KG LEGAL \ INFO
BLOG

Strategic Technology Platform for Europe (STEP) Seal

Publication date: April 14, 2026

The Strategic Technologies Platform for Europe (hereinafter referred to as STEP) is a European Union initiative established to, among other things, “ensure the sovereignty and security of the Union, reduce the Union’s strategic dependencies in strategic sectors, and strengthen the Union’s competitiveness by increasing its resilience and productivity.”[1] STEP was established by Regulation (EU) 2024/795 of the European Parliament and of the Council of 29 February 2024[2], which entered into force on 1 March 2024, and provides the legal framework for the entire platform. Its primary mission is to reduce the European Union’s dependence on external technology suppliers and strengthen European value chains in key technology areas. This is part of the implementation of the European Union’s core policy of “improving the competitiveness and resilience of the European economy through the green and digital transformation.”.

STEP is not a standalone funding program, but rather a platform coordinating funds from existing EU instruments. This platform integrates funds from 11 different European Union programs to coordinate support for projects with strategic potential. This mechanism allows for more efficient use of available funds by enabling the combination of different funding sources for technological and innovative projects.

One of the most important results of STEP’s first year of operation is the mobilization of significant financial investments in strategic technologies. According to the European Commission’s communication from March 2025, during the first year of operation, the platform managed to mobilize over €15 billion for investments in key technology sectors in the European Union. These funds come from investments in 11 European Union programs, which, through STEP, have been directed to support three main technological categories: digital technologies and deep-tech innovation, clean and resource-efficient technologies, and biotechnologies. Regulation (EU) 2025/2653 of the European Parliament and of the Council of 19 December 2025 amending Regulations (EU) 2021/694, (EU) 2021/695, (EU) 2021/697, (EU) 2021/1153 and (EU) 2024/795 as regards incentivizing defense-related investments in the EU budget in order to implement the ReArm Europe plan[3]  (hereinafter referred to as Regulation 2025/2653) a fourth sector was also added, namely defence technologies.

Such a broad mobilization of resources has profound strategic implications. The European Union currently faces intense technological competition with the United States and China. Furthermore, “high inflation, labor shortages, supply chain disruptions due to the COVID-19 pandemic, Russia’s aggressive war against Ukraine, rising interest rates, and rising energy and input costs are all impacting the competitiveness of EU industry.”

Additionally, STEP also has an experimental and planning dimension: its structure and financial and coordination mechanisms are intended to serve as a test for a possible future European Sovereignty Fund, which indicates the European Union’s long-term strategy for building lasting instruments of this type.

Regulation (EU) 2024/795 of the European Parliament and of the Council

The legal act establishing STEP is the Regulation establishing a Strategic Technologies Platform for Europe (STEP) and amending Directive 2003/87/EC and Regulations (EU) 2021/1058, (EU) 2021/1056, (EU) 2021/1057, (EU) No 1303/2013, (EU) No 223/2014, (EU) 2021/1060, (EU) 2021/523, (EU) 2021/695, (EU) 2021/697 and (EU) 2021/241 of the European Parliament and of the Council (EU) 2024/795 of 29 February 2024 (hereinafter referred to as the Regulation).

The scope of the Regulation covers the establishment of STEP and the definition of the platform’s objectives (Article 2), the amount of financial support available under STEP (Article 3), the rules for the implementation of the Sovereignty Seal and the Sovereignty Portal (Articles 4-6), and the rules for reporting on STEP objectives (Articles 7-8). The Regulation also amends the wording of Article 1 of the Directive (Article 9) and Article 10 of the EU Regulations (Articles 10-19).

The Regulation’s adoption was motivated by the desire to guarantee the sovereignty and security of the European Union by reducing strategic dependencies in key technological sectors and strengthening the European Union’s global competitiveness. The Regulation’s adoption also aimed to facilitate the mobilisation of financing and create favorable investment conditions, particularly by facilitating synergies between EU programs.[4]

Characteristics of STEP and the competences of the Commission and the Member States

STEP is not a standalone funding program. STEP combines resources from 11 EU funding programs to support investments in strategic technologies and in those who can implement or manage these technologies. Support could also come from more than one EU funding program. For example, grants from the Innovation Fund could be combined with grants from the Cohesion Funds. Facilitating such cumulative funding is one of the goals of the STEP seal. In practice, this means that STEP breaks down the EU’s strategic priorities into specific actions and funding streams, identifying projects that can benefit from funding from various sources—both those directly managed by the European Commission and those implemented jointly with Member States. These resources can take the form of grants (i.e., non-repayable), but can also take the form of public procurement or financial instruments (e.g., equity, loans, and guarantees).

Although the STEP initiative was designed as a mechanism coordinated at the EU level, the role of the Member States is also crucial, as the platform does not replace national competences but relies on close cooperation between them and the European Commission. The key STEP-related tasks carried out by the Member States include: appointing a contact point for STEP implementation at the national level; providing incentives for countries to prioritize projects in the valleys of accelerated implementation of carbon-neutral technology production projects; and encouraging Member States to allocate a portion of their funds to activities supporting STEP goals. The role of the contact point in Poland is to: maintain direct contact with the European Commission regarding the adaptation of STEP activities at the national level and monitor the implementation of STEP goals in Poland; provide information on the STEP initiative to interested entities; provide information to companies with a sovereign seal on the possibility of obtaining further financing under national programs; and cooperate with managing and intermediary institutions at the national and regional levels responsible for individual funding programs.

The Regulation also lists a number of European Commission competencies related to the operation of STEP. These include: issuing guidelines that would further define certain concepts contained in the Regulation; granting the Sovereignty Seal; promoting the Sovereignty Seal; establishing and managing the Sovereignty Portal; cooperating with competent national authorities and other relevant stakeholders to coordinate and exchange information on financing needs, existing bottlenecks, and best practices in accessing finance; fostering contacts between technology sectors and promoting compatibility, coherence, synergies, and complementarity between EU programs; monitoring STEP implementation and measuring the achievement of STEP objectives; and submitting annual reports on STEP implementation to the European Parliament and the Council and making them public.

Four main strategic areas

In accordance with Article 2(1)(a) of the STEP Regulation, its purpose is to support, among others, the development or production of critical technologies across the Union or to protect and strengthen their respective value chains, in the four sectors mentioned therein (digital technologies and innovation in deep technologies, clean and resource-efficient technologies, biotechnologies, and from 2025 also defense technologies). Individual sectors will be briefly discussed below. For a discussion of individual sectors, it seems advisable to refer to the legally non-binding but practically helpful Commission Guidance on certain provisions of Regulation (EU) 2024/795 on the establishment of a Strategic Technologies Platform for Europe (STEP) (C/2024/3209) (hereinafter referred to as the Guidance). They also define the term value chain which refers to: final products; specific components and specific machinery primarily used for the production of those final products; critical raw materials listed in Annex II to the Critical Raw Materials Act; related services that are crucial and specific to the development or production of those final products; and technologies covered by the Carbon Neutral Industry Act (CNIA).

Digital technologies

The 2030 “Getting to a Digital Decade” policy agenda establishes digital goals and targets related to digital skills, digital infrastructure, the digitalization of businesses, and the digitalization of public services. It lists several digital technologies contributing to these goals and targets, including artificial intelligence, 5G, 6G, blockchain, cloud and edge computing, and the Internet of Things. The Guidelines provide an illustrative list of digital technology areas relevant to STEP. These include advanced semiconductor technologies, artificial intelligence technologies, quantum technologies, advanced communications and navigation, advanced digital technologies, advanced sensing technologies, and robotics and autonomous systems.

Clean and resource-efficient technologies

According to Article 2(1) of the STEP Regulation, clean and resource-efficient technologies include carbon-neutral technologies as defined in Article 4 of the Carbon Neutral Industry Act. Examples include: solar technologies; onshore and offshore renewable wind energy technologies; battery and energy storage technologies; heat pumps and geothermal technologies; hydrogen technologies; sustainable biogas and biomethane technologies ; carbon capture and storage technologies; electricity grid technologies; nuclear fission technologies, sustainable alternative fuel technologies; hydropower technologies; other renewable technologies; energy efficiency technologies related to the energy system; renewable fuel technologies of non-biological origin; biotechnology solutions for climate and energy; transformative industrial technologies for decarbonisation; CO2 transport and utilisation technologies; wind and electric propulsion technologies; other nuclear technologies; advanced materials, manufacturing and recycling technologies, key technologies for sustainable development such as water purification and desalination, and circular economy technologies.

Biotechnologies

Recital 6 of the STEP Regulation indicates that biotechnology should be understood as the application of science and technology to living organisms, as well as parts, products and models thereof, for the purpose of modifying living or non-living materials to create knowledge, goods and services. This definition is intentionally broad and encompasses current and future biotechnology activities and is consistent with the uniform statistical definition of biotechnology developed by the OECD. Biotechnology can also be broadly defined as any technological solution that uses biological systems, living organisms or their derivatives to make or modify products or processes for a specific use. Application sectors of biotechnology include biotechnology-based industries (e.g. packaging materials, textiles, composite materials, insulation and construction materials, biofuels, paints, adhesives, solvents); environmental services (e.g. biosensors, removal of pollutants from soil/water/air); the agri-food sector (e.g. biofertilizers ) or the pharmaceutical and medical sector (e.g. vaccines, organoids, therapeutics). (gene and cell)”. The Guidelines also provide an indicative list of biotechnology areas relevant to STEP, based on statistical definitions derived from the OECD list. These include: DNA/RNA; proteins and other particles; cell and tissue culture and engineering; biotechnological process techniques; RNA genes and vectors; nanoinformatics and nanobiotechnology.

Defense Technologies

Defense technologies were not initially listed in the Regulation. They were added by Regulation 2025/2653. The reasons for introducing the fourth sector to the platform can be found in the recitals of Regulation 2025/2653, which include: unprecedented geopolitical instability; the rapidly escalating threats; the deterioration of regional and global security, in particular Russia’s unprovoked and unjustified aggressive war against Ukraine; the risk of conventional military threats; the desire to mobilise EU funds in a coordinated and synergistic manner for use in the field of defense, including for key pioneering digital technologies necessary for the development of defense products and technologies, as well as ensuring the use of STEP incentives to increase EU funding for innovative defense technologies to effectively respond to current and emerging threats and contribute to improving European competitiveness in line with the STEP objectives.

Regulation 2025/2653 also includes a definition of defence technologies, as they are technologies incorporated into defence-related products or necessary for their development and production, including defence-related products referred to in the Annex to Directive 2009/43/EC of the European Parliament and of the Council.

Supporting projects through STEP

A key element of the STEP platform is the identification and selection of suitable projects of strategic importance to the European Union. According to the Regulation, STEP aims to ensure the sovereignty and security of the Union, reduce the Union’s strategic dependencies in strategic sectors, strengthen the Union’s competitiveness by increasing its resilience and productivity and mobilising financing, foster a level playing field for investment in the internal market, support cross-border participation, including for SMEs, strengthen economic, social and territorial cohesion and solidarity between Member States and regions, and promote inclusive access to attractive and high-quality jobs by investing in future-proof skills and adapting the Union’s economic, industrial and technological base to the requirements of the green and digital transformations. To achieve the above-mentioned objectives, criteria had to be developed to determine which projects should receive STEP funding. First, the project must contribute to one of the four sectors listed in Article 2(1)(a) of the Regulation and meet at least one of the following two criteria:

  1. bringing to the internal market an innovative, cutting-edge and groundbreaking element with significant economic potential
  2. contributing to reducing or preventing the Union’s strategic dependence and vulnerability to threats.[5]

Ad. a) According to the Guidelines: Innovative elements introduce the key criterion of ‘novelty’, which leads to significant improvements or changes in a given field or industry. State-of-the-art elements refer to new, recently developed technologies that may, for example, stem from the research base and are beginning to gain traction and offer opportunities for significant growth or impact. Disruptive elements refer to the most advanced, innovative and sophisticated technologies currently available or under development in the Union. STEP support should prioritise breakthrough innovations that have the potential to shape, disrupt or create markets and provide significant economic potential for the Union. The significance of the economic potential should be assessed in terms of technologies that could address different Union markets (rather than markets located in a given geographical area) or have a significant impact on the development or production of technologies. Technologies covered by STEP are those that are likely to generate the largest spill-over effects on other Member States, which can enhance the economic potential of the Single Market (as stated in recital 5 of the STEP Regulation). external cross-border activities can be measured by their positive contribution to economic growth, employment and investment in research and development.

Ad. b) “For the purposes of the STEP Regulation, a number of factors should be taken into account when determining whether technologies reduce or prevent the Union’s strategic dependencies:

Contributing to the Union’s industrial and technological leadership: The Union’s industrial and technological leadership in the relevant sectors covered by STEP would provide the Union with a competitive advantage in the global technological landscape and help prevent lock-in. STEP could, for example, support the development of advanced manufacturing techniques, such as additive manufacturing, which could increase the Union’s competitive advantage in high-tech industries.

Contributing to critical infrastructure at European level: Unrestricted access to essential components and technologies will enable the development and production of critical infrastructure in the EU without the risk of disruption or delivery delays. For example, STEP could support the development of critical technologies essential for space and ground satellite systems and electricity grids.

Increasing production capacity: By increasing production capacity for critical raw materials, critical components or value chains within the Union, where there is a risk of strategic dependence within the Union, certain investments can directly reduce dependencies on third-country sources, thereby increasing the Union’s self-sufficiency and resilience. STEP could, for example, support the creation of production facilities for critical components or their value chain, including energy storage facilities, semiconductor chips or pharmaceuticals.

Enhancing security of supply: Enhancing the security of supply of key inputs, components, and technologies in the Union implies a widespread recognition of the collective management of dependencies. This measure can address regional security of supply and thus enhance the Union’s ability to effectively address supply disruptions and vulnerabilities in any part of its territory. STEP could, for example, support the repatriation of production of specific critical pharmaceuticals where the Union has strategic dependencies, or by supporting projects involving critical raw materials.

Promoting positive cross-border effects in the internal market: Fostering cooperation and coordination in the internal market can contribute to building resilient supply chains across industry and downstream sectors. This also fosters a level playing field, thereby reducing distortions and increasing overall competitiveness. STEP could, for example, support the coordinated development of advanced battery storage systems for renewable energy integration by pooling expertise and resources across Member States.”[6]

STEP Seal

One of the elements introduced by Regulation 2024/795 is the Sovereignty Seal (hereinafter referred to as the Seal), which is regulated in Article 4 of Regulation 2024/795. This instrument provides a mechanism for identifying high-quality projects. The Seal should also be used as a quality mark to help projects attract public and private investment by certifying their contribution to achieving the STEP objectives. The Sovereignty Seal should also support better access to Union funding, facilitating in particular cumulative or combined funding from several Union instruments. Member States should also be encouraged to take the Sovereignty Seal into account when granting financial support through their own programmes. Examples include the obligation for Member States to prioritize projects awarded the Seal of Sovereignty when completing their recovery and resilience plans, or the possibility to prioritize projects involving clean and resource-efficient critical technologies awarded the Seal of Sovereignty when deciding on the financing of investment projects from their respective shares in the Modernization Fund pursuant to Article 10d of Directive 2003/87/EC. Furthermore, they may decide to grant national support to projects awarded the Seal of Sovereignty and contributing to the achievement of the STEP objective.

The seal is awarded in competitions centrally managed by the European Commission. Entities can receive the distinction through STEP calls for proposals announced under five EU funding programs: Digital Europe, the European Defence Fund, EU4Health, Horizon Europe, and the Innovation Fund. Projects are evaluated for the seal in parallel.with the assessment of their funding under the STEP calls for proposals.

            The direct benefits for entrepreneurs associated with the granting of the seal include:

  • priority treatment in national calls for EU programmes,
  • strategic projects defined in the regulation on carbon-neutral industry (Net Zero Industry Act): obtaining a faster investment permit for the construction of installations.

In a sense, the seal also serves a political purpose, as it can be used as a symbolic instrument to strengthen the European Union’s position, especially in the current geopolitical competition between Europe and the United States or China. Seals can demonstrate the development of European economies in strategic technological areas. This aligns with the concept of a sovereign and strong Europe compared to other international players, as expressed in the recitals of the Regulation.

It is possible to provide examples of entities (both from Poland and other Member States) that have been awarded the seal of sovereignty.

An example is the OpenEuroLLM project, which is a pan-European initiative that brings together leading start-ups (from 9 Member States) and research organisations in the field of artificial intelligence to create an open, multilingual large-scale language model. The project received €20.6 million in funding from one of the five EU funding programmes managed by the European Commission, specifically the Digital Europe programme.

Among Polish projects, we can mention the Łukasiewicz Research Network – Industrial Research Institute for Automation and Measurements (PIAP), which focuses on underwater optical and acoustic communications, and the Lodz University of Technology, whose employees work on medical threat countermeasures. A full list of recognized projects can be found on the websites of the Ministry of Development and Technology or the European Union.

Prospects and challenges for 2026

Perhaps the most important challenge and change for 2026 regarding STEP is the expansion of cooperation within the platform to include defense technologies, as discussed in more detail in Chapter 4.4. Given the ongoing war in Ukraine and numerous international tensions, including internal crises within the NATO alliance, it seems crucial to invest in the defense sectors of member states to ensure the security of the community’s inhabitants.

The EIC STEP Scale- up program, supported by the European Innovation Council (EIC), will continue in 2026. This program is primarily aimed at SMEs that have already secured a planned investment, which carries significant risk, making it difficult to obtain funding from market investors. The process consists of two stages (application submission and a jury interview). Projects are assessed according to three criteria (company excellence, impact, and risk level). The program has a budget of €900 million for 2025-2027.

The Polish Ministry of Funds and Regional Policy, the Managing Authority of the FENG (European Funds for Modern Economy) program, which allocates funds to the implementation of STEP objectives, has announced the schedule of applications for 2026. Both the National Centre for Research and Development and the Polish Agency for Enterprise Development will accept applications for funding projects in the field of biotechnology, digital technologies and deep tech , as well as clean and resource-efficient technologies. According to the planned schedule, the first calls for proposals should launch in April.

Additionally, events such as the European Commission’s announcement of a billion euros to increase the use of artificial intelligence in key industries as part of efforts to reduce the European Union’s dependence on American and Chinese technologies, or the European Investment Bank’s allocation of 70 billion euros to the development of European technology companies, are worth mentioning. Although such initiatives are not directly related to STEP, they create a financial environment that can support STEP mechanisms in strategic areas.

Summary

STEP represents a shift in the European Union’s approach to industrial and technology policy. The platform’s introduction does not create any new funds, but facilitates the coordination of existing financial instruments to focus support on technologies that are crucial to the Union’s economic and geopolitical future. STEP aligns with the concept of building European technological sovereignty. The focus on digital technologies, resource-efficient technologies, and biotechnologies reflects the Union’s strategic priorities in the digital, green, and health transformations. The expansion of the scope to include defense technologies further underscores the growing importance of industrial resilience and security in the context of rising international tensions and conflicts.

A key element of the platform is the sovereignty seal, which not only serves as a quality mark but also strengthens the position of strategically important projects in the European financial system. This mechanism builds recognition for initiatives deemed crucial to European value chains.

Over the course of this year and the next few years, STEP may emerge as a tool of growing systemic importance. The integration of financial resources and incentives for member states to direct funds towards strategic priorities indicate that the platform is intended to be a permanent element of European economic policy.

Ultimately, STEP can be seen as the European Union’s response to the global technological race and changing geopolitical conditions. STEP signals the EU’s pursuit of greater strategic autonomy, the building of strong European value chains, and ensures that key future technologies are developed and implemented within the EU.


[1]Article 2 paragraph 1 in principle of Regulation (EU) 2024/795 of the European Parliament and of the Council of 29 February 2024 on establishing a Strategic Technologies Platform for Europe (STEP) and amending Directive 2003/87/EC and Regulations (EU) 2021/1058, (EU) 2021/1056, (EU) 2021/1057, (EU) No 1303/2013, (EU) No 223/2014, (EU) 2021/1060, (EU) 2021/523, (EU) 2021/695, (EU) 2021/697 and (EU) 2021/241

[2]Article 1 paragraph 1 of Regulation 2024/795.

[3]Regulation (EU) 2025/2653 of the European Parliament and of the Council of 19 December 2025, Article 5, point 1

[4]Recital (13) of Regulation 2024/795

[5]Article 2, paragraph 2 of Regulation 2024/795 and https://www.gov.pl/web/rozwoj-technologia/platforma-technologii-strategicznych-dla-europy-step accessed on 12/02/2026

[6]Commission Guidelines point 3.2 C/2024/3209 OJ EU.C.2024.3209 of 2024.05.13

 

UP