How to Finance AI Act Compliance with Kit Consulting (up to €24,000)

Executive summary: The Kit Consulting (Spain advisory grant) voucher (up to €24,000 depending on company size) can finance the strategic advisory work needed to comply with the AI Act: AI systems diagnostic, risk classification, action plan and roadmap. This guide explains how to apply when the next call opens, what the AI advisory category covers exactly, what limitations the programme has and how to combine it with ISO 42001 to maximise grant return.

What is Kit Consulting (Spain advisory grant) and what does it have to do with the AI Act?

Kit Consulting (Spain advisory grant) is the aid programme managed by Red.es, within the SME Digitalisation Plan 2021-2026 and the Spain Digital 2026 Agenda, fully financed with NextGenerationEU funds. Its full official name is Agents of Change - Kit Consulting and its regulatory basis is set out in Order TDF/436/2024, of 10 May (BOE-A-2024-9524).

Unlike Kit Digital (Spain digitalization grant) — which finances the acquisition of specific technological solutions (software, applications, tools) — Kit Consulting (Spain advisory grant) finances strategic advisory services: consultancy, diagnosis, planning and preparation of action plans. The voucher materialises in a specific number of hours of personalised consultancy provided by a Change Agent adhered to the programme.

And what does this have to do with the AI Act? Regulation (EU) 2024/1689 on Artificial Intelligence — popularly known as the AI Act — obliges companies that develop, integrate or deploy artificial intelligence systems to comply with a series of requirements ranging from documenting systems to classifying them by risk level, implementing governance controls and ensuring staff training. All that preparatory work — diagnosis, classification, remediation plan, roadmap — is exactly the type of advisory service that Kit Consulting (Spain advisory grant) finances.

Put directly: Kit Consulting (Spain advisory grant) does not explicitly name the AI Act in any of its technical factsheets, but the AI advisory category includes among its mandatory activities the creation of "data governance protocols with AI regulations." That phrase opens the door to structuring an AI Regulation compliance project as an eligible service under the grant.

Current status of the call

The first Kit Consulting (Spain advisory grant) call — with a budget of more than €290 million — was open from 18 June 2024 to 31 March 2025. More than 23,000 vouchers were granted, exceeding the initial target of 15,000 by 53%. Beneficiaries with already-approved vouchers are in the execution and justification phase, with extended deadlines until mid-2026.

Order TDF/38/2026, published in the BOE on 28 January 2026, amends the regulatory bases and legally enables the opening of new calls with the programme's remaining funds. At the time of publication of this article, no second call is officially open, but the possibility is provided for in the regulatory framework. This guide prepares you to act as soon as it is published.


How much can you obtain? Amounts by company segment

Kit Consulting (Spain advisory grant) classifies SMEs (small and medium-sized enterprises) into three segments according to number of employees and assigns a maximum voucher amount to each:

Segment Employees (annual average) Maximum voucher Maximum number of services
Segment A 10 to 49 employees €12,000 2 service categories
Segment B 50 to 99 employees €18,000 3 service categories
Segment C 100 to 249 employees €24,000 4 service categories

Each service category has a subsidisable value of €6,000 and requires a minimum of 100 hours of personalised consultancy. The grant covers 100% of the service cost: there is no mandatory co-financing by the beneficiary company.

What does this mean in practice?

A Segment A company with 20 employees can obtain a €12,000 voucher to contract two strategic advisory services. If it dedicates both to the AI advisory category and to the business process category, it will cover the two key phases of AI Act compliance: the diagnosis and classification of systems (AI) and the design of governance processes and documentation (business processes).

A Segment C company — up to 249 employees — can obtain €24,000 for four services, giving room to combine AI, business processes, cybersecurity and data analysis advisory; a very suitable combination for comprehensive regulatory compliance projects.

Which companies are excluded?

The programme excludes self-employed persons without employees, micro-enterprises with fewer than 10 employees and large companies with 250 or more employees. Also excluded are companies in insolvency proceedings or not up to date with their tax obligations to AEAT and Social Security.

If your company does not meet the Kit Consulting (Spain advisory grant) requirements, check whether your autonomous community has complementary programmes: the Basque Country (SPRI), Galicia (IGAPE), Extremadura and Castilla y León, among others, have their own lines of grants for digitisation and artificial intelligence that may cover similar projects, although they do not directly co-finance the Kit Consulting (Spain advisory grant) voucher.


Which Kit Consulting (Spain advisory grant) categories cover AI Act compliance

The official Kit Consulting (Spain advisory grant) catalogue has ten service categories. For an AI Act compliance project, the two most relevant are:

1. Artificial Intelligence Advisory (the most direct)

This category aims to provide the SME (small and medium-sized enterprise) with an AI plan tailored to its needs, identifying the required investment and adoption measures. The minimum activities that the Change Agent must provide are:

In terms of regulatory compliance, this category can finance the most critical deliverables:

2. Business or Production Processes (complementary)

This category addresses the improvement of operational processes through AI-based analysis. It covers areas such as sales, human resources, manufacturing efficiency and workflow automation.

For AI Act compliance, it fits the phase of controls and procedures design: human oversight protocol, incident management procedure, documentation review and update process. These are activities that the regulation requires from operators of limited-risk and high-risk AI systems, and which can be structured as process improvements fundable under this category.

Is the AI Act explicitly eligible?

In all honesty: the AI Act is not mentioned by name in any official Kit Consulting (Spain advisory grant) technical factsheet. The connection is established through the "AI regulations" cited in the artificial intelligence category. The strongest eligibility argument is to structure the project as a "AI governance plan aligned with Regulation (EU) 2024/1689" in the proposal to the Change Agent. Many adhered digitisation agents are already providing services of this type under this category.


How to apply for Kit Consulting (Spain advisory grant) for an AI Act project: step by step

Although the first call is already closed, knowing the process allows you to prepare for the next one. The process follows these steps:

Step 1: Verify your company's eligibility

Before starting the process, check that your company meets the basic requirements:

Step 2: Identify your Change Agent

Kit Consulting (Spain advisory grant) is not contracted directly with Red.es, but through an adhered Change Agent. These are consultancies and advisory companies that have passed an accreditation process and are authorised to provide the eligible services.

Before applying for the voucher, contact at least two or three agents to assess their specific experience in AI Act compliance. Ask them to explain what specific deliverables they include in the project and how they will structure them within the eligible categories. An agent experienced in AI regulation will know exactly how to document the project to pass Red.es's justification review.

Step 3: Submit the application at Red.es electronic headquarters

When the call is open, the application is submitted at Red.es electronic headquarters. You will need:

Step 4: Resolution and signing of the Service Provision Agreement

After a favourable resolution, you have a deadline to sign the Service Provision Agreement with the chosen Change Agent. This document details the contracted service categories, number of hours, committed deliverables and execution timelines.

Step 5: Execution of the advisory project

The Change Agent provides the advisory service. In the case of an AI Act project, this involves working sessions, interviews with AI system managers, document analysis, risk classification workshops and preparation of the agreed deliverables.

Important: the justification to Red.es requires that the service be completely executed and delivered. It is not valid to justify only the planning phase or present a draft. The deliverable must be finalised and signed by both parties.

Step 6: Justification and payment

Once the service is completed, the Change Agent submits the justification to Red.es providing the deliverables, invoices and execution evidence. Red.es validates the documentation and proceeds to pay the Change Agent directly. For the beneficiary company, the service is effectively free: it does not pay anything upfront.


What Kit Consulting (Spain advisory grant) does NOT cover (and what you will still need to handle)

Transparency on this point is essential so that the grant does not create expectations that are later not met. Kit Consulting (Spain advisory grant) finances strategic advisory services, not technical implementation or certification. These are the items outside the voucher:

Technical implementation

The development or adaptation of AI systems to meet the regulation's technical requirements — adding audit logs, human oversight mechanisms, bias controls, explainability modules — is not included in Kit Consulting (Spain advisory grant) categories. That investment must be borne directly or financed through other means (Kit Digital (Spain digitalization grant), regional FEDER, own financing).

ISO 42001 certification

The certification audit carried out by an accredited body (Bureau Veritas, SGS, AENOR, TÜV) is not an advisory service and therefore is not eligible under Kit Consulting (Spain advisory grant). The total cost of an ISO 42001 certification project for an SME (small and medium-sized enterprise) — including the preparation consultancy, stage 1 audit, stage 2 audit and certificate issuance — typically ranges from €6,000 to €10,000. Of that total, the certification body fee (the part not covered by Kit Consulting (Spain advisory grant)) represents between €1,000 and €5,000 depending on scope and body. However, the advisory work prior to certification — diagnosis, gap analysis, remediation plan, documentation preparation — can be financed with the voucher.

Technology tools and platforms

Compliance software licences, AI risk management platforms or monitoring tools are not eligible. Kit Consulting (Spain advisory grant) pays for consultant hours, not technology.

Internal staff costs

The time your own employees spend participating in the advisory project (meetings, document review, internal training) is not subsidisable. Only the service provided by the external Change Agent enters the voucher.

Summary of what is and is not covered

Activity Does Kit Consulting (Spain advisory grant) cover it?
AI systems inventory✅ Yes
AI Act risk classification✅ Yes
Gap analysis and action plan✅ Yes
Responsible AI use policy✅ Yes
Internal training (AI literacy)✅ Yes (within the service)
Technical implementation in systems❌ No
ISO 42001 certification audit❌ No
Compliance software licences❌ No
Internal employee time❌ No

Combining Kit Consulting (Spain advisory grant) + ISO 42001: the most efficient strategy

The AI Act and ISO 42001 are not two parallel paths that need to be followed separately: they share between 40% and 50% of the controls they require from an organisation. This means a well-designed advisory project can address both frameworks with the same Kit Consulting (Spain advisory grant) voucher, avoiding duplicating effort and money.

Where do they overlap?

Both the AI Act and ISO 42001 require, among other aspects:

How to structure the combined project

The optimal strategy is to contract with the Change Agent an advisory project that produces two simultaneous deliverables:

  1. AI Act compliance report: systems inventory, risk classification, identified gaps, prioritised action plan and responsible AI use policy.
  2. AI Management System per ISO 42001: documentary structure, organisational context, stakeholder analysis, AI objectives, implemented controls and documentation for the certification audit.

If the Change Agent has the AI advisory and business processes categories enabled, you can distribute the work between both. For example, diagnosis and risk classification go to the AI category; the design of operating procedures and management system documentation go to business processes. The result: two services (€12,000 grant for Segment A) cover most of the work that would otherwise cost between €15,000 and €25,000 if contracted directly on the market.

To explore in depth the differences between the AI Act and ISO 42001 and understand what each framework brings to a Spanish SME (small and medium-sized enterprise), read the full comparative guide here.


Timelines: when to apply for Kit Consulting (Spain advisory grant) to be ready for the AI Act

The relationship between Kit Consulting (Spain advisory grant) timelines and AI Act timelines is critical. If you wait too long, the advisory work will arrive when the company is already exposed to sanctions. Here is the calendar you need to manage:

AI Act timelines in Spain

Date Milestone Already in force?
1 August 2024Entry into force of the Regulation✅ Yes
2 February 2025Prohibition of unacceptable AI systems + Art. 4 (AI literacy)✅ Yes
2 August 2025Obligations for general-purpose AI models (GPAI)✅ Yes
2 August 2026General application: transparency (Art. 50), full AESIA powers and Annex III high-risk AI systems (Art. 6.2), per Article 113 of the Regulation⚠️ Imminent — this is the date currently in force
2 December 2027New expected date for Annex III high-risk AI systems if the Digital Omnibus on AI is published (signed 8 July 2026)⏳ Not yet: the Digital Omnibus on AI was published in the Official Journal of the EU on 24 July 2026

As you can see in the table, on 2 August 2026 AESIA will acquire its full inspection and sanctioning powers, and Article 50 on transparency in AI systems interacting with people (chatbots, personalised recommendation systems, AI-generated content) will enter full application.

The Annex III high-risk AI systems — systems used in personnel hiring, credit assessment, educational systems, critical infrastructure — are the point of greatest confusion I am seeing, so it is worth being precise. The application date is 2 December 2027: this is what Article 113 of Regulation (EU) 2024/1689, as amended by Regulation (EU) 2026/1744 (Digital Omnibus on AI), sets. The Digital Omnibus on AI, published in the Official Journal of the EU on 24 July 2026 and in force since 27 July, moved those obligations to 2 December 2027 (Annex III) and 2 August 2028 (Annex I).

While this has not become law, planning against December 2027 means planning against a regulation that already exists. And even if the delay ends up confirmed, it does not eliminate the need to act: the diagnosis and planning phase must be done before deployment or modification of those systems.

How long does the Kit Consulting (Spain advisory grant) process take?

Although the exact timelines for the second call have not been set, experience from the first allows for estimates:

This means that if the second call opens in the last quarter of 2026 or early 2027 (a plausible scenario given the current regulatory framework), an advisory project started in early 2027 would arrive on time only in the scenario where the Digital Omnibus on AI is published and moves Annex III to December 2027. With the calendar currently in force today — 2 August 2026 — that same project would arrive late. This is why diagnosis and system classification should not be delayed while waiting for the voucher: the preparatory work is done now, and the voucher, if it comes, finances what remains to be done.

The lesson from Europe's first AI sandbox

Spain was the first European Union country to complete an artificial intelligence regulatory sandbox. The process, managed by AESIA with an investment of approximately €4.3 million, concluded in June 2026 with the publication of 16 practical compliance guides. These guides are today the most comprehensive technical reference available in Spanish for a company to know exactly what to do to comply with the AI Act.

The message is clear: the Spanish administration already has the active regulatory infrastructure, published guides and supervision powers ready. We are not facing a theoretical threat; we are facing a compliance framework that is already operational.

To learn about the specific obligations the AI Act imposes on your company before August 2026, consult this detailed guide with the complete checklist.


The cost of not subsidising compliance: market comparison

One of the strongest arguments for using Kit Consulting (Spain advisory grant) for the AI Act is the real market cost of advisory services. According to available data from the Spanish market in 2026:

With a Segment A Kit Consulting (Spain advisory grant) voucher (€12,000), an SME (small and medium-sized enterprise) with 20 employees can fully finance a diagnosis and action plan project that on the market would cost between €8,000 and €15,000. With a Segment C voucher (€24,000), a medium-sized enterprise can cover both the diagnosis phase and the ISO 42001 management system design, with a market value of between €18,000 and €30,000.

The grant does not eliminate all costs — technical implementation and certification will be borne by the company — but it drastically reduces outlay in the most critical phase: planning and design.


Frequently asked questions

Does Kit Consulting (Spain advisory grant) finance AI Act compliance?

Yes. The AI advisory category of Kit Consulting (Spain advisory grant) can cover services such as AI systems diagnosis, risk classification according to Regulation (EU) 2024/1689 and action plan preparation. Although the AI Act is not mentioned by name in the official factsheets, the "data governance with AI regulations" activity provides the legal basis to structure the compliance project under this category. The amount ranges from €12,000 to €24,000 depending on company size.

How much can I obtain from Kit Consulting (Spain advisory grant) for the AI Act?

It depends on your company size: Segment A (10-49 employees), up to €12,000; Segment B (50-99 employees), up to €18,000; Segment C (100-249 employees), up to €24,000. Each service category has a value of €6,000 and requires a minimum of 100 hours of consultancy. You can combine several categories within the same voucher up to the maximum for your segment.

What is the difference between Kit Consulting (Spain advisory grant) and Kit Digital (Spain digitalization grant) for AI Act compliance?

Kit Digital (Spain digitalization grant) finances the acquisition of technological solutions: software, applications, tools. Kit Consulting (Spain advisory grant) finances strategic advisory services: consultancy, diagnosis, planning, preparation of action plans. For AI Act compliance, Kit Consulting (Spain advisory grant) is the most appropriate programme because the most costly and complex phase — the diagnosis, risk classification and action plan design — is advisory work, not technology acquisition.

Can Kit Consulting (Spain advisory grant) be used for ISO 42001 and the AI Act at the same time?

Yes. Since the AI Act and ISO 42001 share between 40% and 50% of the controls they require, a well-designed advisory project can address both frameworks with the same voucher. The AI advisory category covers diagnosis and risk classification; the business processes category covers procedure design and management system documentation. It is the most efficient way to use the grant.

How long does the Kit Consulting (Spain advisory grant) process take?

Based on the experience of the first call, application resolution takes between 1 and 3 months. Once the voucher is approved, signing the agreement with the Change Agent takes a further 2 to 4 weeks. Project execution (minimum 100 hours per category) can last between 2 and 5 months for an AI Act compliance project with complete deliverables. In total, allow a minimum of 6 to 9 months from application to obtaining the final deliverables.

Who can be a Change Agent for Kit Consulting (Spain advisory grant) on AI Act?

Any consultancy adhered to Red.es's Kit Consulting (Spain advisory grant) programme with the AI advisory category enabled. The catalogue of accredited Change Agents is available at Red.es electronic headquarters and the Acelera Pyme portal. Before choosing, verify that the agent has specific experience in AI regulation and, specifically, in compliance with Regulation (EU) 2024/1689.

Does Kit Consulting (Spain advisory grant) cover ISO 42001 certification?

Kit Consulting (Spain advisory grant) covers the strategic advisory and planning phase, not external certification itself. The certification audit carried out by an accredited body (AENOR, Bureau Veritas, SGS, TÜV, among others) is not an advisory service and therefore is not included in the voucher. However, the pre-certification consultancy work — diagnosis, gap analysis, remediation plan, management system documentation preparation — can be financed. The cost of the certification audit for an SME (small and medium-sized enterprise) typically ranges from €1,000 to €5,000, which you will need to bear yourself.

Which SMEs (small and medium-sized enterprises) cannot access Kit Consulting (Spain advisory grant)?

Companies with fewer than 10 employees (micro-enterprises and self-employed without employees) and companies with 250 or more employees are excluded from the programme. Also excluded are companies in insolvency proceedings, those with outstanding debts to AEAT or Social Security and those in a crisis situation as defined by the European Union. If your company does not meet these requirements, consult your autonomous community's own programmes, which in some cases have broader access conditions.


Next steps

If you manage AI Act compliance at a Spanish SME (small and medium-sized enterprise) and want to be ready to act as soon as the next Kit Consulting (Spain advisory grant) call opens, here are the steps I recommend taking right now:

  1. Do a basic inventory of your AI systems. Before contracting any external advisory service, knowing what AI tools you use (from a website chatbot to a recommendation system in e-commerce or HR selection software) will allow you to correctly size the project.
  2. Identify your Kit Consulting (Spain advisory grant) segment (A, B or C) based on the number of employees from the last closed financial year. This determines the maximum amount you can apply for.
  3. Consult the 16 compliance guides published by AESIA at aesia.digital.gob.es. They are the most up-to-date technical reference in Spanish for knowing exactly what the regulator expects from your company.
  4. Speak with an accredited Change Agent with experience in AI regulation. The initial diagnostic conversation is usually free and will give you a clear picture of which deliverables are eligible and how to structure the project.
  5. Watch for the publication of the second call in the BOE and at Red.es's portal. Order TDF/38/2026 already legally enables a new opening; when it is published, those who have done the preparatory work will be able to apply from day one.

Do you want to review in detail what the AI Act exactly obliges your company to do before August 2026? Consult the article with the complete SME (small and medium-sized enterprise) obligations checklist.

Do you have questions about how to combine AI Act compliance with ISO 42001 certification and which of the two frameworks to address first? Read the comparative guide AI Act vs. ISO 42001 for SMEs (small and medium-sized enterprises) in Spain.

If you prefer to talk directly about your specific situation — what AI systems your company uses, what your regulatory exposure level is and how to structure the compliance project — write to me here and I will respond within 48 hours.

If you want to see how financing fits with the actual compliance work, here you have AI Act compliance.