Key data
| Regulation | Order TDF/1027/2026, of September 23 (amends Order ETD/1236/2023, of November 14) |
|---|---|
| Publication | October 3, 2026 |
| Entry into force | October 3, 2026 |
| Affected parties | Companies participating in IPCEI microelectronics and cloud computing projects that apply for public aid |
| Category | Aid and Subsidies |
| Program | UNICO IPCEI — IPCEI-CIS (cloud, edge computing and microelectronics) |
| New source of financing | FEDER — Spain's Pluriregional Program (POPE) 2021-2027 |
| Applicable EU regulations | EU 2021/1060 and EU 2021/1058 |
Companies participating in European cloud computing and microelectronics projects have a new public financing avenue available. The Order TDF/1027/2026, published on October 3, 2026, amends the regulatory bases of the UNICO IPCEI program to incorporate FEDER as an additional source of financing, alongside MRR funds from the Recovery, Transformation and Resilience Plan (PRTR).
The change is significant: until now, aid from the UNICO IPCEI program was financed exclusively with Next Generation EU funds (MRR). From this amendment onwards, new aid can be called with funds from Spain's Pluriregional Program (POPE) 2021-2027, which expands the territorial and budgetary scope of the program, especially towards regions with less digital development.
What does this regulation establish?
Order TDF/1027/2026 amends Order ETD/1236/2023, of November 14, which established the regulatory bases of the UNICO IPCEI program. The specific changes are as follows:
| Aspect | Before (Order ETD/1236/2023) | Now (Order TDF/1027/2026) |
|---|---|---|
| Source of financing | Exclusively MRR funds / Next Generation EU (PRTR) | MRR + FEDER (POPE 2021-2027) |
| Applicable control regulation | PRTR regulation | EU Regulations 2021/1060 and 2021/1058 for FEDER calls |
| Territorial scope | Investments already made with PRTR | Extended to regions with less digital development |
| Anti-fraud and DNSH obligations | Required | Maintained in all calls |
The technological areas covered by the program do not change: they remain cloud computing, edge computing and microelectronics, all framed within the European project IPCEI-CIS (Important Projects of Common European Interest — Cloud Infrastructure and Services).
Future calls charged to FEDER must comply with the specific regulation for management and control of European structural funds. This implies adapting to the requirements of the EU Regulation 2021/1060 (common provisions for structural funds) and EU Regulation 2021/1058 (FEDER and Cohesion Fund).
Economic and operational impact
For companies already participating in IPCEI-CIS, this amendment represents an opportunity to access additional financing without changing the project framework. However, it also implies a new operational burden: FEDER justification requirements are different and, in some aspects, more demanding than those of the PRTR.
The main operational impacts are:
- Dual compliance framework: Companies that have received MRR aid and apply for new FEDER calls will have to simultaneously manage two different control and justification regimes.
- New eligibility requirements: Expenses financed with FEDER must comply with the eligibility criteria of structural funds, which differ from those of the PRTR in terms, documentation and verification systems.
- DNSH principle maintained: The obligation not to cause significant environmental harm (DNSH principle) is maintained in all calls, both MRR and FEDER.
- Anti-fraud obligations: These are also maintained in the new FEDER calls, with the same internal control standards required so far.
- Territorial extension: The explicit objective of reaching regions with less digital development may open calls with geographic prioritization criteria.
Who does it affect?
- Companies participating in the European project IPCEI-CIS (cloud, edge computing, microelectronics) that have already received or are applying for aid from the UNICO IPCEI program.
- Technology companies in the cloud and edge infrastructure sector that are evaluating their participation in IPCEI calls.
- Companies in the microelectronics sector with projects of common European interest in progress or in the planning phase.
- CFOs and financial directors of beneficiary companies managing the justification of European public subsidies.
- Advisors and consultants specialized in European funds who support companies in PRTR and FEDER calls.
- Companies located in regions with less digital development that until now had not accessed the IPCEI program due to limitations of MRR calls.
Practical example
A Spanish cloud infrastructure company participating in the IPCEI-CIS project that already received MRR financing through the UNICO IPCEI program now finds itself in this situation:
With the amendment introduced by Order TDF/1027/2026, that same company can apply for a new call financed with FEDER (POPE 2021-2027) to expand or complement its project. However, it will have to prepare a different justification structure: while for MRR funds it applied PRTR regulation, for FEDER funds it must comply with EU Regulations 2021/1060 and 2021/1058, with their own verification models, audit trails and document retention periods.
If the company is located in a region classified as having less digital development, it has priority in accessing these new FEDER calls, which can provide a competitive advantage over competitors located in more advanced regions.
What should companies do now?
- Review your situation in the UNICO IPCEI program: Confirm whether your company participates in the IPCEI-CIS project and at what stage your current financing is (MRR or pending new call).
- Analyze eligibility for FEDER calls: Evaluate whether your project and company meet the FEDER eligibility criteria (EU Regulations 2021/1060 and 2021/1058), which are different from those of the PRTR.
- Prepare the FEDER justification structure: If you plan to apply for aid in the new calls, adapt your internal control and documentation systems to the requirements of European structural funds before submitting the application.
- Verify compliance with the DNSH principle: Ensure that your project demonstrates that it does not cause significant environmental harm, a requirement that is maintained in all calls, both MRR and FEDER.
- Review internal anti-fraud protocols: Anti-fraud obligations are maintained in the new FEDER calls. Verify that your company has adequate internal controls before applying for aid.
- Consult the POPE 2021-2027: Identify whether your region is classified as having less digital development, as this may give you priority access in the new FEDER calls.
Frequently asked questions
What is the UNICO IPCEI program and what projects does it finance?
The UNICO IPCEI program finances the participation of Spanish companies in important projects of common European interest (IPCEI). Specifically, the IPCEI-CIS project covers the areas of cloud computing, edge computing and microelectronics. Until Order TDF/1027/2026, it was financed exclusively with MRR funds from the Recovery Plan (Next Generation EU). Now it can also be financed with FEDER, through Spain's Pluriregional Program (POPE) 2021-2027.
What is the difference between applying for MRR aid and FEDER aid in the IPCEI program?
The main difference is in the applicable control and justification regulation. MRR aid is governed by PRTR regulation, while FEDER aid must comply with EU Regulations 2021/1060 (common provisions for structural funds) and 2021/1058 (FEDER and Cohesion Fund). This implies different verification models, audit trails, document retention periods and expense eligibility criteria.
When do the changes from Order TDF/1027/2026 come into force?
Order TDF/1027/2026 came into force on the same day as its publication in the BOE: October 3, 2026. New calls charged to FEDER will be made from this date onwards, under the amended regulatory bases.
What is the DNSH principle and how does it affect IPCEI companies?
The DNSH principle ("Do No Significant Harm") requires that financed projects do not harm any of the six environmental objectives of the EU. Order TDF/1027/2026 maintains this requirement in both MRR calls and new FEDER calls. Companies must demonstrate compliance with this principle in their application and justification documentation.
Can companies from advanced regions access the new FEDER calls of the IPCEI program?
The explicit objective of the amendment is to extend the IPCEI-CIS project to regions with less digital development, complementing investments already made with the PRTR. Although the regulation does not expressly exclude companies from other regions, the orientation of POPE 2021-2027 and FEDER prioritization criteria may favor companies located in regions with less digital development. It is advisable to review the specific criteria of each call when they are published.
Official source
Consult complete regulation in official source
Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-20584