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The National Transparency Registers in Action

Katrine Lillerud


Keywords: Ex post evaluation, block exemptions, national transparency registers, individual aid, privatization of State aid enforcement, Transparency communication

National registers on individual aid grants above €500 000 became mandatory from 1 July 2016. The European Commission hopes the registers will promote compliance, raise awareness on aid granted and function as a disciplinary measure. They count on the registers to ensure better control at the national level, by incentivising beneficiaries to comply and by providing enough information for competitors to check whether aid was lawfully granted. This article provides a case study of how the national registers function in Norway, Iceland and Liechtenstein. The three European Economic Area States are an interesting case study as they are the only countries that have opted for their own national transparency registers, whilst the EU Member States all use the Commission’s portal. The findings show that the transparency registers currently do not provide the information required for competitors to assess the compatibility of an aid measure with the internal market. Almost all the published aid measures lack a link to the national legal basis or the granting authorities’ decision on the individual aid measure. These shortcomings are easily corrected. However, if left unattended, they arguably render block exempted aid unlawful. Currently, the effect of the national registers appears to be that they induce competitors to apply for aid rather than litigate on it.
Keywords: Ex post evaluation; Block exemptions; National transparency registers; Individual aid; Privatization of State aid enforcement; Transparency communication

Katrine Lillerud is currently finalizing her PhD thesis at the European University Institute. The current article is a result of her PhD research with supervisor Prof Giorgio Monti. She is usually lawyer with the law firm DLA Piper Norway (permission of absence for the duration of the PhD). For correspondence: <>.


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