Not only can public aid be combined, but doing so intelligently can multiply a company's financial capacity by three or four without increasing dilution or compromising control.
Well structured, public aid can not only be combined, but it can Multiply the financial capacity of a startup by three or even four, without increasing dilution or compromising the company's control. Poorly combined, they can become a serious problem when the company is already growing.
In this article we explain to you How to combine public aid such as ENISA, CDTI and grants safely and strategically, avoiding errors that usually appear when it's too late to correct them.
“Yes, but...”: the usual answer to the big question
When the founders ask us if they can simultaneously apply for an ENISA, a CDTI project and an autonomous line, the answer always starts the same: “Yes, but...”.
Spain has one of the most comprehensive public funding ecosystems in Europe. In 2024, the CDTI provided more than 2.3 billion euros in financial support to Spanish companies and startups, including grants, partially refundable grants and investment in venture capital, and in 2025 the total budget allocated by CDTI for R+D+i instruments reached practically 1,942 million euros in grants, loans, investment and other support mechanisms.
For its part, ENISA has granted more than 9,000 participatory loans for a combined amount of approximately 1.4 billion euros to more than 7,500 companies, consolidating itself as a stable public funding instrument for SMEs and innovative startups.
The problem, therefore, is not the lack of opportunities, but Know how to navigate them correctly. The combination is possible and strategically recommended, but there is a regulatory framework that you should know well so as not to run into problems years later, usually in the justification phase.
The Golden Rule: Never finance the same expense twice
The European regulatory framework establishes as a general principle the prohibition of double financing at the same cost with public funds. However, according to the General Category Exemption Regulation (RGEC) of the European Commission, the same expenditure can be co-financed by different public sources as long as the sum of the grants does not exceed 100% of the eligible cost. This makes it possible, for example, to partially attribute the same resource, such as personnel costs, to different grants, provided that each one covers a differentiated and duly justified part of the total expenditure.
In practice, this means that a company can simultaneously have three, four or even five active public funding lines, provided that each one finances different spending concepts, different phases of the project or clearly separated time periods.
Practical example
An artificial intelligence startup presents a project to CDTI to finance the development of its algorithm, including costs for technical personnel, cloud computing infrastructure and acquisition of datasets. In parallel, Torres Quevedo asks for help hiring a doctor in machine learning who does not participate in the CDTI project, and whose salary is partially co-financed by this aid.
In addition, the company requests an autonomous grant to support R&D to cover other complementary activities of the project, such as pilot tests or technological validations, charging only the part of the expenditure that has not already been financed by CDTI or Torres Quevedo.
In this way, each instrument covers different costs or different parts of the same cost, without in any case public funding exceeding 100% of the eligible expenditure. There is no duplication of expenses and each euro has clear and justified traceability.
In a later phase, the company requests funding from ENISA in the amount of 300,000 euros. Unlike previous grants, ENISA does not finance specific costs or specific projects, but rather provides general funding to the company to reinforce its financial structure, support growth, cover working capital needs, strengthen the commercial team or promote the launch of pilot projects. For this reason, ENISA is compatible with the rest of the above-mentioned public funding instruments.
The three types of aid and how to combine them
Public soft loans: the most flexible piece
Instruments such as ENISA, ICF, IVF or ICO they offer loans on very advantageous terms: without guarantees, with long grace periods and interest rates below the market.
Its main advantage is that, when it comes to refundable funding, are not considered pure State aid. For this reason, they present very few compatibility restrictions.
Aid for R+D+i: greater impact, greater complexity
This category includes both grants and certain public loans and other instruments to support innovation such as CDTI, Torres Quevedo, innovation checks, Next Generation EU funds or Horizon Europe. These grants are subject to maximum intensity limits, which depend on the size of the company and the type of activity financed.
Some key limits are:
- Small business + industrial research: up to 70%
- Small business + experimental development: up to 45%
- Process innovation: up to 50%
Precisely for this reason, many incompatibilities do not appear at the time of the concession, but one or two years later, during justification. The correct way to combine them is assign each aid to sequential phases or to clearly differentiated needs.
Tax Incentives: The Perfect Supplement
Beyond direct aid, there are fiscal and labor incentives that can have a very significant impact on the income statement of innovative companies. Among the most notable are tax deductions for R+D+i (which can reach up to 42% of eligible spending) and Social Security bonuses for research staff, which save between 40% and 50% of the common contingencies associated with technical profiles dedicated to R+D+i activities.
However, it is important to keep in mind that both incentives are not always cumulative. The compatibility between bonuses for research staff and tax deductions for R+D+i is only possible when the company has the Innovative SME Seal. Otherwise, the company must choose each annuity which of the two incentives is most advantageous from an economic point of view.
Practical example: a startup with 10 engineers dedicated to R&D and an annual wage bill of 600,000€ can benefit from significant savings if it has the Innovative SME Seal. In this scenario, you could apply bonuses for research staff, substantially reducing Social Security costs, and simultaneously apply tax deductions for R+D+i for a significant amount, even maintaining a project funded by CDTI in parallel. It is important to note that tax deductions may be applied to the total cost of the project once the subsidized part has been deducted, provided that the compatibility limits are respected. Proper planning makes it possible to maximize the impact of these incentives without incurring incompatibilities.
Two Critical Regulatory Concepts You Should Know
In practice, most compatibility problems are explained by a mismanagement of one of these two concepts.
The de minimis regime
This scheme establishes a maximum limit of 300,000 euros in aid granted under the de minimis framework for a period of three fiscal years. However, in those programs that combine different tranches or instruments, only the part of the aid that is expressly subject to the de minimis regime counts within that limit. Many regional lines operate under this framework.
The good news is that major national and European lines (CDTI, ENISA, European programs) are not governed by minimis. Even so, it is mandatory to wear a updated record of minimum aid and state them correctly in each request.
The maximum intensities
When several grants finance the same project, it is essential to verify that the amount does not exceed the established limits. In practice, we recommend assign each aid to a specific phase: CDTI for technological development, Torres Quevedo for research talent and an autonomous line for internationalization.
The five mistakes that can cost you help
Mistake 1: Doubling expenses without realizing it
Ascribe the same payroll or invoice to two different files. It's one of the most common errors we detect.
Solution: implement analytical accounting with differentiated cost centers from the start.
Mistake 2: Forgetting that de minimis aids have memory
Accumulate small grants up to the limit of 300,000€.
Solution: keep an updated record of all minimum aid with their date of granting.
Mistake 3: Not declaring aid pending resolution
Administrations cross databases.
Solution: proactively declare all the grants requested and explain how they are complemented.
Mistake 4: Mixing time periods without clear justification
Projects with overlapping periods and similar concepts.
Solution: plan sequential phases or ensure a clear separation of tasks.
Mistake 5: Losing aid due to formal problems
Poorly broken down bills, transfers that don't add up, or unsigned timesheets.
Solution: keep a digital folder updated and reviewed on a regular basis.
Your public funding roadmap
Step 1: Identify your phase
Step 2: Build a call schedule 9—12 months in advance.
Step 3: It ensures the necessary co-financing (20% — 50% of the budget, even more, depending on the line).
Step 4: Implement the appropriate infrastructure: analytical accounting, management manager and documented procedures.
Why it's worth the effort
According to data from ESADE and ACCIÓ, the companies that combine three or more public instruments:
- They get 60% more private investment in subsequent rounds
- They undergo 40% less dilution in early stages
- They achieve 35% higher ratings on average
Public aid acts as a very powerful institutional validation. If the CDTI approves your project or ENISA validates your business model, you are sending a clear signal of credibility to the market.
Conclusion: combine yes, but with strategy
Combining public aid is possible, profitable and, in many cases, key to accelerating the growth of a startup without diluting capital. But doing so without a clear road map can create problems in the medium term.
The startups that make the best use of public funding are those that:
- They design a strategy that assigns each aid to a specific need
- They know the compatibility regulations and maximum intensities
- They implement control and analytical accounting systems from the start
- Anticipate deadlines and prepare quality requests
- They rely on specialized advice
At Intelectium we have more than 20 years supporting startups and we have managed thousands of public funding files, combining grants from all levels and administrations.
If you are considering applying for several grants or you already have one granted and you want to make sure that they are compatible with each other, we offer an initial review of your public funding structure to detect risks and optimization opportunities before it's too late. Contact us through our online form or through dealflow@intelectium.com.
