NOTE
Danish response to the Commission’s invitation to comment on the re-
vised Guidelines on State aid to promote risk finance investments
The Danish government appreciates the opportunity to comment on the Eu-
ropean Commission’s draft Guidelines on State aid to promote risk finance
investments. In general, the Danish Government is positive towards the in-
creased readability of the guidelines as well as the streamlining of content
and the alignment of definitions.
The Danish Government would like to emphasize that state aid should al-
ways address a market failure. The ex ante assessment of demonstrating a
specific market failure should therefore always be required when notifying
a scheme to promote risk finance investments which do not satisfy all the
conditions laid down in the General Block Exemption Regulation (GBER).
However, the administrative burden connected to the documentation of this
market failure should be proportionate to the amounts of aid granted. The
Danish Government therefore supports the European Commission’s sug-
gestion to remove the requirement to quantify the funding gap for risk fi-
nance investments not exceeding the GBER threshold of EUR 15 million
per eligible undertaking.