Combining the research allowance with other funding

In short: the research allowance (Forschungszulage) and other funding programmes are not mutually exclusive. § 7 (1) FZulG expressly permits the allowance alongside other funding or state aid for the same project. The limit is set by § 7 (2) FZulG: expenses that have already been or will be funded elsewhere must not flow into the assessment base. What is prohibited is therefore not the combination, but double funding of the same euro.

Not either/or: the programmes can be combined

The most common misconception in first conversations is: “We have a ZIM grant – so the research allowance is off the table.” The law says the opposite. § 7 (1) FZulG: “The research allowance may, subject to paragraph 2, be granted alongside other funding or state aid for the eligible research and development project.” So the same project may be funded through a grant and through the research allowance in parallel.

In practice this is even the normal case: a grant programme usually covers only part of the costs and often only a defined project period. Everything else that runs alongside it in research and development – additional staff, additional work packages, additional years – remains available for the research allowance.

The limit: each expense only once

§ 7 (2) FZulG frames the cumulation ban in terms of expenses: eligible expenses within the meaning of § 3 (1) to (4) FZulG must not be included in the assessment base under § 3 (5) FZulG to the extent that they have been or will be funded through other funding or state aid. This expressly also applies to funding from EU sources.

The decisive words are “to the extent that”. The yardstick is not the company and not the project, but the individual expense:

• Not excluded: staff costs of employees who do not work on the funded part of the project.
• Not excluded: hours of the same person spent on an eligible R&D project outside the subsidised work package.
• Excluded: precisely the share of costs already covered by the grant.

Example: a ZIM grant and the research allowance side by side

An SME has €400,000 of R&D staff costs (employer gross, attributable pro rata to an eligible project). €120,000 of that is covered by a grant. Only this share drops out of the assessment base:

The grant remains fully intact – it is not reduced. Anyone who drops the allowance altogether out of fear of the cumulation ban gives up €98,000 here. For projects that started after 31 December 2025 there is also an overhead flat rate of 20% on the remaining eligible expenses (§ 3 (3b) FZulG); which cost types count in the first place is shown in the overview of eligible costs.

Which programmes are affected

The cumulation ban is worded programme-neutrally: it applies to any funding or state aid that carries the same expense. In practice we mostly see grants from ZIM, EXIST, project funding from the federal ministries BMBF and BMWK, state-level programmes of the development banks, and EU funds such as Horizon Europe – the latter being expressly included in § 7 (2) FZulG.

Not every form of financing automatically counts as funding within the meaning of the provision: whether a loan qualifies as state aid, for instance, depends on its terms. That assessment belongs to the individual case and should be clarified before you apply.

What you have to disclose in the application

The combination is not a grey area but a standard case that is actively asked about: § 7 (3) FZulG requires the application under § 5 FZulG to contain the information needed to establish the conditions of paragraph 2. So you must disclose other funding – and be able to show which expenses it covers.

What has proven itself in practice:

• Delimit work packages cleanly: separate the grant project and the R&D work going beyond it – in content and in time.
• Track hours per project: document per person and month which hours fall on the funded work package and which do not.
• Mirror it in cost centres: reflect the separation in your accounts so that grant drawdowns and the research allowance use the same figures.
• Use the proof of use: the amounts settled under the grant are exactly the amounts to be deducted from the assessment base.

The cap: €15 million per company and project

Under state-aid law there is an additional ceiling across all programmes: under § 9 (3) FZulG, the total state aid granted for an R&D project including the research allowance must not exceed €15 million per company and project. For mid-sized companies this is rarely the effective limit – there, the maximum assessment base under § 3 (5) FZulG binds first, which stands at €12 million for expenses incurred after 31 December 2025. The 2026 figures are set out under changes in 2026.

Conclusion: separate rather than forgo

An ongoing grant is not a reason to be excluded from the research allowance – it only reduces the assessment base by exactly the funded share. Separate the expenses cleanly and you get both. How the entitlement works overall is shown in the complete guide; whether your project is eligible and how the delimitation from the grant project can be presented is something we clarify in the free funding check.