NOTE
17. maj 2021
2021 - 7904
miy
Danish response to the Commission’s invitation to comment on revised
Framework for State aid for research and development and innovation
The Danish government appreciates the opportunity to comment on the Eu-
ropean Commission’s draft Framework for State aid for research and de-
velopment and innovation (R&D&I Framework).
In general, the Danish Government is positive towards the draft R&D&I
Framework. We find that the three focus points and connected revisions
will make it easier to use and improve the framework. Overall, we find that
the revision and the three focus points will help stimulate more research,
development, and innovation within the EU.
However, the Danish Government does have some concerns regarding the
aid intensities and the transparency threshold. We elaborate below.
Specific comments
Aid intensities for technological infrastructures
The Danish Government understands the logic behind having higher aid
intensities for research activities than for technology infrastructures since
research activities are further from market. However, Research & Technol-
ogy Organizations (RTOs) may apply technological infrastructures for both
commercial and research purposes. It is important to ensure that the up-
dated Framework will help facilitate the development of technological in-
frastructures that may be used for both purposes
–
not least as part of our
collective efforts to ensure green transition.
Therefore, the Danish Government suggests that the Framework allows for
a differentiation of aid intensity in reference to a flexible, optimised usage
of technology infrastructures (e.g. in reference to TRL-levels). In our opin-
ion, this would help us to avoid that the Framework becomes a de facto
barrier for supporting technology infrastructures and for optimizing added
value.