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Kit Digital and Kit Consulting: representations and appeal against a clawback or loss of the right to payment

Kit Digital and Kit Consulting: representations and appeal against a clawback or loss of the right to payment is filed with Red.es: sede electrónica y Plataforma de Tramitación del Kit Digital. With Managora you do it 100% online: you answer a few questions, sign a digital mandato (power of representation) and we draft, sign and file your recurso (appeal) for you. What we charge you: from €149. Official tasa (government fee): No official fees: neither Red.es nor the platform charges for replying, making representations or appealing. If the aid does have to be repaid in the end, that amount and its late-payment interest are paid to Red.es and are not part of our price.

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Red.es has sent you a request for documents, notice that it is starting proceedings for loss of the right to payment or for repayment (clawback), or the decision ordering it, and the clock is already running. We review the notice and the status of each Acuerdo de Prestación (service agreement), tell you your deadline, gather the evidence, draft your reply, your representations or the recurso de reposición (appeal for reconsideration) and file it for you or, if the platform does not accept us as your representative, leave it ready for you to sign. If you ask us to, we also send a formal written demand to the digitalisation agent (or to the Kit Consulting adviser) to justify the work or take on what is being claimed.

Practical guide: Kit Digital: the grant to digitise freelancers and SMEs. Requirements, deadlines and the steps, explained.

What we charge you
from €149
Managora's fee
€149.00 (21% VAT incl.)
Tasa (official government fee)
No official fees: neither Red.es nor the platform charges for replying, making representations or appealing. If the aid does have to be repaid in the end, that amount and its late-payment interest are paid to Red.es and are not part of our price.
Processing time
Representations: 15 working days from the day you open the notice (if you do not open it, it is deemed served 10 calendar days after it was made available). Request for documents: the deadline it gives (the request for additional documents is 15 working days). Recurso de reposición: one month from notification of the decision. Red.es has 12 months from the start of proceedings to notify its decision. We prepare it with time to spare and file it, or leave it ready for you to sign, without leaving it to the last day.
Where it is filed
Red.es: sede electrónica y Plataforma de Tramitación del Kit Digital ↗
What you receive
Recurso (administrative appeal)

Cost breakdown: Request for documents, waiver or voluntary repayment 149 €: replying to a request to correct or provide documents, or filing a waiver, a withdrawal or a voluntary repayment. Representations against loss of payment or clawback 249 €: representations against the start of proceedings for loss of the right to payment (in full or reduced) or for repayment. Appeal for reconsideration against the decision 349 €, with an application for a stay where appropriate. If you want the written demand to the digitalisation agent or adviser, add 99,00 €. VAT included, no official fees..

Kit Digital and Kit Consulting: representations and appeal against a clawback or loss of the right to payment: how is it filed?

  1. 1Answer the questions (about 8 minutes) and upload the Red.es notice.
  2. 2Payment according to your case: 149 €, 249 € or 349 € (VAT included), plus 99 € if you want the demand to the agent.
  3. 3We review the notice and the status of each Acuerdo de Prestación, and tell you which deadline applies and the exact last day.
  4. 4We gather the evidence (invoice, payment, sign-off, evidence of the solution and of the publicity, correspondence with the agent) and draft the reply, the representations, the recurso de reposición with an application for a stay, or the waiver, withdrawal or voluntary repayment.
  5. 5If the platform accepts us as your representative, you sign the authorisation electronically and we file it as your voluntary representative. If it does not, we leave everything ready and guide you so that you sign and file it yourself. Either way you will need your digital certificate, your Cl@ve or another signature method accepted by Red.es: we never ask for your certificate.
  6. 6We send you the filing receipt and, if you asked for it, the demand to the agent with proof that it was sent.

Which documents do you need?

  • •The full Red.es notice (request, notice of proceedings or decision), downloaded from the platform. Not needed if you only want to waive, withdraw or repay the aid.
  • •The Acuerdo de Prestación signed with the agent or adviser (optional).
  • •The invoice and proof of payment, including the unsubsidised part and the VAT (optional).
  • •Emails or messages with the agent or adviser (optional).
  • •Screenshots of the solution and of the publicity for the aid, if the notice objects to either (optional).

Legal basis and things to bear in mind

  • Kit Digital and Kit Consulting are closed to new applications: the last Kit Digital calls closed on 31 October 2025 and the Kit Consulting call on 31 March 2025, and neither Orden TDF/39/2026 (Kit Digital) nor Orden TDF/38/2026 (Kit Consulting) reopens them. This service is for businesses that already have the voucher and receive a request, notice of proceedings for loss of the right to payment or for repayment, or the decision.
  • Deadlines: 15 working days to make representations from the day you open the notice (if you do not open it, it is deemed served after 10 calendar days) and one month for the recurso de reposición against the decision. Red.es has 12 months from the start of proceedings to notify its decision; if it does not, the proceedings lapse.
  • What can be argued: proportionality where the breach is partial and you acted to comply (art. 36.4 of the Kit Digital rules and art. 36.3 of the Kit Consulting rules), the calculation of a reduced loss (from 1 % to 7 % depending on the months of delay in the invoice or the payment, and a flat 10 % for publicity) and lapse of the proceedings.
  • Even when the fault lies with the digitalisation agent or adviser, Red.es claims the money back from the beneficiary: the agent was paid the voucher, but you are the one answerable to Red.es. The written demand to the agent puts the failure on record and requires them to justify the work or take on the claim, but it does not guarantee that they will pay.
  • Repayment carries late-payment interest from the date of payment (4,0625 % in 2026). If you are going to repay anyway, a voluntary repayment stops the interest running from the day you pay.
  • Appealing does not by itself stop collection: in the recurso de reposición we apply for a stay, which is deemed granted if Red.es does not decide on it within one month.
  • A court challenge against the decision is not included: if it were needed, the Managora law firm handles it.

Kit Digital and Kit Consulting: representations and appeal against a clawback or loss of the right to payment: frequently asked questions

Kit Digital and Kit Consulting: representations and appeal against a clawback or loss of the right to payment: how much does it cost?

We charge you from €149: our fee plus, where applicable, the fixed official tasa we advance. Request for documents, waiver or voluntary repayment 149 €: replying to a request to correct or provide documents, or filing a waiver, a withdrawal or a voluntary repayment. Representations against loss of payment or clawback 249 €: representations against the start of proceedings for loss of the right to payment (in full or reduced) or for repayment. Appeal for reconsideration against the decision 349 €, with an application for a stay where appropriate. If you want the written demand to the digitalisation agent or adviser, add 99,00 €. VAT included, no official fees.. Managora's fee is €149.00, 21% VAT included (€123.14 net + €25.86 VAT). The official tasa charged by the authority (a suplido paid on your behalf, no VAT) is: No official fees: neither Red.es nor the platform charges for replying, making representations or appealing. If the aid does have to be repaid in the end, that amount and its late-payment interest are paid to Red.es and are not part of our price..

Kit Digital and Kit Consulting: representations and appeal against a clawback or loss of the right to payment: how long does it take?

Representations: 15 working days from the day you open the notice (if you do not open it, it is deemed served 10 calendar days after it was made available). Request for documents: the deadline it gives (the request for additional documents is 15 working days). Recurso de reposición: one month from notification of the decision. Red.es has 12 months from the start of proceedings to notify its decision. We prepare it with time to spare and file it, or leave it ready for you to sign, without leaving it to the last day.

Kit Digital and Kit Consulting: representations and appeal against a clawback or loss of the right to payment: which documents do I need?

You need to have to hand: The full Red.es notice (request, notice of proceedings or decision), downloaded from the platform. Not needed if you only want to waive, withdraw or repay the aid., The Acuerdo de Prestación signed with the agent or adviser (optional)., The invoice and proof of payment, including the unsubsidised part and the VAT (optional)., Emails or messages with the agent or adviser (optional)., Screenshots of the solution and of the publicity for the aid, if the notice objects to either (optional).. You do not upload them here: we collect the details through the guided chat.

Who files the procedure?

Managora files it in your name with Red.es: sede electrónica y Plataforma de Tramitación del Kit Digital. You only provide the details through the chat and sign a mandato (power of representation); we prepare, sign and register it.

Can it be done online?

Yes. The whole process is online: you answer a few questions in the guided chat, sign a simple mandato on screen and receive the receipt and the official documents by email, with full legal validity.

Related procedures

Based on the legislation in force and on the official site of the competent authority: Red.es: sede electrónica y Plataforma de Tramitación del Kit Digital ↗.

Managora Gestion SL (company number B88823893) is a private company. We are not Red.es: sede electrónica y Plataforma de Tramitación del Kit Digital, we are not affiliated with, authorised or endorsed by any public authority, and this website is not an official government portal. What you pay on this page is our fee for preparing, signing and filing the procedure on your behalf: it is separate from the official tasa, which where applicable belongs to the authority and is shown to you separately. You can carry out this procedure yourself, directly with Red.es: sede electrónica y Plataforma de Tramitación del Kit Digital.

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