This scheme part-finances digitalisation investments of many kinds — hardware, software, licences and other digital solutions, not just custom development. Click a category to add it to your project costs below. Categories marked MDIA +10% automatically attract an extra 10% aid intensity on those items.
Every answer below quotes the exact section of the official Guidance Notes or User Guide. You can (and should) cross-check with your accountant, especially on de minimis, financial viability, and single-undertaking rules. If any figure or rule below has moved since we wrote this, the official documents win.
Based on Guidance Notes V2.0 and User Guide V2.0 · Source: fondi.euMicro, small, and medium-sized enterprises (SMEs) that are based and operational in Malta or Gozo.
The size test applies to the whole undertaking, not just the applying company. Where your business has linked or partner enterprises — through shared ownership, control, or significant shareholdings — their headcount and financials are aggregated with yours, in full or in proportion. A company that looks micro on its own accounts can test as small or medium once the group is taken into account, and that changes both eligibility and aid intensity. Establish this before you apply; it is not always straightforward and is worth confirming with your accountant.
Thresholds, assessed at undertaking level (must satisfy the headcount test, and either turnover OR balance sheet):
| Size | Headcount | Turnover | Balance sheet |
|---|---|---|---|
| Micro | < 10 | ≤ €2m | ≤ €2m |
| Small | < 50 | ≤ €10m | ≤ €10m |
| Medium | < 250 | ≤ €50m | ≤ €43m |
You are automatically excluded if any of the following apply:
Full list of exclusions in the "Ineligible costs" tab. Jump to ineligible costs →
Guidance Notes §2.1 (Eligible Undertakings) and §2.5 (Exclusions)Applications with a Grant Request over €60,000 are automatically assessed for financial viability. The Intermediate Body reserves the right to do this check even for grants under €60k.
The check looks at whether your organisation:
You can pre-check your position using the EU's own simulator: https://ec.europa.eu/research/participants/lfv/lfvSimulation.do
You must also meet the Total Eligible Cost to Net Assets ratio of more than 2% to pass the Gateway Criteria.
Net assets can also cap your eligible cost
Separately from the viability rating, your net assets (total assets less total liabilities) determine how much eligible cost the grant can be calculated on:
| Applicant | Condition | Consequence |
|---|---|---|
| Not a start-up | Net assets below 40% of total eligible cost | Eligible cost capped at 250% of net assets, unless you provide a guarantee for the difference |
| Start-up | Net assets below 20% of total eligible cost | Eligible cost capped at 500% of net assets, unless you provide a guarantee for the difference |
Start-ups under 3 years with net assets below 20% of total eligible cost, or negative net assets not exceeding €120,000, may instead base the threshold on share capital above the statutory minimum, multiplied by 10 and then by 250%.
Negative net assets between €60,000 and €120,000 reduce the maximum aid intensity by 10 percentage points. Applicants with negative net assets are otherwise excluded, except start-ups under 3 years within the €120,000 limit.
This grant is awarded under the EU de minimis regime (Commission Regulation 2023/2831). Under that regime, a single undertaking cannot receive more than €300,000 in de minimis aid over any rolling three-year period, from any public source (EU or national, this scheme or another).
What counts against the €300k:
You will need to fill in the official de Minimis Declaration Form as part of the application, downloadable from fondi.eu. Getting this wrong risks rejection or, later, recovery of the funds with interest.
What "single undertaking" means: for de minimis purposes, two enterprises are treated as a single undertaking (and share the €300k limit) if any of the following apply between them:
Enterprises linked to each other through one or more intermediate enterprises via any of these relationships are also considered a single undertaking. This is why parent companies, subsidiaries, and sister companies all pool into the same €300k cap.
Yes, with conditions. The rules cover both "multiple ongoing projects" and "applying again after completion":
| Rule | What it means |
|---|---|
| Multiple ongoing projects allowed | Across SME Enhance, SME Enhance (de Minimis), and Digitalise your SME, provided the total grant across them does not exceed €128,400 |
| AI top-up excluded from cumulative cap | The €100,000 AI threshold does not count towards the €128,400 limit |
| Re-apply after completion | Once a project is fully completed (see FAQ below), additional applications may be submitted |
| No segmenting to bypass cap | You cannot split one project into pieces across schemes to work around the €128,400 limit |
| Linked enterprises count | Applicant + any linked enterprises share the same €128,400 cap |
You are also always bound by the separate de minimis limit of €300,000 over 3 rolling years across all public funding, not just this scheme.
The Guidance Notes list 23 categories of ineligible expenditure. The most common gotchas for our clients:
Eligible replacements for MSA-type spend
MSA is out under §2.4(a), but the underlying services can often be restructured into eligible categories:
| What it is | Eligible category | Cap |
|---|---|---|
| Access to software with updates included | SaaS / subscription-based software (§2.3.1) | First 2 years |
| Hosting, storage, compute | Cloud computing (§2.3.1) | First 2 years |
| Security monitoring, patching, endpoint protection | Cyber Security systems (§2.3.1) | First 2 years if subscription |
| New features, modules, enhancements to existing software | Custom software development / Not-quoted enhancements (§2.3.1) | None |
| Training on the specific item being purchased, from the same supplier, bundled in the item price | Installation & training (§2.3.1 last bullet) | Part of item cost |
| Break/fix support, helpdesk, warranty extensions, bug fixing existing code | Stays ineligible | — |
The full list of ineligible categories is in the Ineligible costs tab of this document, quoted directly from the Guidance Notes.
Guidance Notes §2.4 (Ineligible Expenditure)The following categories are eligible under the general threshold. This is not an exhaustive list — other hardware, software or digital solutions identified in the application may also be considered eligible under the scheme.
Hardware includes laptops, docking stations, port replicators, monitors and tablets. Analytical tools include the necessary hardware and software.
Installation and training are eligible where they relate to an item acquired above, are included in that item's purchase price, and are provided by the same supplier.
AI investments carry their own eligible expenditure list and a separate €100,000 threshold — see What is the AI top-up and do we qualify?
Guidance Notes §2.3.1 (Eligible Expenditure)The grant has two possible layers:
| Layer | Base grant cap | + 7% flat rate | Total max |
|---|---|---|---|
| Standard digitalisation | €120,000 | €8,400 | €128,400 |
| AI top-up (if applicable) | €100,000 | €7,000 | €107,000 |
| Combined maximum | €220,000 | €15,400 | €235,400 |
Minimum grant is €25,000. If your project would produce a grant smaller than that, it will not qualify as-is.
Aid intensity (what percentage of eligible costs the grant covers): 50% in Malta, 60% in Gozo, with possible uplifts of +10% (MDIA on specific tech) and +5% (digital intensity). See dedicated FAQs below.
Yes — €25,000 is a hard minimum grant. It's confirmed in two independent places in the official documents:
What this means in practice
The €25,000 floor applies to the grant amount, not the project size. The eligible cost required therefore depends on the aid intensity that applies:
| Aid intensity | Minimum eligible cost for a €25,000 grant |
|---|---|
| 50% — Malta base | €50,000 |
| 60% — Gozo base | €41,700 |
Uplifts raise the applicable intensity and lower the eligible cost required. The +10% MDIA uplift attaches to qualifying items; the +5% digital intensity uplift applies to the application as a whole where the pre- and post-project criteria are met. Both are assessed case by case, so treat the figures above as planning guides rather than thresholds to design to. More on the uplifts →
Where the projected grant falls below €25,000
The application does not qualify in its current form. The scope needs revisiting rather than the application submitting. Common routes:
Whether any of these apply depends on the eligibility of the individual items and on the assessment of the project as a whole.
Guidance Notes §1.7 · User Guide §1.1Two possible uplifts to your aid intensity, on top of the base 50% (Malta) / 60% (Gozo):
| Uplift | When it applies | Funded by |
|---|---|---|
| +10% MDIA | Applied to the specific items involving Cyber Security, Internet of Things, Artificial Intelligence, Big Data analysis, Cloud Computing, or Quantum Technology | Malta Digital Innovation Authority |
| +5% Digital Intensity | The applicant meets no more than 6 of the 12 digital intensity technologies before the project, and will achieve 7 or more after completion | Scheme budget |
Important MDIA caveats:
The 12 Digital Intensity technologies (Annex VI)
The +5% Digital Intensity uplift is designed to reward SMEs that meaningfully step up their digital maturity through the project. The scoring uses 12 categories set out in Annex VI of the Guidance Notes. To qualify, you need to be in the lower band today (6 or fewer) and end the project in the higher band (7 or more).
| # | Digital technology | Have today | After project |
|---|---|---|---|
| 1 | Internet for at least 50% of employees iAt least half of your employees have internet access at their workplace, via broadband, Wi-Fi, or mobile data — not just personal phones. | ||
| 2 | Recourse to ICT specialists (in-house or outsourced) iYou have IT specialists either as internal staff or via outsourced arrangements (managed service providers, IT consultants, dev shops) to handle IT and technology needs. | ||
| 3 | Fast broadband (30 Mbps or above) iYour primary internet connection at the workplace has a contracted download speed of at least 30 Mbps. Check your provider's plan documents. | ||
| 4 | Mobile internet devices for at least 20% of employees iAt least 20% of your employees are provided with a mobile device (phone or tablet) with company-paid internet connectivity for work purposes. | ||
| 5 | A webpage or homepage iYour business has any web presence — a website, landing page, or homepage that customers can find. Any format counts (single page, brochure site, full site). | ||
| 6 | A website with sophisticated functions iYour website includes advanced features — at least one of: online bookings, product configurator, personalisation, customer accounts / login, live chat / chatbots, or comparable interactive tools. A brochure site with just contact info does not count. | ||
| 7 | Active social media presence iYou actively use at least one social media account for business (Facebook, Instagram, LinkedIn, TikTok, etc.) — regular posts, engagement, or paid content. Having an inactive account does not count. | ||
| 8 | Paying to advertise on the internet iYou spend money on any form of online advertising — Google Ads, Meta Ads, LinkedIn Ads, sponsored content, SEO campaigns, or influencer marketing. Free organic posts do not count. | ||
| 9 | Buying medium-high cloud computing services iYou purchase cloud services beyond basic email — such as CRM (Salesforce, HubSpot), ERP, accounting software (Xero, QuickBooks), cloud storage, hosted databases, dev platforms (AWS, Azure), or Microsoft 365 with advanced services. | ||
| 10 | Sending e-invoices suitable for automated processing iYou send invoices in structured electronic formats that recipient accounting systems can read automatically — XML, EDI, PEPPOL, UBL. A PDF sent by email does not qualify; the format must be machine-readable. | ||
| 11 | e-Commerce web sales accounting for at least 1% of total turnover iSales completed through your website (checkout on your site or an e-shop) represent at least 1% of your total annual turnover. Sales via third-party marketplaces (Amazon, eBay) count separately. | ||
| 12 | B2C web sales of over 10% of total web sales iMore than 10% of your total online sales are direct-to-consumer (B2C) rather than to other businesses (B2B). Only relevant if you already qualify for item 11. |
Practical note. The pre-project position is formally established through the Digital Intensity Assessment that MDIA carries out before the project. Contact MDIA at funding.mdia@mdia.gov.mt to book. This tool is a self-check to help you plan.
A 7% flat rate is automatically added to your grant to cover your indirect costs (things like project admin, overheads, utilities). You do not need to document these costs individually — the flat rate is a simplified cost option under EU Reg. 2021/1060.
The 7% is calculated on the eligible cost, and it applies separately to the standard portion and the AI portion of your project.
Call 2 added a dedicated AI stream. Projects that include eligible AI investments can raise their grant cap by up to €100,000 (plus 7% = €107,000 max additional).
Eligible AI expenditure includes:
What you must submit for the AI top-up:
All three are compulsory attachments for applications requesting the AI threshold. The first two are revisited a year after completion to release the MDIA top-up.
Always required (marked * in the User Guide checklist):
Required only if applying for the AI top-up:
Required in specific circumstances (partnership, non-Director signatory, permits, etc.):
See the Where we help tab for which of these Threls can help you produce.
User Guide §7.1 (Checklist of Attachments)The scheme runs as an open rolling call with periodic cut-off dates. Applications submitted before each cut-off are batched, evaluated, and either awarded or rejected together.
Scheme window: open until 31 December 2026. All investments must be concluded by 30 June 2029.
Once approved: the Grant Agreement is signed after evaluation. From that date, you have 6, 12, 18, or 24 months to implement (whichever you applied for). Extensions in 6-month blocks may be granted, with deductions (see "What happens if I do not complete on time?" below).
Guidance Notes §1.4, §1.6, §1.8 · fondi.eu for the live cut-off scheduleApplications are first checked against Gateway (eligibility) Criteria, then scored against Selection Criteria only if they pass the gateway. You need at least 50% of the total score to be approved, subject to budget availability.
Gateway Criteria (all must be met):
The Project Selection Committee then scores across Project Excellence, Impact & Sustainability, Quality of Implementation, Risk, National & Horizontal Priorities, and Do No Significant Harm.
Guidance Notes §5 (Assessment and Selection)The scheme reimburses expenditure you have already incurred. Procurement may only begin once the Grant Agreement is signed — work started before the aid is granted is ineligible.
| Stage | Trigger | Amount |
|---|---|---|
| 1st advance | Signature of the Grant Agreement | 50% of the 7% flat rate |
| 2nd advance | Supplier invoice for the main component(s) | 30% of the eligible grant on those components |
| Interim claim | Delivery of main component(s), with Progress Report | Up to 60% of the grant, 70% if operational, net of advances |
| Final claim | Investment in place and operational, with Final Report | Balance of eligible expenditure and the 7% flat rate |
Advance payments together may not exceed 40% of the total eligible grant. Components covered by the second advance must be fully paid, delivered and operational within the same calendar year.
The AI top-up is settled separately. Where the increased AI threshold applies, the 10% MDIA top-up on that portion is not paid with the final claim. It is claimed one year after project completion, against an MDIA-verified update to the Ethical AI and Societal Well-Being assessment and a report on the productivity gains actually achieved.
What gets reimbursed: the lower of the invoice amount or the expenditure approved in the Grant Agreement. Where three quotations were submitted, reimbursement is pegged to the cheapest accepted quotation or the invoice, whichever is lower.
Timing: claims are expected within 3 calendar months of the operation end date in the Grant Agreement. Later submission incurs a deduction of 0.5% of the grant per month, or part month.
This is why evidence of private match financing is required at application stage: you carry the investment until reimbursement.
Guidance Notes §2.6(iv), §6.2.4, §6.5, §6.6 · Practical Guidelines (Procurement, Advance Payments, Claim for Reimbursement)The scheme allows extensions in 6-month blocks, but with deductions from your grant:
| Situation | Deduction |
|---|---|
| First 6-month extension (requested before end date) | None |
| Each further 6-month block up to 24 months total | 1% of original grant per block |
| Each 6-month block beyond 36 months (if permitted) | 2% of original grant per block |
| Extension requested after end date has passed | +5% of original grant, on top of the block deductions |
| Reimbursement claim submitted late (past 3 months from end date) | 0.5% of original grant per month of delay |
All investments must be concluded by 30 June 2029 regardless of extensions granted.
Practical GuidelinesThe Digitalise your SME application has several sections and attachments. Some are purely business, financial, or legal, and belong with you and your accountant. Others are technical, and this is where Threls, as your technology partner, can produce the documentation you need.
The table below maps every required piece to who typically owns it. Sections marked Yes under "Threls can help" are the ones where we produce the draft, quotations, or specifications for you to review.
| Section | What it covers | Threls can help | Owned by |
|---|---|---|---|
| §2.1 | Applicant Details (name, VAT, size, address, contacts) | — | You · directly from company records |
| §2.2 | Applicant's Core Business Activities (NACE code, business overview) | — | You · your accountant confirms NACE |
| §2.3 | Past experience in EU-funded projects | — | You · from your records |
| Section | What it covers | Threls can help | Owned by |
|---|---|---|---|
| §3.1 | Project Details (project title, location, investment overview) | Yes | Joint · we draft the tech overview, you approve and add business framing |
| §3.1.1 | Proposed Investment Initiative (technical description of what you are building) | Yes | Threls drafts, you review |
| §3.2 | Project Excellence (why this technology, why now, innovation angle) | Yes | Joint · we cover the technical excellence, you cover the business excellence |
| §3.3 | Project Impact and Sustainability (business metrics, ROI, employment impact) | — | You · these are your business metrics, not ours to project |
| §3.4a | Level of Readiness and GANTT / Implementation Schedule | Yes | Threls produces the GANTT for the technology work |
| §3.4b | Operational capacity and human resources allocation | — | You · your team structure, your CVs |
| §3.4c | Post-implementation operational capacity and operating costs | — | You · your ongoing structure and cost base |
| §3.5 | Project Risk Assessment | Yes | Joint · we cover technical risks, you cover business / market risks |
| §3.6 | National and Horizontal Priorities (Malta's Digital Decade, cohesion, gender equality) | Yes | Joint · we can advise on how the tech aligns with Digital Decade targets |
| §3.7 | Do No Significant Harm (DNSH) Principle | Yes | Joint · we can advise on environmental impact of the tech, you sign off |
| Section | What it covers | Threls can help | Owned by |
|---|---|---|---|
| §4.1 | Financial Plan (activities, sub-activities, eligible / non-eligible split) | Yes | Joint · we provide the cost breakdown for our work + quotations, you input the whole plan |
| §4.1 | Staff Costs sub-activity (AI applications only) | Yes | Joint · we identify the hours in the Scoping Report, you provide employee names and IDs |
| §4.1 | 7% Flat Rate — Indirect Costs | — | Auto-calculated by the online form once eligible items are entered |
| Item | What it is | Threls can help | Owned by |
|---|---|---|---|
| §5.1 | Additional Information (clarifications on any earlier section) | Yes | As needed, per section |
| §6.1 | Declaration Form (double funding, family relationships, sign-off) | — | You · signed by an authorised representative |
| §7.1 | Declaration Form (attachment) | — | You |
| §7.1 | Tax Compliance Certificate (MTCA) | — | Your accountant requests from Office of the Commissioner for Revenue |
| §7.1 | NACE Code 2.1 Confirmation | — | Your accountant confirms |
| §7.1 | Evidence of Private Match Financing (bank letter, statements, or equivalent) | — | You / your bank |
| §7.1 | GANTT Chart or Implementation Schedule | Yes | Threls produces the tech GANTT |
| §7.1 | Investment Proposal or Technical Specifications and Quotations (3 quotes per item) | Yes | Threls produces our part; you gather the other quotes from unrelated suppliers |
| §7.1 | Pre-project Digital Intensity Assessment (MDIA-issued) | Yes | You book with MDIA (funding.mdia@mdia.gov.mt), we can prep the tech input |
| §7.1 | De Minimis Declaration Form | — | Your accountant · this is a legal declaration |
| §7.1 | Scoping report for AI cost items (AI applications only) | Yes | Threls produces the tech scope, staff hours, supplier profile |
| §7.1 | Ethical AI and Societal Well-Being Assessment (AI applications only) | — | You · we can advise on the tech questions but this is your governance sign-off |
| §7.1 | Productivity Gains Report (AI applications only) | — | You · these are your business projections |
| §7.1 | Declaration of Authorization (if signer is not a Director) | — | You |
| §7.1 | Certificate of Registration, MOA, Financial Statements, Permits, Trustee Declarations | — | You / your accountant / your lawyer |
Threls is here to make the technical case airtight: what you are building, why the tech choices make sense, what it will cost, and how long it will take. The business case, the financial declarations, and the legal sign-offs remain with you and your professional advisors. If you would like an introduction to a scheme consultant or accountant familiar with fondi.eu applications, ask us.
These costs are listed as ineligible in the official Guidance Notes. Even if we quote them, the scheme will strip them out of the funded total. Below is the complete list, quoted directly.
These items may still be funded under the standard 50% / 60% aid intensity, but they will not attract the additional 10% MDIA top-up:
Bottom line for our quotes: anything in the lists above is either stripped out or funded at the base rate only. If we put a line in the calculator that falls under these categories, we flag it. Ineligible items on our invoices are your cost, in full, ex-grant.