Request Received: 3 July 2025
Under the Freedom of Information Act 2000, I am requesting access to the following information in relation to the Launchpad competition project number 10150400 (Raidmed Ltd) and more broadly the classification of funding awards under the UK subsidy control regime:
1. Internal Communications and Legal Advice Any internal documents, emails, or meeting minutes from UKRI or Innovate UK that contain legal advice, interpretations, or discussions relating to the classification of grant awards under the De Minimis Regulation versus the Minimal Financial Assistance (MFA) route, especially in the context of the Windsor Framework and Northern Ireland-based applicants.
2. Criteria or Policy Documents Used to Determine Classification Any guidance documents, criteria, internal policy, or decision-making frameworks used by UKRI/Innovate UK to determine whether a specific project or applicant should be classified under De Minimis or MFA. This includes documents relevant to decisions involving medical device development projects and mixed hardware-software proposals.
3. Correspondence with External Authorities Any correspondence between Innovate UK and HMRC, DSIT, or other government departments specifically referencing project 10150400 (Raidmed Ltd), or more generally discussing the interpretation of De Minimis and MFA frameworks in relation to NI-based applicants.
4. Assessment of Raidmed’s Eligibility Any recorded assessments, internal justifications, or decision notes made by UKRI/Innovate UK in determining that project 10150400 (Raidmed Ltd) must be classified under De Minimis, including references to the product’s nature, subsidy control rationale, or treatment of similar projects.
First Clarification Received: 23 July 2025
1. Time Frame and Search Terms To assist with your search for information under points 1 and 2 of my original request, I suggest the following terms which may be relevant:
• Search terms: "De Minimis", "Minimal Financial Assistance", "MFA", "Windsor Framework", "subsidy control", "state aid", "Norther Ireland", "Launchpad"
• Date range: 1 January 2023 to present
• Context: Please focus on correspondence, documents, or internal advice specifically relating to the classification of Innovate UK Launchpad grants under De Minimis vs MFA, including any input or guidance from the UK Subsidy Advice Unit or internal subsidy/legal teams.
2. Points 3 and 4 While these relate to Raidmed Ltd specifically, I would still like them to be considered under the FOI process. The rationale is that applicants and the public have a legitimate interest in understanding the process, rationale, and legal basis for grant award classifications, especially where they may impact structural fairness or competitiveness between UK nations. As such, I believe it is in the public interest to include these points in the response.
Second Clarification Received: 13 August 2025
I would like to revise and narrow the scope of my request as follows:
Please conduct a search of internal email communications and documents from 1 January 2024 to 1 July 2025 that include both of the following:
1. The term “Launchpad”, and
2. At least one of the following terms:
• “De Minimis”
• “Minimal Financial Assistance”
• “Windsor Framework”
• “subsidy control”
Additionally, please restrict the search to communications and documents authored by or sent to any of the following individuals:
• <Redacted>
• <Redacted>
• <Redacted>
• Members of the UKRI Subsidy Advice or Legal teams
I hope this refinement brings the scope within the time/resource limits under Section 12, while retaining the intent of the original request — to understand the rationale, precedent, or internal communications behind the classification of Northern Ireland-based Launchpad grants under De Minimis rather than MFA. Separately, I wanted to follow up on your helpful note that “Innovate UK would be able to explain how classifications are determined under De Minimis or MFA and direct you to the publicly available statutory guidance.” My understanding, based on previous correspondence with Innovate UK, is that the subsidy control regime provides high-level frameworks, but there is no explicit statutory guidance that clearly defines when a grant should fall under MFA versus De Minimis — leaving that judgement to the granting body on a case-by-case basis. I have not seen any statutory guidance that prescribes classification rules for individual grant schemes such as Launchpad, nor have Innovate UK staff (including <Redacted>) previously been able to point me to such a source. I would therefore appreciate clarification as to whether this guidance is (a) public and general, or (b) internal to UKRI/IUK.
If such guidance does exist — especially anything produced by BEIS, DfE, or UKRI to inform decision-making in Northern Ireland under the Windsor Framework — I would be very grateful if you could point me to it.
