Regulation
The Competition and Markets Authority's Subsidy Advice Unit (SAU) on 24 August 2026 accepted a referral from Transport Scotland to evaluate its proposed Scottish Zero Emission Truck (ScotZET) Fund Scheme. The scheme, classified as a Scheme of Particular Interest under the UK's subsidy control framework, proposes up to £240 million in public funding to accelerate the mass transition of heavy goods vehicles (HGVs) to zero-emission powertrains, with a particular focus on SMEs (small and medium-sized enterprises) that dominate Scotland's haulage sector. Funding will be awarded only to consortia. Each consortium must include at minimum one private finance provider and four HGV operators, and may also include energy companies, charge point operators, and manufacturers. Any HGV operator participating must operate services to, from, or within Scotland, and vehicles and supporting infrastructure must be based in Scotland for the project's duration. There is no fixed cap on the amount any individual consortium can receive. Funding will be delivered competitively over a three-year period spanning 2027-28 to 2029-30. Applicants must package both zero-emission vehicle deployment and the energy infrastructure required to support it. The SAU is required to publish its compliance report by 5 October 2026, with the deadline for third-party submissions set at 7 September 2026.
Why this matters
The ScotZET referral is part of a growing pipeline of large public-subsidy schemes being tested against the UK's post-Brexit subsidy control framework, which replaced EU state aid rules and sits under the CMA's SAU function. A £240m scheme targeting a sector dominated by SMEs is commercially significant because it creates new capital flows into the HGV electrification supply chain, and the consortium structure, requiring private finance as a mandatory partner, is designed to leverage additional private capital alongside public funding. The SAU's assessment will be watched closely by hauliers, energy infrastructure providers, and fleet financiers because the outcome determines whether the scheme proceeds, is modified, or is blocked on subsidy control grounds.
On the Ground
The legal work here sits at the intersection of public procurement, subsidy control, and energy infrastructure finance. Regulatory practices will be advising potential consortium members, energy companies, and charge point operators on eligibility, compliance obligations, and the structure of consortium agreements. Finance practices will be advising the private finance providers who must anchor each consortium, including on the terms under which public and private capital are blended. Trainees on a matter like this would be drafting regulatory notification submissions for the third-party comment window closing 7 September, preparing compliance gap analysis memos against the SAU's published methodology, and summarising licence conditions applicable to charge point infrastructure.
Interview prep
Question you might get
“How does the UK's subsidy control framework, operated through the CMA's Subsidy Advice Unit, differ from the EU state aid regime it replaced, and what does that mean for a scheme like ScotZET?”
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