Subsidy Control Policy

Walsall Community Active Projects CIC

Company number 17051741

Subsidy Control Policy

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1. Statement of Intent

Walsall Community Active Projects CIC receives grants and other support from public bodies. We are committed to handling this funding lawfully and transparently, in line with the UK's subsidy control rules.

This policy sets out how we identify, record and report public funding that may count as a subsidy.

2. What is Subsidy Control?

Subsidy control is the UK's framework for managing financial support given by public bodies to organisations carrying out economic activity. It replaced EU State Aid rules after the UK left the European Union. The main legislation is the Subsidy Control Act 2022, in force since 4 January 2023.

A subsidy is financial assistance that:

• Comes from public resources (central or local government, public bodies, lottery funds, and some others)
• Confers an economic advantage on the recipient
• Is specific to certain organisations or types of activity
• Could affect competition, investment or trade in the UK or internationally

Not all public funding is a subsidy. For example, payments for services delivered on standard commercial terms may not count.

3. Who This Policy Applies To

This policy applies to all staff, volunteers and trustees involved in applying for, receiving, accounting for or reporting on public funding.

4. Key Categories

• Minimal Financial Assistance (MFA): small-scale public funding up to £315,000 over a rolling three-year period, with simplified rules.
• Services of Public Economic Interest (SPEI): support for services that the market would not otherwise provide adequately, up to £725,000 over a rolling three-year period.
• Subsidy schemes: approved schemes that public bodies operate under set rules.
• Stand-alone subsidies: individual subsidies assessed against the seven subsidy control principles.

5. Our Responsibilities

When applying for or accepting public funding, we will:

• Read the funding agreement carefully to understand how the funder is treating the award (for example, as MFA)
• Provide accurate information about previous public funding when asked
• Keep records of all subsidies received
• Cooperate with funders to support publication on the UK subsidy transparency database where required
• Seek advice if we are unsure

6. MFA Declarations

When asked by a funder for a Minimal Financial Assistance (MFA) declaration, we will:

• Provide an honest, complete list of MFA we have received in the current and previous two financial years
• Include MFA received by any group, parent or subsidiary company we are connected to, where we form part of a single 'economic actor'
• Keep a copy of every declaration in our subsidy register
• Check we are not exceeding the £315,000 MFA threshold over the rolling three-year period

Providing false or incomplete information could lead to funds being recovered, loss of future funding and reputational damage.

7. Subsidy Register

The Finance Lead will keep a Subsidy Register recording:

• The name of the funder and the name of the funding programme
• The date the subsidy was awarded
• The amount of the subsidy, or estimated cash-equivalent value of in-kind support
• The subsidy control category used (MFA, SPEI, scheme, stand-alone)
• The purpose for which the subsidy was given
• The period the funding covers
• Any conditions attached
• Whether the subsidy has been published on the UK subsidy database (the funder is normally responsible for this)

The register will be reviewed at least every six months by the Finance Lead and presented to the Board at least once a year.

8. Transparency and Public Database

Public authorities are normally responsible for publishing subsidies above set thresholds on the UK subsidy transparency database. We will:

• Cooperate fully where a funder needs information from us in order to publish
• Not object to lawful publication of subsidy information about us
• Treat the use of public funds as a matter of public interest

9. Prohibited and High-Risk Subsidies

Some forms of subsidy are prohibited or subject to extra rules under the Subsidy Control Act, including:

• Unlimited state guarantees
• Export performance subsidies
• Subsidies that depend on using domestic over imported goods
• Subsidies to companies in difficulty (in certain situations)
• Subsidies for relocating jobs or activity within the United Kingdom

We will not knowingly accept any subsidy of this kind. If we are unsure, we will seek advice from the funder, our accountant or a legal adviser.

10. Conflicts of Interest

Conflicts of interest can affect how public funding is awarded and managed. This policy works alongside our Conflict of Interest Policy. Anyone with a personal interest in a funder, applicant or partner organisation must declare it before being involved in funding decisions.

11. Record Retention

Subsidy records will be retained for at least 6 years from the end of the funding period, in line with HMRC and funder requirements.

12. Training and Awareness

The Founder and Finance Lead will keep up to date with subsidy control rules and guidance from the UK Government, the Subsidy Advice Unit at the Competition and Markets Authority, and our funders. Key information will be shared with the Board.

13. Concerns

Concerns about possible breaches of subsidy control rules should be raised through our Whistleblowing Policy.

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Policy Review

This policy was adopted on 14 February 2026 and will be reviewed annually, with the next scheduled review in February 2027. It will also be reviewed earlier if there are significant changes in legislation, guidance, or our activities.

All staff, volunteers and trustees will be made aware of any updates and asked to confirm they have read and understood the revised version.

Signed on behalf of the Board