Spain’s AI Voucher Under Plan IA360: What’s Confirmed and What Isn’t Yet

The Spanish Government has announced an AI Voucher for SMEs as part of Plan IA360, but there is still no regulatory basis, no call for applications, and no confirmed amount per company: here’s what the official document says today and what you should prepare in the meantime.

By E2M Global Advisory LLC · Published on October 6, 2026 · About E2M

If you run an SME and you’ve read in the press that the Spanish Government is preparing an “AI Voucher” of up to €600 million, it’s reasonable to wonder how much your company might receive and when you can apply. The problem is that, two weeks after the announcement, dozens of articles already cite amounts, aid percentages, and application deadlines that, as of today, do not exist in any official text. Conflating the political announcement with the regulatory basis that has yet to be written leads to planning mistakes: companies that passively wait for aid that won’t arrive before 2027, or that try to fit an AI project into a mold that hasn’t been defined yet.

This article separates what Plan IA360 actually says — with date and document — from what is still forecast, third-party calculation, or press comparison. And it outlines what your company can do in the meantime, regardless of whether the voucher ends up taking the shape announced today.

What we know about the AI Voucher today, in one sentence

On September 21, 2026, the Spanish Government presented Plan IA360, a 12-month roadmap that includes a future AI Voucher for SMEs and sole proprietors, with a planned allocation of €600 million and the goal of reaching 25,000 companies. As of this article’s publication date, there is no regulatory basis, no call for applications, and no amount per company: the plan itself places the pilot in the first half of 2027 and the general call “before the end of 2027.” Any specific per-company figure you read today is, at best, an anticipation.

What exactly is Plan IA360, and where does the AI Voucher fit in?

Plan IA360 is, according to the Spanish Prime Minister’s office itself, a roadmap of actions to be carried out over the next 12 months so that Spain can take advantage of AI — not a law already in force. The stated goal is that by 2030 more than half of Spanish companies will have integrated AI into their operations. Within that plan, the AI Voucher appears as one of the initiatives aimed at SMEs and sole proprietors (La Moncloa, 9/21/2026).

This distinction matters: a plan announces intent and a timeline; a call for applications with regulatory basis is what creates an enforceable right to apply for aid. Plan IA360 is the former. The AI Voucher, today, is not yet the latter.

What the official document actually says, with date and page

The baseline figure and the 2030 target

Plan IA360’s own document, dated September 20, 2026, cites as a baseline that 21.1% of companies with 10 or more employees were using AI in the first quarter of 2025, according to Spain’s National Statistics Institute (INE) survey on ICT use and e-commerce in companies. The plan’s goal is to go from that 21.1% to 55% of companies using AI by 2030 (Government of Spain, Plan IA360, official PDF).

This figure should be read precisely: the 21.1% measures only companies with 10 or more employees, not microenterprises or sole proprietors. The AI Voucher, by contrast, is announced as targeting precisely SMEs and sole proprietors — a universe that survey does not cover. Saying “one in five Spanish companies uses AI” is not the same as saying “one in five companies with 10 or more employees uses it”; the plan only claims the latter.

What the voucher would fund and how it would be paid

According to the official PDF, the voucher’s design would include milestone-based payments and conditions tied to AI training for employees and the actual incorporation of AI into the beneficiary company’s internal processes (Government of Spain, Plan IA360, official PDF). The word “would include” matters here: it’s a design-stage conditional, not a closed condition set out in published regulations.

According to coverage of the announcement, the voucher would not fund mere subscriptions to software licenses, but rather services that transform production processes, delivered by European technology companies that add their own proprietary value — development, integration, sector expertise, or process redesign — on top of foundation models (Marketing4ecommerce, 9/22/2026). This wording comes from press coverage of the official presentation, not from a verbatim quote we were able to verify line by line in the full PDF; treat it as “what was announced,” not as finalized legal text.

If this orientation holds in the final regulatory basis, it aligns with a principle we at E2M applied before any voucher existed: an AI license without a process behind it changes nothing in a company. What transforms a sales process is the combination of reliable information, a specific use case, and someone accountable for using and measuring it — not the tool itself. We cover this in AI for Sales Processes: Where to Start Without Buying Another Tool Without a Plan.

The real timeline: Red NEURONA and a pilot before the call for applications

The voucher doesn’t appear as a stand-alone instrument: the document ties it to Red NEURONA, a public-private network of regional demonstration hubs. The timeline set out in the plan itself is: a first pilot with 100 SMEs in two autonomous regions before the end of 2026; expansion to 10 autonomous regions and 5,000 companies during 2027; voucher design and regulatory preparation in the first half of 2027, with a general call “before the end of 2027” (Government of Spain, Plan IA360, official PDF).

In other words: even if the entire timeline is met without delays — something no document can guarantee — the general call would not open before 2027.

What doesn’t exist yet (and why it matters that you know it)

As of this article’s publication date, there is no regulatory basis, order, or call for applications published in Spain’s Official State Gazette (BOE) for the AI Voucher. There is no per-company amount, no aid percentage, no confirmed managing body, no finalized legal instrument, and no application opening date (ePoint, consistent with what can be verified in the official document).

This has an immediate practical consequence: any figure you see published about “how much the voucher will give you” is, at best, a third-party estimate. The €600 million allocation with the goal of reaching 25,000 companies is the program’s aggregate figure, not the amount per beneficiary (El Economista). Dividing €600 million by 25,000 companies to get a per-company average is a calculation some outlets make as an illustrative exercise, not an official figure; it doesn’t indicate what your company will receive, among other reasons because the plan speaks of milestone-based payments, not a fixed amount.

Nor should this voucher be confused with other aid programs that already exist — some digitalization lines run by chambers of commerce carry different percentages and caps — or assumed to work with the same mechanics as Kit Digital, Spain’s existing digitalization voucher program, a comparison part of the press has made as a rough guide, not because the AI Voucher already has a catalog of approved digitalization agents or company-size-based tiers like Kit Digital’s.

Why “waiting for it to launch” is the worst strategy for your company

There’s a reasonable temptation: if there’s no regulatory basis yet, why move? Because what a call for applications of this kind will foreseeably require — real employee training, demonstrable incorporation of AI into processes, measurable milestones — is exactly what any company needs before applying AI, with or without public aid. Waiting for the call to exist before starting to think about this means losing time you could have spent building judgment, testing a defined use case, and already having evidence of what works in your specific sales process.

At E2M we frequently see SMEs that, when a new aid program or tool appears, try to fit the project in backwards: first they decide “we’re going to apply for the voucher” or “we’re going to buy the tool,” and only then look for a process to plug it into. The order we advocate is the opposite: first the sales process you want to improve, then the information source that feeds it, then who uses it and how you measure the result. If public aid appears along the way, it adapts to that process — not the other way around. We explain this for the decision to automate with no public aid involved in When an SME Should Not Automate Yet.

What your company can prepare now, with or without the voucher

It doesn’t matter whether the AI Voucher ends up resembling the September 2026 announcement or changes during the subsequent regulatory process: these six questions are what any company should be able to answer before applying for AI-related aid, and also before buying any tool with no aid involved at all.

• What specific sales process do we want to improve? Not “incorporate AI” in general, but a specific point: proposal follow-up, lead qualification, responding to technical inquiries, drafting first drafts.
• What reliable information source would feed that process? An agent or copilot working on disorganized or outdated data doesn’t improve the process — it degrades it faster.
• Who on our team would actually use it? Without a person responsible for operating and reviewing it, there’s no “incorporation into processes” — there’s just an unused license.
• How would we measure whether it worked? Before implementing anything, define which business metric (response time, proposal conversion rate, hours freed up) would confirm it was worthwhile.
• What part of this could we already test without waiting for any aid? If the answer is “nothing,” the project probably isn’t defined clearly enough yet.
• Have we identified the regulatory risks of the use case? If the process touches sales or customer service, you should review the obligations that already exist, independent of the voucher (we cover this in The AI Act and Businesses: What Your Sales and Customer Service Team Should Review).

If your company can answer all six with more than just intuition, you’re in a position to act once the call for applications exists and, more importantly, you’re in a position to act now, without depending on it.

What E2M would not do

We would not offer to “manage the application” for aid that still has no regulatory basis, nor would we promise preferred access, approval, or a specific voucher amount for something that today is an announcement, not a call for applications. Nor would we build an AI use case designed to fit the anticipated requirements of a future aid program without first validating that it solves a real business problem for the company: the correct order is process → evidence → aid, if it comes — not the reverse.

Nor would we conflate the AI Voucher with other regulatory obligations that already exist today, such as those arising from the AI Act for systems that interact with customers: these are different frameworks, with different timelines and requirements, and presenting them as a single thing confuses more than it helps.

Sources and limits of this guide

• La Moncloa, presentation of Plan IA360 (9/21/2026). Confirms the official announcement, its nature as a 12-month roadmap, and the stated 2030 goal. It is not a law in force and contains no aid regulatory basis.
• Government of Spain, Plan IA360 PDF document (9/20/2026). Primary source for the INE 21.1% figure, the 55% target for 2030, the voucher’s planned design (milestone-based payments), and the Red NEURONA timeline. It does not include a per-company amount, aid percentage, or application procedure.
• Marketing4ecommerce (9/22/2026). Reports statements from the official presentation on the voucher’s orientation toward value-added services versus licenses. It is specialized press covering the announcement, not legal text verified line by line.
• El Economista. Reports the €600 million allocation and the goal of 25,000 companies. It is general press covering the official announcement, not a source for calculating individual per-company amounts.
• ePoint. Confirms the absence of regulatory basis, order, or call for applications in the BOE as of publication date, consistent with the official document itself.

This guide reflects the state of the announcement as of September 2026. It is not legal advice and does not guarantee that the voucher’s final design will match what is described here: once regulatory basis or a call for applications is published in the BOE, this information should be reviewed, and for the formal application, it’s advisable to seek specialized grant/subsidy advice.