Loss of the right to payment and refund of the Kit Digital (and Kit Consulting): why it arrives, how much they take and how to submit a defence

The digital voucher is not paid when granted: it is paid as each phase is justified. By signing the Digitalisation Solutions Provision Agreement, you transfer the right of payment to the digitalising agent and Red.es pays them when it verifies the justification.

The loss of the right to payment means that Red.es stops paying what it has not yet paid: the entire Agreement (full loss, pérdida integral) or a percentage (reduced loss, pérdida minorada). The refund means that it asks you to return what it already paid, with late payment interest from the day of payment. If phase 2 fails, both things arrive at the same time: a refund of what was paid for phase 1 and the loss of what was left for phase 2.

Both begin with an initiation resolution that indicates the cause, the breached obligations and the affected amount, and they are notified in the mailbox of the Kit Digital Processing Platform: the rules require electronic notification, which you open at the sede electrónica (official e-office).

As of 5 October 2026 the Kit Digital is closed to new applications (last closure, 31 October 2025) and the Kit Consulting as well (31 March 2025). Órdenes (Orders) TDF/39/2026 (Kit Digital) and TDF/38/2026 (Kit Consulting) do not reopen them: they clarify that what has been granted continues to be governed by their rules until each file is closed, 'including any possible refund procedures'.

Almost always for something that happened in the justification, which the agent submits on your behalf but for which you are the 'ultimate responsible party' according to the rules. The table of causes in this guide includes the 8 foreseen by the rules and Red.es: Agreements not signed on time, phase 1 or phase 2 unjustified, invoice or payment out of time, breach of the publicity requirements, withdrawal after payment and extinction of the company.

The deadlines: phase 1 lasts up to 3 months from the validation of the Agreement and is justified within 6 months from that validation; phase 2 lasts 12 months from the invoice and is justified in the following 3 months. If the agent does not justify on time, Red.es requires them to do so in 15 days and informs you. If you receive that notice, speak to the agent that same day: it is the last chance to avoid the problem.

It is not rare: the addendum to the agreement between Red.es and the Spanish Chamber of Commerce (BOE, Spain's Official State Gazette, of 22-09-2025) foresees 114,100 Agreements with complete loss and refund between the second half of 2025 and 2028.

When the failure concerns deadlines or the publicity requirements, Red.es does not take everything from you: it applies a percentage to the aid amount of the Agreement. According to its guide for beneficiaries (version of 7 March 2024), for an invoice or payment out of time, 1% to 7% is deducted depending on the months of delay. For breaching the publicity requirements, the fixed 10% set by the rules.

The percentages are added together. The official example from Red.es is a €3,000 Agreement with an invoice issued 20 days late (1%, €30), payment with 3 months and 20 days of delay (4%, €120) and publicity requirements not met (10%, €300): total, €450.

Before making written submissions (alegaciones), recalculate: the bracket depends on the months of delay over the maximum date, and the maximum date for payment changes according to the call (3 or 6 months). An error in dates or brackets is proven with documents that are already on record.

If what is being discussed is the entire Agreement, the amount is all the aid of that Agreement, with the limit of its category; if the entire voucher is discussed, it can reach €12,000 (I), €6,000 (II), €3,000 (III), €25,000 (IV) or €29,000 (V).

Yes. Red.es paid the agent because you transferred the right of payment to them, but the rules make the beneficiary ultimately responsible for the justification and expressly state that the lack of justification entails the demand for a refund 'from the beneficiary'. The notification and the payment letter (carta de pago) arrive in your name.

The agent faces removal from the catalogue and the penalties of the Agreement, but the Agreement model we have reviewed (call C022/22-SI) does not contain any compensation clause in your favour, although the rules require the Agreement to include the compensation that the parties must receive in case of breach. Recovering from the agent what you refund is a separate civil claim, based on your contract, which our firm handles.

Late payment interest runs from the day Red.es paid the agent until the refund is ordered, or until you pay if you do so earlier. The rate is the legal interest plus 25%: in 2026, 4.0625%. The rules allow you to refund voluntarily, without waiting to be asked, paying the corresponding interest; this serves to stop the clock when there is no possible defence.

In a comunidad de bienes (co-owned business), the co-owners are liable, jointly and severally and in proportion to their participation; in a dissolved and liquidated company, the shareholders are liable up to what they received in the liquidation.

When Red.es makes the notification available to you on the Platform (Buzón, Notificaciones: the mailbox and notifications menus), you have 10 calendar days to open it. If you do not log in, after 10 days it is considered notified anyway. If you click 'Rehusar notificación' (reject notification), it is also considered notified. In all 3 cases, 15 working days to make written submissions (alegaciones) start counting from the following day.

Afterwards, Red.es has 12 months from the date of the decision to open the procedure (acuerdo de iniciación) to notify you of the resolution. If it does not do so, the procedure expires. The refund claim becomes time-barred 4 years after the justification deadline expired, but any action by Red.es that is formally communicated to you interrupts that period.

First, the limit. The Red.es guide warns that 'new documentation provided together with the written submissions will not be taken into account': for Red.es, the written submissions serve to review what has already been provided, not to correct out of time. The rules, on the other hand, allow you to present 'the written submissions and documentation you deem appropriate'. The defence relies on what is already on record; a decisive document that was not provided is included anyway by invoking the rules, without counting on it being admitted.

What does work: the calculation of the delay (dates, bracket and deadline of 3 or 6 months); that what Red.es is missing was indeed presented with the justification or the correction; proportionality when compliance is significantly close to the total; that the agent was not formally required, with notice to you, to justify within 15 days; the procedure having lapsed, the refund claim being time-barred and the calculation of interest.

Our service 'Kit Digital and Kit Consulting: written submissions and appeal against the refund or loss of the right to payment' does this: we read the notification, the Agreement, the invoice, the payment and the justification history, we calculate your deadlines and we draft the written submissions within the 15 working days. You can see the current price on the service page.

Who signs: the written submissions are presented on the Platform, in Tramitación de Acuerdos (agreement processing), Alegaciones a la pérdida de derecho a cobro (written submissions against the loss of the right to payment), and are signed with a certificate or with Cl@ve (the Spanish electronic identity system; without Cl@ve in the first call, C005/22-SI). If the Platform does not admit Managora as a representative in your file, you sign with your Cl@ve or your certificate and we leave everything prepared for you and guide you step by step. We never ask for your digital certificate.

You have 3 paths: pay with the payment letter issued by the Platform, interest included; file an appeal for reconsideration (recurso de reposición) before Red.es within 1 month; or go to contentious-administrative proceedings within 2 months, before the judicial body indicated at the bottom of your resolution regarding appeals.

The appeal does not stop the collection on its own, but if you request the suspension and Red.es does not resolve it in 1 month, it is understood to be granted. Furthermore, a refund debt suspended when appealing, deferred or paid in instalments does not prevent you from being up to date to collect other subsidies.

The appeal for reconsideration is not a wasted step: in the Kit Consulting, Red.es upheld appeals in April 2026 from applicants considered to have withdrawn and ended up granting the aid. The same written submissions and appeal service for the Kit Digital and Kit Consulting prepares that appeal with the suspension request. You can see the current price on the service page. If it is necessary to reach the contentious-administrative stage, our firm handles it.

The Kit Consulting has a single phase: the adviser provides the service within 3 months from the validation of the Agreement and justifies it within 5 months from that validation. If they do not do so, Red.es requires the adviser to do so in 15 days, notifying you, and if they still do not justify, you lose the right to payment. The vouchers were for €12,000, €18,000 and €24,000 depending on the number of employees.

The reductions are in the rules themselves: 1% to 7% for an invoice issued more than 3 months after validation or for late payment, and 10% for breaching the publicity requirements. If you withdrew after payment and did not return the aid, refund proceedings are opened. The deadline for written submissions is 15 days and Red.es has 12 months to resolve.

The last deadline to sign Agreements ended on 31 May 2026 at 23:59 for vouchers granted since 28 February 2026 (the general deadline had ended on 31 October 2025): the part of the voucher not associated with Agreements is lost. Vouchers granted after upholding appeals for reconsideration (the last grant is from 29 June 2026) gave 3 months from their publication to sign the first Agreement. Red.es does not detail the channel for written submissions for the Kit Consulting: if the sede electrónica does not accept a representative, you sign and we prepare the document and guide you.