What is Minimal Financial Assistance?
Minimal Financial Assistance is a category of subsidy under the UK Subsidy Control Act 2022. It allows the UK Government to provide relatively small amounts of financial support to businesses without the need for detailed subsidy justification, provided the cumulative support stays within a set threshold.
The MFA threshold is the equivalent of 325,000 Special Drawing Rights (SDRs) over three rolling fiscal years. At current exchange rates, this equates to approximately £315,000. This cap applies to your entire business group, not just the individual entity applying for funding.
Under the Growth Guarantee Scheme, the subsidised element of each loan counts toward your MFA total. This is not the full loan amount but rather the value of the 70% government guarantee that benefits the lender and, indirectly, the borrower through better pricing and access than would otherwise be available.
What counts toward the MFA limit?
Any previous Minimal Financial Assistance received from any UK public body within the three previous complete fiscal years must be declared when applying for a GGS facility. This includes previous GGS loans, Recovery Loan Scheme loans, grants from local enterprise partnerships, innovation grants, and other government-backed subsidies that are classified as MFA.
The relevant period is the three most recently completed UK fiscal years (April to March). So if you are applying in early 2026, you would need to declare MFA received in the fiscal years 2022/23, 2023/24, and 2024/25.
- Previous GGS facilities from any accredited lender
- Recovery Loan Scheme (RLS) facilities received after 6 April 2022
- Innovation grants classified as MFA
- Local enterprise partnership grants if classified as MFA
- Any other government-backed subsidies classified as MFA under UK Subsidy Control
What does NOT count toward the MFA limit?
CBILS and CLBILS facilities taken before 30 June 2022 do not count toward your GGS cumulative subsidy limit, as confirmed in the British Business Bank's published GGS FAQs. Similarly, RLS facilities taken before 1 August 2022 do not count.
Bounce Back Loans are treated differently. According to the BBB's own GGS FAQs, a BBL 'may count towards your cumulative aid allowance' - it depends on whether your BBLS lender notified you at the time that your loan was provided under EU de minimis Regulations. You should check with your lender to confirm your exact position. A business with a BBL cannot automatically assume it retains its full £315,000 MFA allowance.
- CBILS facilities (taken before 30 June 2022) - not counted
- CLBILS facilities (taken before 30 June 2022) - not counted
- RLS facilities taken before 1 August 2022 - not counted
- Bounce Back Loans (BBL) - may or may not count, depending on how your lender notified you at the time
- Standard commercial loans without government guarantee - not counted
- Invoice finance and asset finance not under a government-backed scheme - not counted
How the MFA value of a GGS loan is calculated
For most GGS facilities, the MFA-equivalent value is not the full loan amount but a smaller figure representing the economic benefit of the government guarantee. The British Business Bank provides guidance to accredited lenders on how to calculate this. In practice, for a typical SME GGS loan the MFA equivalent will often be between 5% and 15% of the facility amount, depending on the term and the creditworthiness of the borrower.
For the purposes of the MFA declaration, lenders will typically confirm the MFA-equivalent value of any previous GGS or RLS facilities you have taken. If you are unsure how to quantify your existing MFA position, a finance broker or your previous GGS lender can help you calculate it before you apply.
Implications for businesses near the MFA cap
If you have already received GGS or other MFA-qualifying support close to the £315,000 threshold, you may be restricted in how much further GGS funding you can access. In these cases, there are several options to consider.
First, check whether your previous facilities have been fully repaid, as repaid MFA support may reduce your cumulative position. Second, consider whether alternative lending products, such as standard term loans or asset finance outside a government scheme, are appropriate for your needs. Third, speak to a broker who can model your MFA position and identify the most suitable funding route.
Frequently Asked Questions
Does my Bounce Back Loan affect my GGS MFA allowance?
It may. The British Business Bank's own published GGS FAQs state that a BBL 'may count towards your cumulative aid allowance' when calculating the maximum GGS amount you can access. Whether it counts depends on whether your BBLS lender notified you at the time that the loan was provided under the EU de minimis Regulations. You will need to check with your lender to confirm your specific position - do not assume your full £315,000 MFA allowance is available without checking first.
Does a CBILS loan count toward the GGS MFA limit?
Generally no, if the CBILS facility was taken before 30 June 2022 (which applies to virtually all CBILS borrowers, as the scheme closed in April 2021). The BBB's published GGS FAQs confirm that CBILS and CLBILS facilities accessed before 30 June 2022 do not count toward the cumulative subsidy limit for GGS purposes.
Does a previous Recovery Loan Scheme (RLS) facility count toward MFA?
It depends on when the RLS facility was taken. RLS loans issued under the EU State Aid framework (before April 2022) do not count toward the GGS MFA limit. RLS facilities issued after the UK Subsidy Control regime came into force (broadly from April 2022) do count as MFA.
What happens if I exceed the MFA limit?
If your cumulative MFA exceeds £315,000, you cannot access further GGS funding. Lenders are required to verify your MFA position as part of the application process and must decline applications where the cap would be breached. However, you may still be able to access commercial lending outside the government guarantee scheme.
Does the MFA cap apply to my whole group or just my company?
The MFA cap applies to the economic unit, which in practice means your entire business group including subsidiaries and associated entities. If you have multiple trading entities under common ownership, their combined MFA must not exceed £315,000.