Is aerospace development eligible?

Yes, as long as the behaviour of a structure, propulsion system or avionics system was open before the first test. Qualification to a fixed test procedure, by contrast, is not experimental development under Section 2 FZulG.

Aerospace R&D Tax Credit 2026

In aerospace the scope of the project decides, not the certification programme.

The certification office does not assess how strict CS-25 or DO-178C are, but whether a technical question was open beforehand and answered systematically. A supplier rarely loses an application on the technology; usually it is lost because certification evidence and development sit in the same project.

Rates, costs and limits

The essentials on the research allowance in aerospace

Funding rate: 25% of the assessment basis, 35% for SMEs. For projects started after 31 December 2025, a 20% flat rate increases the assessment basis (Section 3 (3b) FZulG); the EUR 12 million cap still applies (Section 3 (5) FZulG).
Eligible: Novel propulsion, structural and avionics concepts, qualification trials and test articles. What counts is not the certification programme but whether novelty, technical risk and systematic approach can be demonstrated.
What counts: The employer gross salary of structural, propulsion and avionics engineers for the hours spent on the project. Since 2024 also the depreciation of movable assets used exclusively for the project, such as a test rig or test article. Material for the test article itself is not eligible.
Ceiling: Assessment base of EUR 12 million per financial year, maximum research allowance EUR 4.2 million.
Contract research: 70% of the cost of commissioned development work is eligible (Section 3 (4) FZulG): wind tunnel testing, testing institutes, DLR collaborations, external certification labs.
Retroactive: Applications for closed financial years from 2022 are possible as long as the assessment period of the respective year is still open; for 2020 and 2021 it has expired (§ 12 FZulG in conjunction with § 169 AO). Projects started before 1 January 2026 do not receive the overhead allowance.

Which activities in aerospace are eligible?

The industry does not decide eligibility. The certification office checks every project against three criteria: novelty, technical risk, systematic approach. If one fails, the application fails. Below are the activities we encounter most often at aerospace companies and their suppliers, with the verdict we expect.

Boundary case: eligibility depends on the specific project.

Structures & lightweight design

Novel composite structure with unknown damage tolerance and fatigue behaviourEligible
Eligible. Novelty: No laminate or sandwich concept available on the market achieves the required ratio of weight, stiffness and residual strength for your load case. Technical risk: Whether delamination growth, residual strength after impact and fatigue behaviour land in the target range is not known before simulation and test article. Systematic approach: Layup design, FEA, test article, fatigue testing, iteration, documented by calculation reports and test protocols.
Weight optimisation of an existing structure through thickness reductionBorderline
Borderline. Routine as long as the design rules transfer. It becomes eligible when residual strength or damage tolerance at the new wall thickness demonstrably falls outside known substantiation methods and has to be re-derived.
Replacing a metal part with a composite part in a known geometryBorderline
Borderline. Eligible is the part for which no validated design exists, such as new load introduction points or joint details. Not eligible is pure material substitution using library values.
Manufacturing drawing and lay-up plan to specification for a known partNot eligible
Not eligible. Interfaces, layup, cure cycle: the result is known before the start, the procedure is documented. Effort is not a criterion of the FZulG.

Propulsion & engines

New combustion or cooling concept for hot engine componentsEligible
Eligible. Anyone who designs a cooling concept because standard solutions do not reach the required component temperature or life must explain why. That names the state of the art. Keep the rejected concepts and their measurements; that is the decisive evidence later.
Hybrid or electric propulsion with unknown system behaviour under flight conditionsEligible
Eligible. Whether power density, thermal balance and failure behaviour of the powertrain land in the target range under real flight profiles is open beforehand. Test rig series showing these variables over iterations are systematic approach and technical risk in one.
Adapting an existing engine to a new aircraft typeBorderline
Borderline. Eligible if the interaction of engine, intake and airframe is structurally or thermally unresolved and worked out in testing. Routine if the interface control document and the engine's type certificate prescribe the way.
Series integration of a certified engine to manufacturer specificationNot eligible
Not eligible. Intended installation per instructions for continued airworthiness and installation manual. Only when the interaction demonstrably deviates from the documented case does an open technical question exist.

Avionics, sensors & control

Own control strategy for active gust load alleviation or flight controlEligible
Eligible. Anyone who designs a controller because standard controllers do not achieve the required load reduction or path accuracy must explain why. Keep the rejected controller structures and their measurement series; that is the decisive evidence later.
Sensor fusion for a new structural health monitoring conceptEligible
Eligible. Whether distributed fibre sensing or acceleration signals support the required statement about structural condition at all is open beforehand. Measurement series showing signal quality and model accuracy over iterations are systematic approach and technical risk in one.
Porting existing avionics software to new hardwareBorderline
Borderline. Eligible if the real-time behaviour on the new platform is unresolved beforehand and worked out in testing. Routine if compiler, time slices and interfaces are ported to manufacturer specification.
Parameterising certified flight control software to specificationNot eligible
Not eligible. Intended use of the approved platform. Only when the platform demonstrably cannot map the requirement and a separate method is developed alongside it does an open technical question exist.

Testing, qualification & certification

Qualification trial to resolve a technical question open before certificationEligible
Eligible. A trial that shows whether a part reaches a required limit load, temperature or life at all is a gain of knowledge. With a measurement plan and abort criteria documented in advance, this is the clearest case in this group.
Wind tunnel or ground vibration test to substantiate an edge caseBorderline
Borderline. Eligible is the share in which behaviour at the edge of the operating envelope was not known beforehand. Pure confirmation trials within already substantiated limits are evidence gathering, not a gain of knowledge.
EASA certification documentation and substantiation under CS-25 without an open technical questionNot eligible
Not eligible. Pure compliance evidence for the certification authority where the technical result is already settled. The test protocols created along the way can, however, serve as evidence for an eligible project if they show iterations and not pure confirmation.
Repeat testing under an established test plan for batch releaseNot eligible
Not eligible. Even elaborate series testing remains quality assurance. The way is documented, the result predictable.

Suppliers, space & digitalisation

Physics-based condition model or digital twin of an aircraft or satellite systemEligible
Eligible. Whether a reduced model predicts the dynamic or thermal behaviour of the system with sufficient accuracy is open beforehand. Comparing model and measurement over several iterations is the evidence.
Tier-1 or tier-2 development of a component for an OEM or a space programmeBorderline
Borderline. Eligible if the supplier itself bears the technical risk and part of the development was open beforehand. Pure manufacturing to an OEM drawing, where the development risk sits with the client, is not.
Integrating standard PLM or MES software into manufacturingNot eligible
Not eligible. Even demanding integration work remains integration. The tools are built for exactly this purpose, the way is documented, the result predictable.

What is regularly rejected

Contract manufacturing and supply without own development riskNot eligible
Not eligible. Whoever manufactures to someone else's drawing bears no technical risk. The case is different when the supplier develops the component itself and is accountable for its behaviour.
Maintenance, repair and overhaul under approved procedures (MRO)Not eligible
Not eligible. Work under an approved maintenance manual is maintenance, not development. The result is settled beforehand, the procedure is approved.
Spare-part and modification upkeep for already certified assembliesNot eligible
Not eligible. The result is fixed beforehand: the same functional scope in an approved form. Occasionally submitted by advisers along with everything else, and then it drags the whole project into scrutiny.

Your project is not listed or sits between two lines? That is the normal case; eligibility is decided on the specific facts, not on the heading. Describe the project to us and we will tell you where it stands.

What evidence does the BSFZ expect in aerospace?

Aerospace companies practically never introduce an additional system for the research allowance; they have the evidence already, often more thorough than in other industries. We evaluate what exists and assign each source to the criterion it supports.

What evidence does the BSFZ expect in aerospace?
Source	What it proves	Criterion
Wind tunnel and structural test protocols	Aborted runs and limit trials date what was tried when and what it was measured against. A trial that falls below the flutter margin is no blemish; it is proof of an open outcome.	Systematic approach · Technical risk
FEA and CFD calculation reports	Calculation reports with boundary conditions, convergence studies and comparison against measurement show that the target value was not trivially achievable.	Technical risk
Flight test data and telemetry	Measurement series from flight testing show the difference between simulated and real system behaviour, often the strongest evidence of an open technical risk.	Technical risk · Systematic approach
Qualification plans and test specifications	Measurement plans and abort criteria fixed in advance for qualification trials document the systematic approach before the certification office asks.	Systematic approach
Configuration baselines · CAD/PDM	Configuration changes show attempt, rejection and new approach, the strongest evidence of experimental development a design department can deliver.	Systematic approach · Technical risk
Change requests · ECR/ECO	Change histories name the rejected solutions, exactly the information with which the state of the art can be demonstrated.	Novelty
Time recording · project hours	For the tax office application the hour counts. We map an existing time recording onto the projects instead of introducing a parallel system.	Cost side
Materials and fatigue test reports	Tensile, impact and fatigue tests to DIN and ASTM document the experimental character when they reflect iterations, not just the certification acceptance.	Scope

The most common mistake in assisted applications is a development process constructed after the fact with phases that never existed at your company. Your real test rigs and change histories are the better evidence; they provide a complete, dated record of the procedure.

What comes out of it?

Two calculated cases for projects that started after 31 December 2025, once at the SME rate of 35%, once at the standard rate of 25%.

Avionics systems supplier, 40 employees · SME

Employer gross, 10 avionics and systems engineers: EUR 850,000. Ten avionics and systems engineers, R&D share documented via project hours, plus a qualification contract placed with a testing institute

R&D personnel costs (employer gross)EUR 425,000

Contract research, 70 % of EUR 50,000+ EUR 35,000

Overhead flat rate 20 %+ EUR 92,000

Eligible expensesEUR 552,000

Funding rate35 %

Research allowance per yearEUR 193,200

Per year. Applied for retroactively over three open financial years: around EUR 0.5 million, without the overhead allowance, because the project started before 2026.

Engine components supplier, 400 employees

Employer gross, 25 developers: EUR 2,250,000. Twenty-five developers working on a new cooling concept generation for turbine blades, not an SME. Standard rate 25%, contract research with a DLR institute

R&D personnel costs (employer gross)EUR 1,237,500

Contract research, 70 % of EUR 150,000+ EUR 105,000

Overhead flat rate 20 %+ EUR 268,500

Eligible expensesEUR 1,611,000

Funding rate25 %

Research allowance per yearEUR 402,750

Per year. The assessment base is capped at EUR 12 million, a maximum of EUR 3.0 million allowance at the standard rate, EUR 4.2 million as an SME.

As a rule of thumb: an avionics engineer with an employer gross of EUR 85,000 who spends half of the time on eligible projects yields around EUR 17,850 research allowance per year (SME rate, with the overhead allowance — the project starts after 31 December 2025). The whole is capped at an assessment base of EUR 12 million and an allowance of EUR 4.2 million per year. Go to the calculator

Guide: R&D tax credit for aerospace companies
The eligibility rules, the sources of evidence and a template for the project description, as a PDF.

What aerospace companies ask us most often

Are dual-use developments (civil & military) eligible under the FZulG?+

Dual-use technologies are not fundamentally excluded. The FZulG supports R&D regardless of the later field of application, provided a civil use case exists. For mixed-use projects, clear documentation of the civil component is recommended. Purely military R&D with no civil application perspective is excluded from funding.

Can ESA- or CleanSky-funded projects also receive FZulG funding?+

A combination is possible provided no double funding of the same personnel costs occurs. ESA contracts typically reimburse personnel costs directly, and these costs cannot additionally be claimed as an FZulG assessment base. Costs not covered by ESA funds, as well as own contributions beyond the ESA project, can however be eligible.

Is EASA certification work (DO-178C, CS-25) eligible as R&D?+

Pure compliance evidence for certification purposes is not eligible. However, the preceding development and verification phase, where new technical solutions are developed, is clearly eligible. NOVARIS cleanly separates the R&D portion from the certification work, maximising the eligible assessment base.

Are suppliers (tier 1/2) eligible even if the part is later installed in an OEM aircraft?+

Yes, if the supplier itself bears the technical risk of the development. Pure contract manufacturing to an OEM drawing is not eligible, but the development work is, if the supplier is accountable for the component's behaviour and part of the result was open beforehand.

Is a qualification trial for type certification eligible?+

Yes, insofar as it resolves a technical question open before the start, such as whether a part reaches a required limit load. Pure substantiation documentation for the certification authority after the technical result is already settled is not.

How far back can aerospace companies apply?+

Applications for closed financial years from 2022 are possible; the assessment period of the respective year is decisive. For many aerospace companies the largest single amount lies precisely in these earlier years, because several development generations sit there unclaimed. Retroactive application

Is wind tunnel or test rig time eligible as an R&D expense?+

The personnel costs of the engineers who run and evaluate the trials are fully eligible. If the wind tunnel or test rig time is commissioned externally, it is eligible as contract research at 70% (Section 3 (4) FZulG). The test protocols are at the same time some of the strongest evidence of technical risk.

How much effort arises in our development team?+

For a typical aerospace project we reckon with two to four hours on the part of the head of development: a technical conversation in which we take up the project, and one approval round on the finished project description. We take over the evaluation of test protocols, configuration baselines and time recording as well as both applications.

How does your documentation become an application?

Your test field and your qualification documentation already document everything the certification office wants to see, just in a different language. Here is the same set of facts in four registers, from the test rig protocol to the application sentence.

In the test field — What gets written anyway

Wing TF-19, gust load test series 2
Load reduction 8% at full flutter margin
  // target −15%, controller too cautious

- FBG fibres, spar ..... 3 segments
- trailing edge actuator rev. B
- series 3 ............. 17% / flutter ok

In conversation — What the team says about it

"The controller was too aggressive on the first pass, we lost the flutter margin. Then we pulled the gain back but only got to eight percent. Only with the third controller version and the strain fibres in the spar did we reach seventeen percent, and the margin still held."

Technically complete and worthless as application text. There is no reference to the state of the art or to the measured variable.

At the BSFZ — What is actually examined

Novelty
Technical risk
Systematic approach

For each of the three criteria the application must contain a verifiable statement. What is described is the knowledge gained on the way to the finished wing.

In the application — What we formulate from it

"For a load-adaptive trailing edge with fibre-optic structural monitoring no control concept existed that reduces gust loads on the wing by at least 15% without falling below the required flutter margin. Whether a stable actuator command could be derived from the strain signals of the sensor fibres could not be determined in advance. The project established this in three measurement series in the wind tunnel and on the ground vibration test against a defined target."

This is the work. The same facts, four formulations, and only one of them is an application. This translation is our actual service: building, from what your test field produces anyway, the statement the certification office can examine. Not writing more beautifully. Writing differently.

Why do applications fail in aerospace?

Rejected projects from aerospace rarely fail on their technology. They fail on five recurring patterns, and we see them in self-submitted applications just as in externally assisted ones.

The state of the art is missing

The application describes what was built, not why it could not be done with what was available. Without named competitor solutions, standards or qualified parts the certification office cannot establish novelty. This is the most common reason in our own mandates.

How we do it. We specifically name the concepts, materials and processes that were examined and rejected, each with the technical property on which they fail.

Certification evidence is submitted as development

An application describing "the EASA certification" as the project forces the certification office to assess compliance evidence and development together. The pure documentation work drags the whole project down, even if part of it contains real qualification trials.

How we do it. We scope the project to the qualification trials that resolve a question open beforehand, and cleanly separate compliance documentation and type certification.

Project risk instead of technical risk

Delivery dates, programme cost and supplier availability are not technical risks. Anyone arguing this way describes a management problem and gets it decided as such.

How we do it. We phrase the risk as an open technical question: which property of the system was not predictable before the start, and exactly where the project would have failed.

The test article is described as a product

The application reads like a data sheet: thrust, weight, range. The certification office is looking for the way there, the trials that did not work and the measurement that proves the difference.

How we do it. We derive the systematic approach from your own artefacts: layout in the calculation report, trial in the test protocol, decision in the change request.

Cost side and facts do not match

The BSFZ certifies the project, the tax office checks the costs. Anyone who claims personnel costs already reimbursed through an ESA or EU funding programme, or hours that contradict the project description, loses in the second step, after the certificate has already been issued.

How we do it. We run project description, time recording and research allowance application (ELSTER) against the same scope from the start, including a check for double funding on international programmes.

If you already have a rejection, the first step is analysing the decision: which of the five points carries it. That determines whether objection or new application is the right way.

Which other industries use the research allowance?

The sector never decides eligibility — Section 2 FZulG does. These pages show the same three criteria against the activities of each field.

Mechanical engineering — Design, testing, commissioning
Automotive — Drivetrain, battery, driving function
Medical technology — Operating principle, SaMD, pre-approval
Pharma & life sciences — Compound, formulation, bioprocess
Construction — Methods, materials, component tests
Energy & cleantech — Cell, storage, grid control
Agriculture & FoodTech — Process, formulation, field trial
Software & IT — Algorithm, model, architecture

Send us a test protocol, not a questionnaire

In the first consultation we talk about your project, not about your certification programme. After thirty minutes you know which part of your development is eligible, in what order of magnitude, and whether a retroactive application is worthwhile. The first consultation is free; 30 % of the fee falls due with the BSFZ decision, 70 % only after the allowance has been paid out.

Book a first consultation

Official sources

Read on

Max Nodes

Founder and Managing Director of NOVARIS Consulting. Specialised in the German R&D tax credit (FZulG) since 2021; 25 of 25 accompanied BSFZ applications approved (as of 09/2026). Max Nodes

R&D tax credit for aerospace: development yes, qualification no

Aerospace: test systems through cycles