FAQ – Operations in the NRRP (National Recovery and Resilience Plan

Expenses for goods or services, including machinery and plants, and any environmental impact assessments instrumental/functional to the development of the investment.  These expenses may also be financed provided they are directly related to the sustainability and ecological transition of the Applicant Company – based on the documentation to submit in the reporting, including supply agreements, statements made by suppliers, invoices and the Final Repot as per section 5.4 of the Circular – in terms, for example, of energy efficiency, waste management and climate impact mitigation.

The following expenses may be financed:

• expenses for renting or purchasing new commercial facilities (a single facility for each type – shop, office, showroom or corner store), opened during the Execution Period (therefore not already started before submitting the loan application). The conformity of the facilities to international expansion purposes shall result from the rental or purchase agreement, indicating the intended use. The expenses shall be incurred exclusively by the Applicant Company. Expenses relating to staff, travel and facility management, also through a local trader, are excluded;
• promotional expenses, also undertaken through digital channels, directly connected with the international expansion of the Applicant Company or initiatives that may be financed in the expenditure category “International expansion expenses”, as resulting from the service agreement and invoices to submit in the reporting. Expenses must concern promotional activities abroad;
• expenses for advisory services concerning international expansion, including the Temporary Export Manager. Legal or tax advisory services may also be financed, provided they are directly related to the investment made abroad which the application for financing refers to. The connection with international expansion shall be clear from the service agreement indicating the purposes of the advisory service, the programme of actions, duration and fee.
• expenses for participation in international events in Italy and other countries. An event means a trade fair, exhibition, promotional event, business mission abroad or, if in Italy, which is on the calendar of AEFI, the Association of Italian Exhibitions and Trade Fairs, as an international event. Staff and travel expenses are excluded.
• expenses abroad for international product certification and the registration of trademarks.

Expenses for technical assistance cannot be financed.
All “International expansion expenses” may be financed, provided there is a direct connection with international expansion. This evidence must be provided in the reporting, in supply agreements, the statements made by suppliers, invoices and the Final Report (as per section 5.4 of the Circular).

Expenses for advisory services for DNSH audits (see the “DNSH conformity statement” and related technical datasheets and focus sheets) and for advisory services to obtain or renew environmental certification can be financed.

Expenses for advisory services, including the digital manager, related to the digitalisation of the Applicant Company, may be financed, in terms of the technological innovation of business, production and organisational processes. The purpose of the advisory service related to the digital transition shall be clear from the supply agreement, containing the purposes of the advisory service, the programme of actions, duration and the fee, as well as the statements made by suppliers, invoices and the Final Report (as per section 5.4 of the Circular) on the use of financing and co-funding, to submit in the reporting.

No, these expenses cannot be financed, as they are strictly related to the digital transition processes of the Applicant Company.

No, these expenses must concern training provided by a third party with the relative invoice submitted in the reporting. Expenses relative to the Applicant Company’s internal staff are always excluded.

The Framework Decision and Operating Circulars of the National Recovery and Resilience Plan (NRRP) exclude the financing of expenses/costs covered by other public funding (even public funding which is not State aid, such as tax receivable measures relating to the same costs/expenses) and require compliance with the no dual financing obligation (i.e. the prohibition to cover the same costs/expenses twice), whereas different costs or different parts of the cost of the same good/project that are not supported by the SIMEST NRRP measure, can be supported by different public financing, in conformity to the RGS Circular no. 21 of the Ministry of the Economy and Finance (MEF) of 14 October 2021 and related technical attachment, and further clarified in the 

RGS Circular no. 33 of the MEF of 31 December 2021, Circolare-del-31-dicembre-2021-n-33.pdf (mef.gov.it), and in compliance with regulations on State aid. By way of example, as indicated in the MEF Circular mentioned, if the SIMEST NRRP measure finances 40% of the value of a good/project (i.e. the eligible expenses), the remaining 60% may be financed through other sources, provided applicable provisions on cumulation are met, and overall, 100% of the related cost is not exceeded.
By way of example, if I purchased an asset/machinery for the value of €1/mln, I can cover €300k with the SIMEST NRRP loan and the remaining €700k (i.e. the part of the cost not funded by SIMEST) with other public financing, accumulating support from different financial sources in compliance with regulations on State aid. Instead, I cannot duplicate the financial support from public financing for the €300k funded with the SIMEST NRRP loan.

Yes, you need to conduct DNSH audits. Technical Datasheet no. 3, available in the website section on DNSH principles, is currently being updated. See the page for updated information.

Guidelines are being prepared on the requisites of the environmental consultant, and the DNSH analysis report to write. See the website section on DNSH principles for updated information.

Yes. For the scheme in question, the supply agreement for the proprietary Platform or for access to the market place must be submitted, for compliance with the conditions precedent. In order for the agreement to be considered as conforming for financing purposes, it must contain complete, detailed information on (i) the service covered by the agreement, (ii) the fee agreed, (iii) the procedure for paying the agreed on fee, (iv) the duration of the service, (v) the procedure for service provision, and which shall be consistent with the indications in the invoices, to submit in the reporting.

Excluded activities and assets do not correspond exactly to ATECO codes, however it is possible to recognise the following as sectors that may not be financed:

• All of Category B: extraction of minerals from quarries and mines
• All of Category 19: Manufacture of coke and petroleum products
• Category 35.2: production of gas; distribution of gaseous fuels through pipelines
• Category 38.21: treatment and disposal of non-hazardous waste
• Category 38.22: treatment and disposal of hazardous waste

The sectors and activities excluded by the InvestEU Regulation, listed in Annex V – Letter B of Regulation (EU) 2021/523 of the European Parliament and of the Council of 24 March 2021 cannot be financed either. See the list.
In addition to the Activities and assets excluded, which cannot be financed pursuant to the NRRP, Category A and codes 10.11 and 10.12 of Category C cannot be financed pursuant to the “de minimis” regulation.

The invoices must indicate a date which falls within the execution period, which starts from the date when the application is submitted and finishes at the end of the pre-amortisation period (12 or 24 months after stipulating the agreement and depending on the type of financing). Relative supply agreements must provide for activities to be carried out during the above execution period.

The configuration of employees by age and gender must be indicated in a table on the termination of conditions precedent, which can be displayed in the Portal mask. The table has the following format: