Streamlined Routes in subsidy control law
22nd December, 2025
Streamlined Routes are subsidy control exemptions which may be created by a Minister of the Crown and used to lawfully award subsidies by any public authority that is able to satisfy all the relevant conditions.
Subsidy control law regulates financial assistance awarded through public sector funds and resources, in situations where this will advantage businesses or other organisations engaged in economic activity. The regime works on the basis that any measure which falls within the definition of a ‘subsidy‘ is at risk of being found to be unlawful unless it is awarded in line with one of the exemptions set out in the Subsidy Control Act 2022. The Streamlined Routes are one such exemption.
How can Streamlined Routes be created?
Streamlined Routes may be “established for categories of subsidies at especially low risk of causing market distortions, that promote UK strategic policy objectives and which the Government judges to be compliant with the Subsidy Control regime” in line with the process set out at Section 10 of the Subsidy Control Act 2022.
This requires that a Streamlined Route is made by a Minister of the Crown and specifies that it is created as such. The conditions of the Streamlined Route must be laid before Parliament after it is made for forty days. If within this period either the House of Commons or the Houses of Lords resolves not to approve the scheme then it will not be created. However if not such resolution arises, the Streamlined Route will enter into law.
How can a public authority use a Streamlined Route to award a subsidy?
When all the relevant conditions of the streamlined route are satisfied, an award will be considered to have cover and deemed automatically lawful.
This means it will not be necessary for the public authority to conduct an individual examination under the subsidy control principles set out at Schedule 1 of the Subsidy Control Act 2022, nor to make a referral to the Subsidy Advice Unit as a ‘Subsidy of Particular Interest’.
Which Streamlined Routes are in force?
Three Streamlined Routes are currently in force. These are:
- Local Growth (subsidy control number: SC10782)
- Research, Development and Innovation (subsidy control number: SC10780)
- Energy Usage (subsidy control number: SC10781)
The government has said it will publish new streamlined routes, covering:
- Arts and Culture
- Community Regeneration
How can an award made under a Streamlined Route be challenged?
Subsidy control is a challenge regime. Should a public authority fail to ensure that all the conditions of a Streamlined Route have been met, then the subsidy will be at risk of challenge in the Competition Appeal Tribunal. The Competition Appeal Tribunal has the power to order the termination of the award, thereby prompting the recovery of a sum equal to the value of the subsidy from the beneficiary.
Conclusion
In the coming years Streamlined Routes are expected to become an important part of the UK Subsidy Control regime, enabling public authorities to award lower value and commonly encountered subsidies with reduced administration. However the government does not have a free hand in determining the situations when these can be established and when awarding subsidies under the cover of streamlined routes public authorities must ensure that all requirements are met.
Ward Hadaway has specialist subsidy control lawyers who can support you with the design and delivery of your projects in line with the Subsidy Control Act 2022.
Please note that this briefing is designed to be informative, not advisory and represents our understanding of English law and practice as at the date indicated. We would always recommend that you should seek specific guidance on any particular legal issue.
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