I agree. A key part not mentioned is that you have to fund the salaries before and it's only paid much later! As in after you close your fiscal you then have to submit and it takes about a year before you're paid. So in total you have to cover the salaries for two 2+ years before you're paid. You also have no guarantee you will be paid.

It's also only on developer costs that are accepted and only on R&D work: none of the business costs etc are covered. In many cases these are just as significant or more.

There's also a reason that a consulting industry has started around it, it's a good amount of effort. Again helping more advanced companies as they can afford the costs for the 2+ year it takes before you can get it back. And again nothing is guaranteed.

Essentially it's not good for startups or smaller companies, it really only benefits companies of a medium size that were alreday going to cover this expenses by reducing some of their costs to increase them growth rate. But for a small company, less than 10 employees it's really hard to actually take advantage of the program in real life.