EUROPEAN COMMISSION
DG Competition
State aid: General Scrutiny and Enforcement
R&D&I, IPCEI and Environment
Brussels, 26/11/2025
COMP/H23/HS/bsz
comp(2025)13110605
Permanent Representation of
Estonia to the EU
Rue Guimard 11/13
1040 Bruxelles
E-Mail:
[email protected]
[email protected]
Subject: Monitoring of Block Exemption Measures
SA. 106808 (2025/MX) - Support for mapping and developing
cybersecurity levels
Dear Madam, dear Sir,
I thank you for the letter dated 10 November 2025 in which your authorities provided
information on the above-mentioned scheme.
On the basis of the information sent by your authorities, DG Competition considers that
the scheme under reference is, prima facie, in line with the provisions of the General
Block Exemption Regulation (GBER)1.
At the same time, we would like to draw your authorities' attention to the fact that the
rules relating to cumulation of aid (as set out in Article 8 of the GBER) are not included
in the “Conditions and Procedure for Supporting the Mapping and Development of
Cybersecurity Level” but only indirectly mentioned via references to the GBER or the de
minimis Regulation. Please note that for the sake of clarity, it is preferable for future aid
scheme to fully incorporate criteria, such as those related to cumulation of aid, into the
legal basis of an aid measure, rather than simply referring to the source of the definition
and its associated criteria.
DG Competition has decided not to ask your authorities for any additional information
regarding the above measures.
1
Commission Regulation (EC) No 800/2008 of 6 August 2008 declaring certain categories of aid
compatible with the common market in application of Articles 87 and 88 of the Treaty (now Articles
107 and 108 TFEU) OJ L 214, 9.8.2008, p. 3, as from 1 July 2014 replaced by Commission Regulation
(EU) No 651/2014 of 17 June 2014 declaring certain categories of aid compatible with the internal
market in application of Articles 107 and 108 of the Treaty, OJ L 187, 26.6.2014, p. 1.
Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11.
We however would like to draw your attention to the fact that the monitoring was limited
to the assessment of the compliance of the national legal basis with the GBER.
Therefore, the closure of this case does not contain any conclusions beyond that
assessment and the aid scheme concerned, or its successor may be subject to subsequent
monitoring.
The official in charge of this file in DG Competition is Saskia HENDRIKS
(
[email protected]).
Please mention the reference to this case file, as provided in the subject SA.106808
(2025/MX), in any future correspondence.
Yours sincerely,
e-signed
Demos SPATHARIS
Head of Unit
2
Saatja: "Info - RAM" <
[email protected]>
Saaja: "Info - RAM" <
[email protected]>
Teema: FW: comp(2025)13110605 – SA.106808(2025/MX) - EE- LMS – Support for mapping and developing cybersecurity levels
Kuupäev: 2025-11-27 08:49
From:
[email protected] <mailto:
[email protected]>
<
[email protected] <mailto:
[email protected]> >
Sent: Wednesday, November 26, 2025 7:10 PM
To: ESTONIA_PREP (
[email protected] <mailto:
[email protected]> )
<
[email protected] <mailto:
[email protected]> >; Stateaid.est - RAM
<
[email protected] <mailto:
[email protected]> >; Monica Hankov
<
[email protected] <mailto:
[email protected]> >
Subject: comp(2025)13110605 – SA.106808(2025/MX) - EE- LMS – Support for
mapping and developing cybersecurity levels
Dear Sir, Dear Madam,
Please find attached doc. comp(2025)13110605.
Best Regards,
State Aid Registry
European Commission
DG Competition
MADOU Office 13/031
B-1049 Brussels/Belgium
Tel: +32 2 29 61154
E-mail: <mailto:
[email protected]>
[email protected]
DG Competition website: <http://ec.europa.eu/competition>
http://ec.europa.eu/competition