CMA Subsidy Advice Unit publishes final report on Scotland's proposed £240m zero-emission truck fund, clearing the way for Transport Scotland to proceed
On 29 September 2026, the Competition and Markets Authority's Subsidy Advice Unit (SAU) published its final report evaluating Transport Scotland's proposed Scottish Zero Emission Truck (ScotZET) Fund, a subsidy scheme of up to £240 million designed to support the mass transition of heavy goods vehicles (HGVs, meaning large freight trucks) to zero-emission powertrains. The SAU accepted the referral on 24 August 2026 and published its report within the statutory 30-working-day timetable, closing the case the same day. The SAU's role under the Subsidy Control Act 2022 is to evaluate whether Transport Scotland's own assessment of the scheme's compliance with the Act's subsidy control requirements is adequate, not to approve or block the scheme outright. The ScotZET Fund would be open only to consortia (groups of organisations rather than individual applicants), each comprising at minimum one private finance provider and four HGV operators. Funding would run across a three-year window from 2027-28 to 2029-30, awarded competitively with no fixed cap per consortium. Applications must combine deployment of zero-emission HGVs with the supporting charging or refuelling infrastructure. The scheme is targeted particularly at SMEs (small and medium-sized enterprises), which dominate Scotland's haulage sector, and is designed to support both fleet transition and workforce development.
Why this matters
The SAU report is a significant step in giving the ScotZET Fund regulatory clearance: by completing its evaluation within the statutory period under the Subsidy Control Act 2022, it removes a key compliance hurdle for Transport Scotland. The scheme's consortium-only structure and requirement to bundle vehicle deployment with infrastructure signals a deliberate policy choice to de-risk the market alongside the fleet transition, rather than simply subsidising truck purchases. At £240 million, this is a material public subsidy with implications for the competitive dynamics of Scotland's haulage market and the wider zero-emission HGV supply chain. The SAU's involvement also illustrates how the post-Brexit UK subsidy control regime is operating in practice for devolved governments seeking to offer targeted industrial support.
On the Ground
The legal work spans public procurement and state aid (now subsidy control): firms advising Transport Scotland or prospective consortium members will need to review the SAU's compliance evaluation and ensure bid structures conform with the Subsidy Control Act 2022 requirements. Consortium formation itself generates commercial contracts work, including co-investment agreements between financiers, hauliers, energy companies, and charge-point operators. Infrastructure deployment raises planning, environmental, and grid-connection advisory work. A trainee on a subsidy control matter would draft summaries of SAU guidance, prepare regulatory filing checklists, review draft consortium agreements against the scheme's eligibility criteria, and coordinate input from local-counsel equivalents in Scotland.
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