The European Green Deal target to reach climate neutrality by 2050 calls for unprecedented levels of public and private investments accompanied by deep reforms. In this context, well-designed State Aid schemes will be key to unlock investments and make the best use of public funds.
The European Alliance to Save Energy is happy to provide its feedback on the revised GBER. Energy efficiency is the bedrock of a decarbonised EU energy system: energy efficiency gains are essential to achieve the increased GHG emission target reduction of 55% by 2030 and full decarbonisation by 2050.
In its current form, the revised GBER offers some welcomed added flexibility for the application of state aid to energy efficiency projects. Energy efficiency is a precondition for a full integration of renewables and the phase out fossil fuels. Yet, in its current form the GBER does not provide the necessary level playing field with renewable energy sources and other energy supply measures. In particular the aid intensity levels for energy efficiency are lower and the rules on eligible costs are far more complex to apply.
EU-ASE therefore calls on the European Commission to:
1. Enshrine and enforce the “Energy Efficiency First principle” in the GBER
2. Level the playing field between energy efficiency measures and renewable energy sources (Art. 38 & 39 GBER)
3. Simplify cost eligibility and conditions for total cost eligibility (Art. 38)
4. Simplify the cconditions for the “incentive effect” (to favour the transition to MEPS)
5. Extend the scope of the Green Bonus (+ 15 points percentage) for high energy-efficiency projects
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Download related response to the CEEAG
Read more in our paper: Boosting energy efficiency through the revision of State Aid rules
In a fast-changing political and economic environment, 2025 was a year of continued efforts to strengthen security, stability, and competitiveness for European businesses.
Throughout the year, our work demonstrated that energy efficiency is not only essential to achieving climate goals, but also a key driver of innovation, energy independence and sustainable long-term growth across Europe.
Strong engagement with policymakers, combined with the successful organisation of the 4th European Energy Efficiency Day, highlighted the importance of collaboration and dialogue in advancing shared objectives. Partnerships across sectors and institutions remained central to delivering impact and shaping effective energy policies.
Looking ahead to 2026, we will intensify our efforts to secure the regulatory certainty that can accelerate the energy transition, while providing businesses with the investment confidence they need and strengthening Europe’s competitiveness.
Read the full Activity Report here.