Kit Digital 2026: combining Spain's AI grant with custom development

Quick summary

Spain's Kit Digital program remains active through 2026 following Order TDF/39/2026, published in the BOE on 28 January 2026. The order allows Red.es to reinvest unspent funds from previous calls to address pending applications, so the program no longer has a hard closing date.

The categories with associated AI (introduced in May 2024 by Order TDF/435/2024) are restricted to Segments IV and V, meaning companies with 50 to 249 employees. For freelancers, micro-businesses, and small firms (Segments I-III), there is no AI-specific grant, but adjacent categories like "Process Management" or "Business Intelligence" without AI cover up to €18,000.

If your company falls into Segment IV or V, the maximum stack across AI categories combined reaches €81,000. But the catalog covers standard SaaS solutions, not custom development or code owned by the client, and that distinction matters.

What is Kit Digital and what changed in 2026

The Kit Digital is the grant program from Spain's Ministry for Digital Transformation and Public Administration, aimed at SMBs, micro-businesses, and self-employed individuals. The original regulatory base is Order ETD/1498/2021 (BOE, 30 December 2021), modified by successive orders. The most recent is Order TDF/39/2026.

What Order TDF/39/2026 changed:

• Reinvestment of unspent funds. Red.es can reallocate leftover budget from past calls to address applications that met requirements but were left out due to budget exhaustion.
• No fixed closing date. The program stays active until remaining reinvested funds are exhausted, removing the rigid deadlines previous calls had.
• Modification of articles 4, 6.3 and 28.8 of the base regime, adjusting temporal scope, payment conditions, and resolution procedure.

The total budget committed to Component 13 of Spain's Recovery, Transformation and Resilience Plan is €3.067 billion, financed by NextGenerationEU funds.

The "AI associated" categories themselves are not new in 2026. They were added in May 2024 by Order TDF/435/2024. What changed in 2026 is the possibility for more companies to access them because of rescued funds.

The four AI-relevant categories (Segments IV-V only)

Maximum combined stack: €81,000 combining all three AI categories plus cybersecurity, in a single Segment V company (100-249 employees).

Segments IV and V are defined as:

• Segment IV: medium companies with 50 to 100 employees, basic package up to €25,000.
• Segment V: medium companies with 100 to 250 employees, basic package up to €29,000 (extendable with AI categories to reach the stack above).

What if I am self-employed or a small company

Segments I, II, and III (0-50 employees) do not have access to AI-associated categories. Maximum package:

• Segment I (10-50 employees): up to €12,000
• Segment II (3-10 employees): up to €6,000
• Segment III (0-3 employees, freelancers included): up to €3,000

Even so, several categories cover automation and software with AI components without an explicit AI label:

• Process management (no AI tag): up to €18,000 (Segment I), €6,000 (II), €2,000 (III). Covers ERP, operational CRM, document management, internal workflow automation.
• Customer management (no AI tag): up to €12,000 (Segment I). CRM, customer service, marketing automation.
• Business Intelligence and Analytics without AI: up to €7,000 (Segment I). Dashboards, KPIs, data analysis.

A freelancer in Segment III cannot buy AI directly with Kit Digital, but they can subsidize the infrastructure on top of which custom AI is later built.

What the Kit Digital catalog covers, and what it does not

The official Acelera Pyme catalog sets minimum technical requirements per category. In practice, registered digitizing agents (public list at sede.red.gob.es) mostly offer:

• Deployment of pre-built SaaS solutions (Holded, Bitrix24, Odoo SaaS, Microsoft Dynamics SMB and similar).
• Standard configuration of off-the-shelf CRMs and BI tools.
• Templates of low-code/no-code automation (n8n, Zapier, Make resold as a service).

What the catalog does not cover well:

• Custom development outside the catalog. The grant only finances listed categories, not custom software.
• Code owned by the client. Subsidized SaaS remains the SaaS vendor's property; after the mandatory 12-month service period, the client either pays subscription or loses access.
• Complex integrations with legacy systems. The catalogs assume greenfield installation.
• AI models specific to the client's domain. "Associated AI" in the catalog is typically generic SaaS modules (lead scoring, basic ticket classification).

When custom development is the smart complement

Three scenarios where combining the grant with custom development makes economic sense:

1. Full Segment V stack with AI stack exhausted. A 150-employee company already running SAP or Salesforce doesn't need a new CRM. They can use the "Customer management with AI" grant (€24,000) to have an agent implement the AI module of the existing CRM, and allocate own budget to custom development of the RAG agent over their internal document base, where the catalog can't reach.

2. SMB in Segment II-III that wants AI but isn't covered. The honest strategy: use the grant for adjacent infrastructure (Segment II CRM up to €4,000, BI up to €2,000), and finance custom AI outside the program. The grant covers data, custom development builds the model on top.

3. Companies with data sovereignty requirements. Sectors with sensitive data (healthcare, legal, financial) that can't use multi-tenant SaaS. Kit Digital covers little here; catalogs don't include self-hosted. The honest option is custom development outside the grant.

How to choose a digitizing agent

If you are going for an AI category in Kit Digital, the objective criteria for choosing an agent:

• Time registered as an agent. Searchable at sede.red.gob.es. More than 12 months as an active agent equals experience with justification processes.
• Cases similar to yours. Ask for references in the same sector and same segment.
• Post-grant continuity model. Ask what happens at month 13 when the agent's obligation ends. Subscription? Migration? Own code?
• Technical transparency. If they do not tell you which SaaS or technology they are installing, do not sign.
• Location. For occasional in-person support, prefer agents based in Catalonia or Madrid depending on your location.

Frequently asked questions

When does Kit Digital close? Following Order TDF/39/2026, there is no fixed closing date. The program continues until reinvested remaining funds are exhausted.

Can a freelancer apply for AI categories? Not directly. "AI-associated" categories are restricted to Segments IV and V (companies with 50+ employees). A freelancer (Segment III) has a maximum grant of €3,000 in non-AI-labeled categories.

How long is the agent required to maintain the solution running? 12 months of effective service delivery. From month 13, the contract depends on the agent's commercial model, usually subscription.

Does the code or SaaS deployed remain the client's property? In most cases, no. The catalogs are designed for SaaS. If you need code ownership (for compliance, technical control, or continuity without subscriptions), custom development outside Kit Digital is the honest option.

Can I combine multiple categories? Yes. A Segment V company can combine "Customer management with AI" (€24,000) plus "Process management with AI" (€19,000) plus "BI with AI" (€9,000) plus "Managed cybersecurity" (€29,000) up to a total of €81,000, provided they can absorb and integrate all those solutions.

Is there a quota? The program works on a first-come basis until funds run out. Order TDF/39/2026 allows reinvestment of leftover funds, but availability per call remains limited.

How SolidaWeb helps

SolidaWeb is not a registered Kit Digital digitizing agent. What we do:

• Free initial diagnosis: which categories apply to you, which stack maximizes the grant, what is left outside for custom development.
• Custom development of the complement the catalog does not cover: domain-specific AI agents, integrations with legacy systems, self-hosted models for sensitive data.
• Post-grant migration. When the agent's 12-month obligation ends and the SaaS subscription stops making economic sense, migration to own infrastructure.

If you would like to see if your case fits, contact info@solidaweb.com.

Sources

• Order TDF/39/2026, 26 January, modifying Order ETD/1498/2021. BOE no. 25, 28 January 2026. boe.es/buscar/doc.php?id=BOE-A-2026-2070
• Order ETD/1498/2021 (original regulatory base). boe.es/buscar/doc.php?id=BOE-A-2021-21873
• Official solutions catalog: Acelera Pyme. acelerapyme.gob.es/kit-digital/soluciones-digitales
• Registry of adhered digitizing agents: Red.es. sede.red.gob.es
• Spain Recovery Plan, Component 13: espanadigital.gob.es/lineas-de-actuacion/programa-kit-digital