R&D Loan Deferral for SMEs Without Guarantees: What SMEs Can Do in 2026

Key data

If your company has pending R&D public loans and is experiencing temporary liquidity difficulties, the Order PJC/808/2026 opens a concrete path for you to defer or split those installments without having to provide endorsements or guarantees. The regulation came into force on the same day as its publication, August 1, 2026, and expands the mechanism that already existed with Order PCM/519/2020, extending it to new calls and updating the competent body for issuing the necessary certificates.

The mechanism is not automatic: it requires the company to request certification from the Ministry of Science and present it along with complementary documentation to the corresponding Delegation of Economy and Finance. But it eliminates the most common barrier in these processes: the requirement for guarantees that many innovative SMEs, especially biotechnology ones, cannot provide.

What does this regulation establish?

Order PJC/808/2026 specifies the procedure for SMEs with high R&D investment intensity to benefit from the guarantee waiver provided for in articles 46.3.c) and 46.5.d) of the General Collection Regulation when requesting deferral or installment payment of public loan installments.

The key elements of the procedure are:

• The Ministry of Science issues certifications that identify eligible cases for deferral with guarantee waiver.
• These certifications facilitate the Delegations of Economy and Finance with the necessary elements to assess the company's future viability and the temporary nature of its financial difficulties.
• The beneficiary company presents the certification along with complementary documentation to obtain the deferral without guarantees.
• The regulation expands the scope of application to calls from the three state plans in force in recent years.

Calls covered by the regulation

Comparison with previous regulation

Economic and operational impact

For an innovative SME with cash flow difficulties, the requirement for guarantees in a deferral can be an insurmountable obstacle: assets are committed, working capital is scarce and bank endorsements are costly. This regulation eliminates that obstacle for eligible companies.

The concrete operational implications are:

• Immediate liquidity: deferring repayment installments frees up cash to continue operating and investing in R&D.
• No guarantee cost: there is no need to contract a bank endorsement or commit additional assets.
• Bounded administrative process: the Ministry of Science's certification centralizes the accreditation of eligibility, reducing the documentary burden before Finance.
• Biotechnology sector especially benefited: the regulation explicitly mentions this sector as the main recipient, given its high investment and deferred return profile.

The regulation does not establish maximum deferral periods or minimum or maximum amounts of deferrable debt: these parameters are governed by the General Collection Regulation and are determined case by case by the Delegations of Economy and Finance.

Who does it affect?

• SMEs with high R&D investment intensity with pending public loans from calls under the State Plans 2013-2016, 2017-2020 or 2021-2023.
• Companies in the biotechnology sector, expressly mentioned as main beneficiaries.
• SMEs benefiting from state programs for research, development and innovation aimed at society's challenges and promotion of scientific-technical research and its transfer.
• CFOs and financial directors of these companies, who must assess whether requesting deferral improves the liquidity position without compromising the relationship with Finance.
• Advisors and management firms that support innovative SMEs in managing their obligations with the Administration.

Practical example

A biotechnology SME that received a public loan under the State Plan 2017-2020 has several repayment installments pending. The company is in a clinical development phase with limited income and does not have sufficient assets to provide bank guarantees.

With Order PJC/808/2026, the process would be as follows:

1. The company requests from the Ministry of Science the certification that accredits that its case is included in the eligible calls of the State Plan 2017-2020.
2. The Ministry issues the certification, which identifies the case and provides the elements to assess the company's future viability and the temporary nature of its difficulties.
3. The company presents that certification, along with the required complementary documentation, to its Delegation of Economy and Finance.
4. The Delegation assesses the request and, if appropriate, grants the deferral or installment payment without requiring guarantees, under articles 46.3.c) and 46.5.d) of the General Collection Regulation.

The result: the company can defer payment of installments, maintain liquidity to continue its research activity and avoid the cost and complexity of providing endorsements.

What should companies do now?

1. Verify if you have eligible loans: check if your company is a beneficiary of loans from calls under the State Plans 2013-2016, 2017-2020 or 2021-2023 with pending installments.
2. Evaluate the liquidity situation: determine whether deferral is convenient based on your current financial position and short-term cash projections.
3. Request certification from the Ministry of Science: contact the Ministry of Science to start the process of obtaining the certification that accredits the eligibility of your case.
4. Prepare complementary documentation: in addition to the certification, you must provide documentation that accredits the company's future viability and the temporary nature of financial difficulties.
5. Submit the request to the Delegation of Economy and Finance: with the certification and complementary documentation, formalize the request for deferral or installment payment without guarantees.
6. Coordinate with your tax or financial advisor: the procedure involves assessments of business viability that should be properly documented to maximize the chances of success.

Official source

Consult complete regulation at 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-2026-16807