TL;DR
When applying for Malta Enterprise grants like Digitalise Your SME, you'll encounter two state aid routes: De Minimis (for established SMEs) and GBER (for start-ups under 5 years old). The route you take affects your aid intensity, how much you get upfront, and cumulation limits. Most applicants don't get to choose. Your business profile determines which route applies.
If you've started looking into the Digitalise Your SME grant, you've probably come across references to "De Minimis" and "GBER" without much explanation of what either means. The official documentation assumes you already know. Most applicants don't.
These two terms refer to the legal framework under which your grant is approved. The one that applies to you will affect your aid intensity, your payment schedule, and how much total state aid you can receive across all government schemes. It's worth understanding before you apply.
What is State Aid?
State aid is any financial support from government or EU funds that gives a business an advantage over competitors. It's regulated at the EU level to prevent unfair competition between member states. When you receive a Malta Enterprise grant, you're receiving state aid, and the EU has rules about how much any single business can get.
Two main frameworks govern this: De Minimis and the General Block Exemption Regulation (GBER). Think of them as two different legal tracks under which your grant can be approved, each with its own rules and limits.
The Two Routes
De Minimis
De Minimis is Latin for "about minimal things." The concept is straightforward: small amounts of state aid are unlikely to distort competition, so they're permitted with fewer restrictions.
Under De Minimis rules, a business can receive up to EUR 300,000 in total state aid over any rolling three-year period. This cap applies across all sources, not just Malta Enterprise. If you received EUR 50,000 from another government scheme last year under De Minimis rules, that counts against your cap.
This is the default route for most established SMEs applying for grants like Digitalise Your SME. If your business has been operating for more than five years, or if you've distributed profits, De Minimis is almost certainly your path.
GBER (General Block Exemption Regulation)
GBER is a broader EU regulation that pre-approves certain categories of state aid without requiring individual notification to the European Commission. It covers everything from regional development to research grants.
For Malta Enterprise grants, GBER matters because of Article 22, which deals specifically with start-up aid. If your business qualifies as a "start-up undertaking," you access a different, generally more favourable set of rules.
To qualify under GBER Article 22, your business must be:
- An unlisted small enterprise
- Up to 5 years from registration
- Has not yet distributed profits
- Has not taken over another enterprise's activity
- Was not formed through a merger (with minor exceptions)
All five criteria must apply. If any one doesn't, you default to De Minimis.
How This Affects Your Grant
The differences between the two routes are practical, not just legal. Here's what actually changes when you apply for Digitalise Your SME.
Aid Intensity
Aid intensity is the percentage of your eligible project costs that the grant covers. Both routes start at the same base: 50% for Malta-based businesses, 60% for Gozo.
Where they differ is the start-up bonus. GBER applicants receive an automatic +10% increase to their aid intensity. De Minimis applicants don't qualify for this.
Both routes can access the same additional bonuses: +10% for projects involving advanced technology (AI, IoT, cloud, cybersecurity, big data, or quantum computing, assessed by MDIA), and +5% for projects that measurably improve your business's digital intensity level (assessed by Malta Enterprise).
The practical result: a Malta-based GBER applicant can reach up to 80% aid intensity, compared to 70% for De Minimis. For Gozo, the theoretical maximums are 85% and 80% respectively.
Aid Intensity Comparison
| Bonus | De Minimis | GBER (Start-up) |
|---|---|---|
| Base rate (Malta) | 50% | 50% |
| Base rate (Gozo) | 60% | 60% |
| Start-up bonus | Not available | +10% |
| Advanced tech (MDIA) | +10% | +10% |
| Digital improvement | +5% | +5% |
| Maximum (Malta) | 70% | 80% |
| Maximum (Gozo) | 80% | 85% |
Payment Timing
This is where the difference hits your cash flow.
Under De Minimis, you receive 50% of the flat-rate amount (the 7% indirect costs portion) when you sign your grant agreement. Under GBER, you receive 100% of that flat-rate amount upfront.
The interim payment caps also differ. De Minimis applicants can receive up to 60-70% of the total grant value by the time their system is delivered and operational. GBER applicants can reach 70-80%. In both cases, the remaining balance is paid after final verification.
For start-ups where every euro matters, that difference in upfront cash is significant.
Payment Structure Comparison
| Payment Stage | De Minimis | GBER (Start-up) |
|---|---|---|
| Flat rate at signing | 50% | 100% |
| Interim cap at delivery | 60-70% | 70-80% |
| Final balance | After verification | After verification |
Cumulation Limits
This is the most important structural difference between the two routes.
De Minimis has a hard cap: EUR 300,000 in total de minimis aid over any rolling three-year period. Every de minimis grant you've received from any source counts toward this. If you're an established business that has already benefited from other government support schemes, you might find your available headroom is smaller than expected.
GBER doesn't have this fixed cap. It has its own cumulation rules under Article 8, which are more complex but generally more generous for individual projects. Aid intensity caps apply per project rather than across all support received.
Which Route Applies to You?
Most applicants don't actually get to choose. Your business profile determines your route.
You'll use De Minimis if your business is older than five years, has distributed profits at any point, was formed through a merger or acquisition, or doesn't meet the GBER start-up definition for any other reason. This covers the majority of applicants.
You'll use GBER if you meet all five criteria of a start-up undertaking under Article 22. The Business START grant, for instance, operates exclusively under GBER since it's designed for early-stage businesses.
Malta Enterprise assesses your eligibility based on your application. You don't need to declare a preference upfront, but understanding which route applies helps you estimate a realistic aid intensity and plan your project budget accordingly.
If you're on the boundary (say, your business is approaching its fifth year), talk to a grant consultant before applying. The registration date, not the date you started trading, is what typically matters.
Common Questions
Does the state aid route affect what I can spend the grant on?
No. Both routes cover the same eligible costs under the Digitalise Your SME scheme. The route affects how much of those costs are covered and when you get paid, not what qualifies as an eligible expense.
What if my business is exactly 5 years old?
The GBER definition says "up to 5 years following its registration." If you're right on the boundary, Malta Enterprise will assess based on your exact registration date. Don't assume, check.
Can I receive both De Minimis and GBER aid at the same time?
You can receive aid under both frameworks for different projects, but cumulation rules apply. You can't receive both types for the same project. Each project follows its own route and rules.
I've already received De Minimis aid from another source. Does this affect my Digitalise Your SME application?
If you're going the De Minimis route, yes. All de minimis aid counts toward the EUR 300,000 rolling cap. You'll need to declare previous aid in your application. If you're close to the limit, it could reduce the grant amount available to you. GBER applicants aren't affected by this cap.
Next Steps
Understanding which state aid route applies to your business is one of the first practical steps in planning a grant application. For practical advice on structuring your application, see our guide to writing a strong investment proposal.
If you're considering the Digitalise Your SME scheme for a software or digital transformation project, we provide all technical documentation, specifications, and quotes needed for your application.
For early-stage businesses, the Business START grant provides up to EUR 10,000 for qualifying start-ups and operates under GBER.
