The Competition and Markets Authority (CMA)'s Subsidy Advice Unit (SAU) opened a formal review on 10 September 2026 of a proposed £350 million subsidy scheme put forward by the Department for Business, Innovation, Science and Trade (BIST). The scheme, called the Critical Chemicals Resilience Fund (CCRF), is intended to run until March 2030 and is designed to improve resilience in the UK chemicals sector, with a particular focus on producers of strategically important chemicals used in Critical National Infrastructure (CNI) sectors and key supply chains. Under the scheme, eligible companies, identified by BIST and ratified by a panel of industry experts, will be invited to apply for funding for new capital projects. Successful applicants could receive grants covering up to 50% of eligible costs of a proposed project. The scheme is due to open for applications in the autumn. BIST referred the scheme to the SAU because it constitutes a Subsidy Scheme of Particular Interest, the threshold that triggers a mandatory independent review under the subsidy control framework. The SAU will assess whether BIST's own compliance analysis meets the subsidy control requirements. Third-party submissions are accepted until 23 September 2026, and the SAU must publish its report by 21 October 2026. The CCRF is framed as targeting modernisation of infrastructure and efficiency improvements, with the aim of reducing the risk of cascading failures across interconnected chemical clusters and downstream industries that depend on continued access to critical chemical inputs.
Why this matters
The CCRF is one of the largest sector-specific industrial subsidy schemes the UK government has brought forward since the Subsidy Control Act 2022 replaced EU state aid rules. At £350 million, it tests how far the new domestic subsidy regime permits targeted support for strategic industries. The chemicals sector is deeply interconnected: a failure in one facility can cascade through supply chains for pharmaceuticals, food processing, and energy, meaning the resilience rationale is commercially and politically credible. The SAU review is not merely procedural as it will set a precedent for how the CMA scrutinises large, sector-targeted government grants going forward, shaping the appetite of other departments to deploy similar industrial policy tools. The outcome by 21 October 2026 will be watched by sectors from semiconductors to defence where analogous resilience arguments are being made.
On the Ground
This scheme activates public law and state aid (now subsidy control) practices, with firms advising either the government or potential beneficiaries on compliance with the subsidy control requirements. Companies applying for grants will need advice on structuring their business cases, demonstrating additionality and value for money, and navigating the SAU process. Any third parties wishing to object to or comment on the scheme have until 23 September to make submissions, creating a short-window advisory mandate. A trainee working on this type of matter would assist with drafting regulatory notification letters or submission responses, preparing compliance gap analysis memos against the subsidy control criteria, and coordinating third-party submission logistics.
Interview prep
Question you might get
“What does the SAU review process involve, and what legal standards must the CCRF satisfy to proceed?”
Sign up free to see the full answer
A model answer you can lift into an interview — how to frame this story for a partner.
Sign up freeMy notes
saved