Champions of Change: Inside the State Aid Peer2Peer Community's Journey to Excellence 

In this issue of REGIO Peer2Peer Communities newsletter, we would like to invite you to a conversation with the Champions from the State Aid Peer2Peer Community. The interview highlights the role of Community Champions and the achievements of the Community and encourages more practitioners to join Peer2Peer efforts. 

The State Aid Community was established back in 2016 with the primary aim to facilitate the exchange of State Aid knowledge and procedures established within national environments of various EU Member States. In 2019, the Community focused on creating 'State Aid maps' for various sectors including R&D, energy, and transport. Those maps were designed to help practitioners navigate the complexities of State Aid regulations in these specific areas. The Community was particularly active during the COVID-19 pandemic outbreak in 2020 and the Russian invasion in Ukraine in 2022. During this period, there was significant knowledge sharing on State Aid temporary frameworks, which were crucial in addressing the challenges posed by those crises. Recent reflections within the Community have focused on State Aid in the context of European Structural and Investment Funds (ESIF) simplification rules, State Aid and its application within the Green Deal and the transport sector.

Currently there are five Community Champions: Palma Muñoz Morquilla (Andalucia TRADE, Spain); Liezelotte Deschryvere (Agency for Innovation & Entrepreneurship, Belgium); Liga Grantina (Central Finance and Contracting Agency, Latvia); Stefan Jarecki (Ministry of Funds and Regional Policy, Poland); and Zoe Georgopoulou (Ministry of National Economy and Finance, Greece), supported by Community Manager, Zuzana Palkechova, and Junior Community Manager, Martin Kertes from PwC. 

Achievements and Impact 

Zuzanna Palkechova (ZP), Martin Kertes (MK): What motivated you to become a Community Champion, and what do you find most rewarding about this role? 

Palma Muñoz Morquilla (PMM): The Communities’ idea was love at first sight for me. 

In January 2016, I was invited to an initial meeting with JRC officers in Brussels who were designing the REGIO Peer2Peer Communities as an experimental project. I loved the idea immediately. My first thought was: "You are not alone." It was a perfect match! I realized then that I now can channel my energy, expertise, and passion into co-creation of something new and thinking outside the box. Meeting experts from various EU countries, who shared the same doubts and concerns and were willing to collaborate for the benefit of our organizations, companies, and Europe was incredibly inspiring! 

Liezelotte Deschryvere (LD): In 2018, I was actively seeking more information on the correct implementation of State Aid regulations in ERDF investments. By chance, I discovered a small network that was focused precisely on what I was looking for - a 'happy' coincidence.  

I immediately engaged with the first Community Manager and advocate of peer collaboration, Marceline Bonneau, who encouraged me to organize an event in Brussels and include items on the agenda that I had been struggling with for a long time. Since then, I have hosted two more State Aid Community events in Brussels. 

The exchange of knowledge with many interesting European colleagues has been very rewarding, both on a professional and personal level. 

Stefan Jarecki (SJ): My motivation stemmed from a desire to find answers to specific State Aid related questions and to engage with peers facing similar challenges. The reward was the development of innovative solutions to complex State Aid cases, supported by collaboration with esteemed experts and practitioners in the field. 

Zoe Georgopoulou (ZG): I initially got involved in the Community activities to help clear up some specific issues around the application of State Aid in Structural Funds. How reassuring it was to realize that many colleagues in different Member States had the same questions, problems, and concerns! 

Liga Grantina (LG): I first joined the State Aid community at the end of 2019. At that time, I was seeking advice and insights on how other Member States handle State Aid issues. I discovered that the challenges are quite similar across the Member States, which encouraged me to initiate discussions and share expertise with other experts.

ZP, MK: Since the inception of the State Aid Community in 2016, what do you consider the most significant achievements?

PMM: We've made remarkable strides since 2016. The synergies with TAIEX have been instrumental, providing the financial support needed for in-person meetings and offering robust tools to facilitate peer exchanges. 

The COVID-19 pandemic, surprisingly, opened up new opportunities for us. It was the first time we could hold online meetings with officers from DG REGIO and DG COMP. This allowed us to share our doubts and issues regarding the implementation of the State Aid Temporary Framework in real-time. 

It's incredibly important to have officers from both DGs involved in State Aid issues - DG COMP and, when co-funded with ESIF, DG REGIO - sitting at the same table with State Aid practitioners on the ground. This setup has proven to be a win-win situation for everyone. Both the European Commission (EC) and the practitioners benefited immensely from the exchange of experiences and knowledge. 

ZG: I agree. The discussions on provisions of the new General Block Exemption Regulation (GBER) and the presentation by DG COMP on the energy sector in 2022 in Brussels were important. 

SJ: From my perspective the most significant achievement was definitely the development of State Aid maps for the R&D, energy, and transport sectors, extensive discussions on the new GBER provisions, and the formulation of a proposal for a special clause that permits an increase in State Aid amounts without undermining the incentive effect. 

LG: I agree. During the meeting in Brussels, we discussed the incentive effect with representatives from DG COMP and DG REGIO. When two different concepts interact and theory meets practice, the Community was able to develop a clause to be used in contracts that satisfied the requirements set out in both State Aid and ESIF rules.  

LD: The establishment of an ever-growing State Aid network of European peers is quite an achievement! Do not forget that we all come from diverse backgrounds (law, economy, etc.) and different agencies or bodies (Managing Authorities, Audit) working at various levels (national, regional). We are all drawn to this network by a shared eagerness to find answers to sometimes very challenging judicial contradictions (DG REGIO versus DG COMP) and to gain better knowledge about the concrete implementation of State Aid regulations. There is a huge willingness to cooperate on common topics related to State Aid in structural funds, which is a very specialized field of knowledge. 

ZP, MK: Can you share some specific examples of how the Community has positively impacted State Aid practices in your country or region? 

PPM: Discussions on the interpretation of the incentive effect have provided us in Spain with new insights to better defend our cases before national courts of justice. 

SJ: In Poland, there have been instances where beneficiaries were unable to implement projects without an increase in the amount of aid. However, such increases were often infeasible due to the requirements concerning the incentive effect. This issue became significant following the outbreak of the COVID-19 pandemic and the Russian invasion of Ukraine, both of which led to a dramatic rise in energy and raw material prices and, consequently, an unpredictable increase in the implementation costs of many projects co-financed by public authorities. The State Aid Peer2Peer Community proposed a measure to prevent similar problems in the future. The measure includes a special clause addressing the incentive effect. Polish authorities plan to implement these solutions under the 2021-2027 financial perspective. 

ZG: After the 2022 meeting with DG REGIO and DG COMP we managed to finalize a specific scheme in Greece under GBER for companies looking to improve their energy consumption and efficiency. We used a competitive process based on the clarifications provided during the meeting, which allowed us to achieve the maximum aid intensity. 

LG: From Latvian perspective discussions on the correct interpretation of the definition of dedicated infrastructure and sharing experiences on how to identify dedicated infrastructure in practice were based on explanations published on E-WIKI and recent EC opinions. There were also discussions on ancillary activities, sharing challenges from both a material scope and procedural perspective. For instance, issues such as the excessive monitoring period and the lack of resources to address small-scale irregularities were highlighted. 

LD: In Belgium, besides the very specific knowledge on interpretation questions on e.g. articles in the GBER we share, there is a very interesting exchange on management procedures, how to gather specific proof, and how to deal with audit findings. 

Community Engagement and Development 

ZP, MK - What strategies have been most effective in increasing Community engagement and participation? 

SJ: Definitely in-person meetings because they enable discussion of complex issues between the Community Members and EC representatives. 

ZG: I agree. The meeting I mentioned earlier, which included representatives of DG COMP, facilitated productive discussions among the participants.  

PMM: I can only echo Zoe and Stefan: the most fruitful participation comes from physical, in-person meetings. State Aid issues are usually complex, and discussions between the Community Members and EC representatives yield the best outcomes and results. Moreover, the networking and exchanges that occur after the formal meetings provide the highest value for participants. 

LD: The very pertinent topics we have put on the agenda so far address questions that are not easily answered through online resources or private State Aid courses.  

I agree that in-person meetings allow us to share 'off the record' good practices, audit reports, and outcomes of exchanges directly with the EC, which can sometimes shed new light on 'old' problems we are confronted with. 

ZP, MK: What are some of the challenges you face as a Community Champion, and how do you overcome them? 

LD: There is always the daily business that already takes up most of our time, but I learned that the time you invest in this network might save you time later down the line. "The key is in not spending time, but in investing it." 

PMM: The most difficult part for me continues to prove to a wider audience, including my supervisors, the benefits we get from me participating in these activities.  

What I do besides explaining the benefits for my organization is to provide innovative solutions thanks to my involvement in the State Aid Community. Moreover, I managed to invite my colleagues from different units dealing with State Aid issues to the online State Aid Community meetings and last, but not least, engaged them when organising an onsite meeting in Seville. 

ZG: For me the biggest challenge is the lack of time to fully participate in the Community’s activities. 

LG: For me the challenge is that the auditing authority also works and participates in the discussions of the Community. It is not always rational for intermediate bodies to share their challenges with the auditing authority. 😊

Future Directions and Opportunities

ZP, MK - What are the key topics and areas of focus for the State Aid Community in the coming months?

PMM: The members of the State Aid P2P Community have pinpointed several key topics of interest. Foremost among these are the development of simplification measures and the application of State Aid within the framework of the Green Deal.

SJ: Looking ahead, other significant areas of focus include the assessment of the stimulation effect and its interpretation within State Aid rules, State Aid for the transport sector, and the utilization of financial instruments. 

Additional areas of interest, as identified through the survey among the Community Members, encompass audit and compliance in EU-funded programs and individual case law, including decisions on the non-existence of State Aid. 

LD: First and foremost, since preparations for the new period post-2027 have already started, it is crucial to establish a link between our State Aid P2P Community and the Working Group on Simplified Cost Options (SCOs) at the DG REGIO level (SCO WG). We learned from the last programming period that exchange between Managing Authorities and SCO WG is crucial to ensure that everybody is aware of the potential implications.  

Many ERDF Managing Authorities are investing in green infrastructure. The revised GBER regulation of July 2023 includes revised articles that are adapted to the Green Deal investments in the EU but at the same time clarification on many aspects of those articles is still lacking (also in the E-WIKI). Our network could (partly) fill that gap or jointly define the missing parts. 

We shall also continue to exchange specific national audit findings in relation to State Aid. 

ZP, MK: How do you plan to address the identified issues and legal uncertainties? 

SJ: We suggest strengthening our Community's initiatives by arranging meetings that bring together Community Members with representatives from both DG COMP and DG REGIO.  

ZG: Exactly! We shall also consistently approach them with well-founded proposals on behalf of the Community. 

PMM: As I mentioned before, it's a win-win situation to have all parties involved - us, the Member States practitioners and Commission services - sitting around the same table. 

LD: Yes, we should keep both DG REGIO and DG COMP jointly involved in the work of our network by presenting our findings to them. Additionally, we need to invite them to participate in person when we have specific topics to discuss. 

ZP, MK: What opportunities do you see for new members to contribute to the Community, and how can they get involved? 

SJ: Their participation will introduce new questions and experiences to the Community, fostering growth and development. 

LD: To bring in new concrete problems or issues they have been confronted with and possibly new ideas on how they tackled them. Or join a growing group of Member States that put things forward as a joined force to have our very specific voice - SF Managing Authorities - heard towards DG COMP. 

One very specific advantage is the fact that we have a better overview of what is going on in the different Member States, which is especially interesting on State Aid related topics in audit findings.

Personal Insights and Encouragement

ZP, MK: What advice would you give to someone considering joining the State Aid Community? 

SJ: Hop on immediately! You will find answers to many questions on State Aid and fascinating people who understand your problems and will support you. 

ZG: Participation is crucial, as many officers involved in the application of Structural Funds are not very familiar with State Aid rules and restrictions. 

PMM: The Community is open and inclusive, allowing anyone to join at any time. You can bring your topics for further discussion or listen to the challenges that peers from other Member States have identified. 

LD: Just do it (no promotion of any particular sneakers’ brand 😊)

ZP, MK: Can you share a memorable experience or success story from your time as a Community Champion? 

SJ: The most memorable moments were the inspiring brainstorming sessions that led to the creation of the proposal for the special clause on the incentive effect and the development of State Aid maps. I always look at these maps when assessing projects in terms of State Aid. They are indispensable references for me! 

LG: It was very helpful to initiate a discussion with peers when CFCA faced a lot of issues regarding application of art.56 GBER and beneficiaries were not happy with our national approach and were asking for experience from other Member States. So, I brought this topic to the Community, gave a short presentation to introduce the cases with other practitioners, highlighted the issue and organized a discussion round with other experts in order to exchange experiences with other Member States. I returned home with a lot of ideas for further incorporation in our internal procedures and improvement. It was a productive and inspiring discussion.  

LD: We had an in-person meeting with representatives from DG COMP. This meeting provided us with a clearer understanding of how they handle specific investment projects and their interpretations. They mentioned that the face-to-face session also helped them gain a better insight into the implementation challenges related to certain GBER articles from the Managing Authority perspective. 

PMM: I have made various presentations at the European Week of Regions and Cities to raise awareness about the project. Additionally, I was involved in co-development of State Aid maps, including those for RDI, transport, and energy. 

ZP, MK: How do you balance your professional responsibilities with your role as a Community Champion, and what keeps you motivated? 

SJ: It is not easy. I am motivated by the opportunity to meet fascinating people, discuss with them, and solve complicated problems together. 

ZG: Although daily work is demanding, participating in the Community provides us with valuable opportunities for fruitful discussions and brainstorming. 

PMM: I always have a lot of work at the office and for the supervisors of the organization. It can sometimes be challenging to have the time and space I would love to dedicate to the State Aid Community. Despite these difficulties, I persist in explaining the benefits and continue working on this initiative because I am a strong believer in it. 

LD: My passion for bringing people together and fostering cooperation, combined with the direct relevance to my job (providing State Aid advice specifically applied to the European Fund for Regional Development investments), makes my participation feel less like 'work' in the traditional sense of the word. 

I am truly passionate about this highly successful network, which today includes around 90 participants in both online and in-person meetings and represents over half of the EU Member States, all engaged on a voluntary basis. 

About interviewees:

Palma Muñoz Morquilla is an International State Aid Expert. Since February 2024, she has been a Senior EU and Public Lawyer at Andalucia TRADE, the Business Agency for Economic Transformation and Development of the regional Government of Andalusia. She is pursuing a PhD in State Aid Law at the University of Seville and is a board member of the European Movement in Andalusia and the Cohesion Alliance.

She has 30 years of experience as a Legal Expert in State Aid Law for the Intermediate Body of the Andalusian Global Grant. She was the first woman appointed as Director of the Legal Service of the regional development Agency of Andalusia, managing a team of 15 for six years. She resigned in 2015 to focus on her passion for EU and State Aid Law. In 2016, Palma became the first champion on State Aid to participate in the Policy Lab of DG REGIO. As a pioneer of the State Aid Community, she has been invited to several European Week and Regions editions in Brussels and co-organized three Multi-country State Aid Community meetings in Seville. In 2022-2023, she participated in a DG REGIO study to improve support for practitioners managing European Funds.

Stefan Akira Jarecki is a professor at the Faculty of Administration and Social Sciences at Warsaw University of Technology and a lecturer at the Lech Kaczyński National School of Public Administration. He is a member of the Association of Communication Engineers and Technicians of the Republic of Poland and participates in the Warsaw Seminar on the Axiology of Administration. He also serves on the scientific council of the ProKolej Foundation. Stefan is an expert in State Aid and transport regulation, providing legal services for EU fund implementation in transport projects. He has represented Polish authorities before the European Commission on State Aid issues. Additionally, he is an internal trainer for a central government office and an accomplished author and speaker at various conferences and training courses, both domestically and internationally.

Zoe Georgopoulou is the General Director of Institutional & Operational Support at the National Coordination Authority. She holds an MSc in Environmental Engineering and a PhD in Law, specializing in State Aid and the GBER application. An expert in state aid and financial engineering, she is a member of various working groups and investment boards related to state aid and structural funds. Zoe collaborates with the EIB group on financial instruments and played a key role in establishing and expanding the National Promotional Bank of Greece. She developed the Greek de minimis registry and the ESIF Management Information System for State Aid. Speaker at the National Centre for Public Administration and Local Government of Greece, the European Institute of Public Administration, and various conferences and training courses both domestically and internationally.

Liga Grantina serves as the Head of the State Aid Division within the Project Selection Department at the Central Finance and Contracting Agency (CFCA) in Latvia. The CFCA operates as an intermediary body for the European Structural and Investment Funds (ESIF), with a wide range of responsibilities including project selection, contracting, making payments, and ensuring management verifications throughout the project cycle. Liga has a legal background and holds a master's degree in law. She has gained extensive knowledge by attending specialized international courses. As an experienced expert in state aid and internal training, Liga has recently begun teaching courses on state aid for public administration in Latvia.

Liezelotte DESCHRYVERE, State aid advisor to the ERDF Managing Authority, Flemish Agency for Innovation and Entrepreneurship, Belgium. More than 20 years of structural funds experience (both ESF+, ERDF, Interreg North West Europe).

About interviewers: 

Zuzana Palkechova - Zuzana works for PwC and has over 12 years of experience, currently leading EU Funding and State Aid practice in Slovakia. She specializes in EU legislation, particularly state aid, and manages large-scale investment and R&D projects, including IPCEI initiatives, for clients across Slovakia, Poland, and the Czech Republic. Zuzana has knowledge of Cohesion policy and has worked with various European clients, including DG REFORM, DG REGIO, etc. Zuzana has prepared feasibility studies and compliance methodologies for R&D infrastructure; advised the Slovak Authorities on Recovery Resilience Plan & IPCEI Hydrogen projects for the Slovak Authority. 

Martin Kertes - Martin is a Senior State Aid Consultant in Slovakia with over 8 years of experience in managing and deploying EU and national funding projects. His expertise includes Cohesion policy and programs directly managed by the European Commission. Notable projects include preparing and leading a project within the CEF Digital; Martin has also managed Regional Investment Aid projects, focusing on grant application and projects implementation. Additionally, he is skilled in assessing expenditure eligibility, performing financial checks on Payment Requests, and processing payments through the ITMS system, which manages EU projects from inception to implementation in Slovakia.