The current IPCEI wave has changed how the project portfolio is submitted: not everything must be ready on day one. But the sections that must be ready decide whether your file enters assessment at all.
In the AI wave, the Commission staggered the project portfolio into three colour-coded groups to speed up applicants' work. The green sections are the minimum required to pre-notify: the company description, the R&D&I and FID contents, and proportionality, including the funding gap. A file without them is sent back. The yellow sections, the form of the aid and the confirmation that the company is not an undertaking in difficulty, can be drafted by the applicant but should be scrutinised by the national State aid experts. The blue sections, targeted DNSH and the quantitative competition assessment, can wait for a second pass, when the coordinators call for them; the qualitative market description is filled in from the start.
What happens after submission
The staging does not change the destination: all parts of the PP are ultimately necessary for the notification to be complete, and applicants who are ready may submit the full portfolio at pre-notification. From there, the file follows a fixed path. National authorities pre-screen for completeness and quality and ask for improvements. In pre-notification, the Commission asks its questions and the PP is adjusted throughout, in step with the batch-by-batch construction of the joint chapeau document. Later come common questionnaires sent to all participants, on spillovers, on DNSH, and the competition assessment template. The practical implication: someone in each project team should be thinking about spillovers and market data well before the corresponding questionnaire lands.
One more process reality worth knowing early: a claw-back mechanism will apply and its design is discussed between the Commission, the coordinator and the Member States during the procedure. Applicants who see a problem with that are expected to raise it in time, not at the end.
The takeaway.
Sequence your effort the way the Commission sequences its reading: perfect the green core first, book your national authority's time for the yellow parts, and assign owners now for the blue questionnaires that will arrive mid-procedure.
Sources
– IPCEI Communication, OJ C 528, 30.12.2021 (EUR-Lex)
– European Commission – IPCEI overview (DG Competition)
– European Commission, IPCEI project portfolio template (v1, October 2023; adjusted for IPCEI AI, 2026), distributed to applicants via national authorities
– DG COMP Unit H23, IPCEI AI workshop for direct participants and Member States: project portfolio, funding gap and spillovers, 12 June 2026 (workshop materials)