date of 5 November had probably been chosen to leave time for the final report and the payment of the last instalment before the budget year closed. Moving it to 5 December shortens that margin to 26 days, in a scheme where the aid is granted „de regulă în cel mult două tranșe”, as a rule in no more than two instalments. The gain for the festival organiser or the publishing house submitting a project is real: an extra month means that a late-autumn event fits inside the implementation period without being moved.
The loss is of another kind. The eligibility conditions were not mere formalities: they contained the two-year standing filter, which excluded organisations set up specially for a call, the list of cultural and creative sectors, which defined what a cultural project means for the purposes of the scheme, and the public-policy prohibitions, that is, political parties, religious institutions, companies in insolvency, those with tax debts and those finally convicted of fraud or money laundering. All of that disappeared at once, through two lines of text.
The Applicant’s Guide cannot fill the gap on its own. The scheme mentions it seven times and leaves it the grids for administrative and eligibility assessment, but a guide approved by the provider is subordinate to the scheme cleared by the Competition Council, and cannot supplement it with criteria the scheme no longer contains. The Competition Council’s favourable opinion for this amendment bears the number 14.272 and the date of 7 September 2026, and the one for the original scheme the number 9.602 and the date of 9 June 2026.
Advantages and disadvantages
What it improves
- The 30 extra days move the implementation deadline from 5 November to 5 December, so they cover the late-autumn events that used to fall outside the eligible period.
- The filter of two years’ standing since establishment, removed along with Article 6(1), was the most criticised condition of the scheme, because it shut the door on newly formed cultural collectives and organisations.
- Selection procedures under way remain subject to the rules in force when they started, so nobody loses an application lodged under different conditions.
- The rest of the scheme, that is, the budget of 7,342,868 euro, the grant of between 10,000 and 100,000 euro, the intensity of 80% and the de minimis ceiling of 300,000 euro, remains unchanged and predictable until 2029.
What remains a problem
- The scheme is left with no definition of the eligible beneficiary, even though two articles that were not touched continue to refer to it.
- Partnerships remain permitted, but without categories of eligible partners, in a scheme where the cumulation rules have to be analysed for each partner.
- The condition that activities be carried out in the cultural and creative sectors listed has been left without a list, because the list sat in the repealed paragraph.
- The prohibitions on political parties, religious institutions and companies in insolvency or with tax debts have disappeared from the scheme, although they were not optional: it is part of the de minimis aid regime that the beneficiary must not be under a decision recovering incompatible aid.
- Moving the deadline to 5 December leaves only 26 days between the end of activities and the end of the year, for reporting, verification and payment of the last instalment.
Practical advice
- First check which call you are in. If the selection procedure was already under way on 24 September 2026, Article II keeps the old rules, including the deadline of 5 November. The new deadline applies to calls launched after that date.
- Do not assume the standing filter has gone for good. Future calls may reintroduce the condition through the Applicant’s Guide or through another amendment to the scheme, and planning an application on the basis of its absence is risky.
- Work out your de minimis ceiling before you apply. The limit is 300,000 euro per undertaking or single undertaking, over any three-year period assessed on a rolling basis, not over completed tax years. The declaration is made on your own responsibility, under Annex no. 2 to the scheme.
- If you apply in partnership, keep the documents that showed, under the old Article 8(2), that the partner met the conditions. Paragraph (3) still requires the declaration on the type and category of undertaking, and the cumulation analysis remains compulsory for all partners.
- Get the cash co-financing ready. The intensity is up to 80% of the eligible expenditure, and the rest is provided by the beneficiary, in money, not as an in-kind contribution.
- Plan the activities so that reporting does not fall in the last days of the year. With the deadline moved to 5 December, the final instalment has to pass through verification and payment in a window of under four weeks.
Frequently asked questions
What is the new implementation deadline?
Does the new deadline apply to projects already submitted?
Who can still apply for funding after this amendment?
How much can be received for a project?
What is the de minimis ceiling?
How long does the scheme run?
Errors and inconsistencies in the published text
- The repeal of Article 6(1) leaves the scheme with no definition of the eligible beneficiary, although two unamended texts continue to refer to it. Article 4(1) provides that the scheme applies to „solicitanților eligibili, așa cum sunt aceștia definiți în cadrul acesteia”, to eligible applicants as defined within it, and Article 6(2), the only part of Article 6 left, requires „solicitanților eligibili”, eligible applicants, to complete the declaration in Annex no. 1. The repealed paragraph was the only place in the scheme where those applicants were defined. After the amendment, it can no longer be established who falls under the scheme and who does not, even though the scheme keeps its budget, its ceilings and its application procedure.
- Article 9(1) makes the eligibility of activities depend on a reference that has been left with no target. The text requires the objectives and activities of projects to be carried out „în sectoarele culturale și creative prevăzute la art. 6 lit. b)”, in the cultural and creative sectors provided for in Article 6(b). That list, from architecture to the visual arts, sat in Article 6(1)(b), repealed by this order. The reference was already imprecise in the July 2026 version, because it gave the letter without giving the paragraph, but the target existed then. Now there is none at all, and the condition Article 9 imposes can no longer be verified.
- The repeal of Article 8(2) removes the categories of eligible partner but leaves partnerships and their obligations in force. Paragraph (1) still allows implementation in partnership with entities in Romania and requires the cumulation rules to be analysed for all partners. Paragraph (3) requires „partenerilor eligibili”, eligible partners, to provide the declaration on the type and category of undertaking. Nothing in the scheme says any longer what an eligible partner is, even though both the admissibility of the project and the calculation of the de minimis ceiling for each entity depend on that status.
Editorial analysis
The change of deadline is well judged and solves a problem the sector had been flagging: 5 November cut out of the calendar precisely the months in which the seasons, the autumn festivals and the book launches are concentrated. An extra month costs nothing in budget terms and genuinely changes which projects can be proposed. Had the order stopped there, it would have been a clean intervention.
The problem is that the repeals were not accompanied by replacements. An act that removes from the scheme the definition of the eligible beneficiary and that of the eligible partner, yet leaves untouched the three articles that refer to them, produces a scheme that can no longer be applied in the form published. The most likely explanation is that the requirements were to move into the Applicant’s Guide, and that would be a real administrative relief: the criteria could then be adjusted from one call to the next without going through the Competition Council each time. Except that a guide approved by the provider cannot create conditions the cleared scheme does not provide for, and Article 24 of the scheme leaves the guide the assessment grids, not the substantive criteria.
The second point shows up only with a calculator. The scheme fixes, in Article 10, a maximum estimated number of 1,470 beneficiaries, and in Article 11 a budget of 7,342,868 euro. Dividing gives 4,995 euro per beneficiary, that is, under half the minimum grant of 10,000 euro imposed by Article 20. Conversely, 1,470 beneficiaries at the minimum grant would require 14,700,000 euro, exactly twice the budget. At the minimum grant, the scheme can fund 734 projects; at the maximum, 73. The figure of 1,470 is not impossible only if the average grant were to fall below the scheme’s own minimum, which cannot happen. The present order touches neither of the two figures, although it amends the very chapters around them.
The third observation is an inheritance from July that the order had a chance to repair. Article 25(3) of the scheme allows cumulation with aid granted under Regulations (EU) no. 1408/2013 and no. 717/2014, „în limita plafonului relevant de 300.000 euro acordați în ultimii 3 ani”, within the relevant ceiling of 300,000 euro granted over the last 3 years. Those two regulations are the agricultural one and the one for fisheries and aquaculture, and their own ceilings are 50,000 euro and 30,000 euro over three years respectively, not 300,000. A beneficiary who also has an agricultural activity and reads the scheme as it is written can exceed the sectoral ceiling without realising it, and the consequence is recovery of the aid with interest.
What should be changed
- Reintroducing a minimum definition of the eligible beneficiary and of the eligible partner, directly in the scheme. The thirteen previous conditions are not needed; the legal categories, the cultural and creative sectors and the prohibitions imposed by the de minimis aid regime in any event are enough. Without them, the first call launched after 24 September 2026 will be open to challenge by anyone rejected, because the ground for rejection is not in the legal act.
- Correcting the reference in Article 9(1). The list of cultural and creative sectors needs a place of its own in the scheme, for instance in Article 5, which contains the definitions anyway. That way it survives any rewriting of the chapter on beneficiaries, and the eligibility condition for the activity remains verifiable.
- Reconciling Article 10 with Article 20. Either the estimated number of beneficiaries comes down to the order of magnitude the budget allows, that is, below 735, or the minimum grant falls. The present figure, 1,470, appears in the public communication of the scheme and creates an expectation the money allocated cannot meet.
- Putting right the ceilings in Article 25(3). The text should say that the relevant ceiling is the one laid down by each regulation separately, not 300,000 euro for all of them. The practical effect: a beneficiary with mixed activity, cultural and agricultural, would know that the limit on the agricultural side is much lower.
- A transitional rule clearer than Article II. The formula „selection procedures under way” does not say whether a procedure begins when the call is published, when submissions open or when the first application is lodged. In a scheme with up to 15 calls, some of them with rolling submission, the exact moment decides which set of rules applies to each applicant.
Original text of the legal act
The text below is reproduced in Romanian, the official form of publication.
The full text, as published in the Official Gazette of Romania
Official Gazette of Romania no. 814 of 24 September 2026 16 pages PDF, 103 KB the act starts on page 5
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This article is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed attorney or tax advisor.