FAQ – New subsidised loans

All instruments indicated in Circulars 3-4-5-6-7-8/394/2023

I have already applied for/obtained a Fondo 394 (Fund 394) loan in the past. Can I apply for a new one?

You can apply for several loans under Fund 394, up to the limit of exposure with the Fund of 35% of average revenues in the last two years, subject to de minimis ceiling availability, as specified in the operating circulars. The projects and expenses that may be funded must be different. In any case, all eligibility conditions indicated in section 2.2. of each Circular must be met, and so the business:

must not have defaulted on any other obligations undertaken with SIMEST in its capacity as operator of public funds, and must not be in any of the situations that require the Funding to be withdrawn;
must have returned all amounts subject to an order for total or partial withdrawal, or returned subsidised loans granted under Fund 394/81 or under co-funding.

N.B. If opening the account online, the account must be activated, as per the specific instructions of the reference bank (a bank transfer to the new account to activate it is usually required), in order to proceed with the disbursement.

What does exposure with Fund 394 mean?

Exposure with Fund 394, the Fondo Promozione Integrata (Integrated Promotion Fund) and the Fondo Crescita Sostenibile (Sustainable Growth Fund), with reference to all types of operations (including the National Recovery and Resilience Plan, Ukraine, Grants) is calculated, in order to determine the maximum amount that may be disbursed for new Subsidised loan applications, by adding:

the total amount of the Subsidised loans applied for and not yet approved, including the loan applied for which the calculation is made, and
the total amount of Subsidised loans granted and not yet repaid, net of the amount of any grants already consolidated.

What does “non-cumulative expenses covered by other public funding” mean? Are the new measures of Fund 394 cumulative with the Industria 4.0 (Industry 4.0) measure) and with the “Beni strumentali – nuova Sabatini” (Capital Goods – new Sabatini) measure?

The new measures of Fund 394 consist of de minimis financial support, for both the subsidised loan component and the co-funded grant component, for eligible costs specifically identified in the Operating Circulars.

The rules on cumulation set out in the applicable European regulation on state aid (see Article 5 of Regulation (EU) No 1407/2013 on de minimis aid), as well as specific national and EU provisions, in effect at any given time, that govern other public measures for which cumulation would occur and that indicate any limits or prohibitions on cumulation, apply.

Therefore, any additional limitations on the cumulation of new Fund 394 measures may arise from the circumstance that specific legal provisions, in effect at any given time, applicable to other aid measures with which cumulation would occur, establish limits for a prohibition on cumulation with other aid measures.

As regards the cumulation of new Fund 394 measures with tax receivables for investments in capital goods (Industry 4.0 tax incentives) – that do not constitute State aid as the measure is general by nature, as confirmed by the Italian Revenue Agency and by the Italian Ministry of Enterprises and Made in Italy MIMIT) – the specific provisions governing the Industry 4.0 measure apply.

In particular, the last part of paragraph 1059 of Italian Law 178/2020 (2021 Budget Law), as amended, currently establishes specifically that the tax receivable «is cumulative with other financial support concerning the same costs, on condition that this cumulation, also considering that it does not contribute to the formation of income and the tax base for regional business tax…, does not result in the incurred cost being exceeded». Basically, cumulation on the same eligible costs is permitted up to the ceiling represented by the cost incurred (see applicable regulations link). As regards cumulation with the aid of the Capital Goods – New Sabatini measure (consisting of State Aid under the General Block Exemption Regulation (GBER), point 8.8 of the Executive Circular of 6 December 2022, no. 410823 currently establishes that “Aid may be cumulated with any other State aid, in relation to the same eligible costs, partly or fully overlapping, only if such cumulation does not result in exceeding the highest aid intensity or aid amount applicable to this aid under exemption regulations applicable based on the activity carried out by the beneficiary business” (see the applicable regulation and the FAQs link)

Why is it possible to choose a subsidised rate which is 10%, 50% or 80% of the EU benchmark rate? Is it possible to know in advance how much of the loan I apply for will consist of the de minimis ceiling?

To find out about the benefits of opting for a subsidised rate and to access the calculator for the de minimis ceiling absorbed by the SIMEST loan, see the specific section.

Find out more

I haven’t submitted a loan application yet, but I have paid some expenses/already received an invoice for some expenses that I have not paid yet. Can I include them in the SIMEST loan?

No. Expenses are eligible only if invoiced and paid in the loan period, which runs from the date when the CUP (Unique Project Code) is received, which is issued during the loan review/approval.

As for environmental/sustainability certification criteria to access the grant, is it necessary to have all the certification indicated in the Circular (ISO 45001, ISO 14001, SA8000)?

No, just one of the types indicated is sufficient.

Is it possible to use a “QONTO” account as the loan current account?

No, because a Qonto is not a current account that can receive incoming transactions. It is a payment account.

Circular 4/394/2023 and the Digital Transition

I am an SME with an export turnover below 10% but above 3%. How can I demonstrate the SME is part of a chain (at least 2 client companies)?

You can submit at least 2 supply agreements with at least 2 client companies, stipulated at least 12 months before submitting the application. The 2 supply agreements (even if not the same) must be maintained in the reporting.

Circular 3/394/2023 and Entry on Markets

I if manage the programme through a local investee, who can incur the expenses?

In a programme managed through a local investee, the expenses may be incurred by the Italian business applying for the loan, or by the local investee proportional to the stake held by the Italian business.

The local investee can also re-invoice the Italian applicant company in full for expenses incurred.

The procedures to use the loan current account for these circumstances are explained in Annex 3 of Circular no. 3/394/2023.