CMA's Subsidy Advice Unit Publishes Final Report on £350m Critical Chemicals Resilience Fund, Closing Its Review Under the Subsidy Control Act 2022
The Competition and Markets Authority's Subsidy Advice Unit (SAU) published its final report on 21 October 2026, closing its review of the proposed Critical Chemicals Resilience Fund (CCRF), a subsidy scheme put forward by the Department for Business, Innovation, Science and Trade (BIST). The case was opened on 10 September 2026 and has now closed. The CCRF is a scheme with an overall budget of £350 million, available until the end of March 2030, designed to improve resilience in the UK chemicals sector. Eligible producers of strategically important chemicals, including those supplying Critical National Infrastructure sectors and key supply chains, will be invited to apply for funding for new capital projects. Successful applicants could receive up to 50% of eligible costs for projects that improve resilience and competitiveness. Eligible companies were identified by BIST and ratified by a panel of industry experts. The SAU's role was to evaluate BIST's own assessment of whether the scheme complies with the subsidy control requirements set out in the Subsidy Control Act 2022. This assessment, known as an Assessment of Compliance, is required for Subsidies of Particular Interest. The SAU's report provides advice to BIST but the ultimate decision on whether to proceed with the scheme rests with BIST. The scheme was due to open for applications in autumn 2026.
Why this matters
The CCRF is a meaningful industrial policy intervention: a £350 million scheme targeting chemicals businesses embedded in Critical National Infrastructure supply chains reflects the government's concern about supply chain fragility following post-pandemic shortages and geopolitical disruption. The SAU review process under the Subsidy Control Act 2022 is still relatively new, and each published final report adds to the body of precedent for how government departments should structure and justify large subsidy schemes. For chemicals and industrial businesses, the fund represents a significant source of capital for infrastructure modernisation that would otherwise require private financing.
On the Ground
The scheme will generate public law and regulatory advice work as eligible companies assess whether to apply and how to structure compliant business cases, including additionality, value for money, and environmental impact arguments required by BIST. State aid and subsidy control specialists will be advising both potential applicants and their lenders on how scheme funding interacts with private financing. A trainee working on a related matter would prepare regulatory filing coordination materials, summarise licence and scheme criteria conditions, and draft compliance gap analysis memos comparing a client's proposed project against the CCRF eligibility criteria.
Interview prep
Question you might get
“What is the role of the Subsidy Advice Unit in reviewing a government subsidy scheme, and how does the Subsidy Control Act 2022 framework differ from the old EU state aid regime?”
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