The “AI budget”: three different things

“New AI budget”, “2026 AI voucher”, “up to €29,000 of artificial intelligence”. Three slogans. Three different rules. Mix them and you sign a pack the BOE will not pay.

This is what is published. Sources: Order TDF/435/2024 (BOE 11 May 2024), Order TDF/436/2024 and its amendment TDF/38/2026 (Kit Consulting), Order TDF/39/2026 (BOE 28 January 2026), and the State Secretariat for Digitalisation and AI note of 17 March 2026. A ministerial order of bases is not an open call. A €40 million press note is not one either.

One: €3.067 billion Kit Digital (not an AI voucher)

Kit Digital is still investment 3 of component 13 of the recovery plan, with a total aid budget of €3,067,000,000. Order TDF/39/2026 does not add AI categories. It does three management things: the bases run until funds are exhausted; Red.es must reinvest any leftover, even after 2026, in the same programme; if credit remains unassigned, new grant proposals must be made for applicants left out when the pot ran dry.

That is Next Generation absorption, not a “Kit Digital IA 2026” for a four-person shop. The voucher ceilings (€12,000 / €6,000 / €3,000 / €25,000 / €29,000) are the SME cap, not the price of one AI line.

Two: AI-associated categories (2024 BOE, mid-size only)

The three “with associated AI” categories entered Anexo IV via Order TDF/435/2024 — not the 2026 order. They are for Segment IV (50 to under 100 employees, plus some smaller firms that count as medium by turnover) and Segment V (100 to under 250). They are not in the self-employed voucher.

Maximum aid per category, 12 months, 70 % / 30 % phases:

• Customer management with associated AI: €18,000 (IV, 10 users, training at least 3) / €24,000 (V, 15 users, at least 5).
• Business intelligence and analytics with associated AI: €8,000 (IV) / €9,000 (V), same user and training floors.
• Process management with associated AI: €16,000 (IV, 20 users, at least 3 trained) / €19,000 (V, 25 users, at least 5).

If you are not mid-size, that catalogue line is not your voucher. You can still do AI via Kit Consulting (advisory, €6,000 per service) or a studio contract. Reciting “AI” over a €2,000 CRM does not change the annex.

What the agent must offer (Anexo IV, not a slide)

The BOE does not ask for a friendly chatbot. It asks for a minimum package. If it is not in the agreement, the category is not being delivered.

Customer management with associated AI

• Parametrisation: 60 hours (IV) or 70 hours (V), plus data load.
• A real CRM: leads (manual or file), accounts, opportunities through to contract, commercial tasks, reporting, alerts, document management, APIs, usable on a phone.
• AI component: predictive lead scoring; meeting automation; sales-journey automation (tasks, mail classification and auto-reply, record updates, assignment).
• Privacy: GDPR. If the system talks to people, they must be told they are interacting with an AI system.
• Technical docs, instructions, copyright directive.
• Training: 20 hours over two months per trained user in the segment, human instructor (on-site or online), diploma. Syllabus: rules and risks; scoring; journeys; FAQ chatbots; intelligent documents.

BI and analytics with associated AI

• Parametrisation: 80 hours (IV) or 90 hours (V).
• Connect other databases, at least 1 GB storage per user, visual dashboards, export to image or Excel.
• Training 20 hours / two months / human instructor / diploma: rules and risks; integration; dashboards; AI use cases.

Process management with associated AI

• Parametrisation: 80 hours in both IV and V.
• Automate integral flows: accounting/finance, invoicing, projects, inventory, purchasing and payments, HR, logistics or other internal processes.
• APIs, updatable, scalable.
• Training 20 hours / two months / human instructor / diploma: those flows, finance, data interpretation, continuous learning. Basics: rules and risks.

That last bucket is where an invoice OCR reader can sit: extract fields, leave a human the ones that do not add up. It does not replace a Verifactu SIF and does not let you shred paper. The processes annex wants an automated flow, not a 99 % slogan.

Three: Kit Consulting AI advisory

Order TDF/436/2024 Anexo IV defines an AI advisory service at €6,000 (VAT excluded in this site’s commercial offer): a plan if you have none, investment, adoption, data governance, one real use case (ML, text or expert systems) and training. It does not buy the tool. Software is Kit Digital or another contract.

The SME advisory voucher is €12,000 / €18,000 / €24,000 for segments A/B/C (10–50 / 50–100 / 100–250 staff). Each catalogue service is €6,000.

Kit Consulting’s 2026 change is not a new AI category. Order TDF/38/2026 (BOE-A-2026-2069, 28 January) is the twin of TDF/39: €300,000,000 of C13 I3, bases until funds run out, Red.es reinvests leftovers even after 2026, and leftover credit triggers new grant proposals. It does not touch Anexo IV. Acelera pyme still marks the call CLOSED. The 14 April 2026 resolution (BOE-B-2026-11759) only extends the deadline to sign agreements on already-granted vouchers (31 May 2026 if granted after 28 February). It does not reopen SME applications.

Four: the March 2026 €40 million (still not a call)

On 17 March 2026 the State Secretariat announced €40 million, ERDF 2021–2027, via Red.es, so startups and SMEs can use AI “as a service”. Target: at least 30 sector use cases and 15 reusable models. Agreements with associations, technology or innovation centres (up to five members), at least 20 % co-funding, up to €12 million per agreement.

That is not an Acelera pyme form for your company. We have not seen a BOE extract with an application window for firms. Anyone selling “sign up for the €40 million voucher” is selling the press note. When the extract exists, we read the extract.

What we do with this

We offer the three AI-associated categories to Segment IV or V holders. We offer Kit Consulting AI advisory to firms of 10–250. And the OCR reader, if the pain is retyping invoices, as capture — inside processes or outside the catalogue — not branded as Verifactu.

Adhesion is in progress. We do not claim Adherido until Red.es decides. The Agreement and the annex override this page.

Frequently asked questions

Is there a €6,000 AI voucher for any self-employed person?

Not in Kit Digital’s “associated AI” catalogue: that is Segments IV and V. A self-employed person can use other categories or a private job. Kit Consulting is 10 to 250 employees.

Did the 2026 order open AI categories to micro-firms?

No. TDF/39/2026 is about validity, leftovers and reassignment. Categories XIV–XVI come from TDF/435/2024 and stay on IV and V.

Is there a new Kit Consulting AI voucher in 2026?

No. The AI advisory service has existed since TDF/436/2024, at €6,000 for A/B/C. TDF/38/2026 only manages leftovers (€300m). Acelera’s catalogue is still ten services.

Can I apply for the €40 million on Acelera pyme?

The note says agreements with collaborating entities, not a Kit Digital-style application. No BOE extract means no SME window.

Does OCR count as “process management with AI”?

It can sit inside an invoicing/purchasing flow if you also deliver parametrisation, automation, APIs, 20 hours of training with a human instructor and a diploma. Extracting PDFs without that does not meet the annex.

Next: Kit Digital and the SIF, what Verifactu is and the sheets for customers + AI, BI + AI and processes + AI. Tell us your segment and whether the voucher is granted.