The Plan IA360 was presented on 21 September 2026. It remains an announcement: there is no open call, no governing rules and no application window for the voucher this article refers to.
Many businesses already pay for a Microsoft 365 Copilot licence, a ChatGPT subscription or a similar generative AI tool, for the whole workforce or part of it. When businesses read that the bono empresarial de IA360 (the IA360 business voucher) will have a €600 million budget, the first question is whether that licence would qualify. The plan itself answers before anyone has to ask: it will not fund «la mera suscripción a licencias» (the mere subscription to licences).
The word doing the work in that sentence is «mera» (mere). The plan doesn't say that Copilot or ChatGPT are excluded as tools; it says that simply being subscribed, and nothing more, isn't a project. This page doesn't repeat that analysis with another generic example: it takes one specific tool, Copilot, and describes what real work — not the licence — would actually fit the conditions the plan sets: that it is provided by a European technology company, that it uses a foundation model as an input, that it adds its own value, and that this value translates into development, integration, sector knowledge, data processing or process redesign.
Before planning anything, work out what you already spend
Before planning any integration work around Copilot, it helps to be clear about what the part the voucher would never fund actually costs today: the licence itself. The Microsoft 365 Copilot cost calculator (in Spanish) only asks for the number of users and the company's base plan, and returns the monthly and annual cost instantly, with no sign-up. With that figure set apart, it is easier to see afterwards which part of a future project would be new work and which part would simply remain a subscription.
Switching Copilot on isn't the same as implementing it
There is a distinction here that businesses already using Copilot tend to discover late: the licence switches the engine on, but it doesn't fix what was already underneath. SharePoint permissions that are too open, no classification labels in Purview, or no written usage policy all mean Copilot can expose content it shouldn't, or that the team abandons it by the third week because nobody knows what it's actually for in their role. That is precisely the work that separates a subscription from a project, and it is also, in practice, the process we follow in our enterprise Copilot consultancy service:
- Governance. Usage policy, connector review, Purview labelling.
- Technical configuration. Activation, identities, Graph permissions set to match each role.
- Role-based training. A salesperson, someone in finance and a technician use Copilot differently; there is no point training them the same way.
- Adoption. A twelve-week programme tracked against a single indicator: actual weekly use, not the number of licences switched on.
Four phases with verifiable work in each. None of this shows up on the licence invoice, and it comes a good deal closer than a bare subscription to what the plan describes when it talks about «rediseño de procesos» (process redesign) or «integración» (integration) — though only governing rules, which don't exist yet, will say for certain what qualifies and what doesn't.
The other end of the scale: when the process is searching your own documents
Copilot works well on what Microsoft 365 indexes for the user asking the question, with the permissions that person already had. When the process you want to transform needs the system to cite the exact source — document, page, section — over a corpus wider than one person's email and files, the work changes in nature. That's RAG, and its implementation process illustrates another form of «tratamiento de datos» (data processing) that the plan mentions as a condition: an upfront inventory of the document corpus (what exists, who can see it, what's duplicated or outdated), indexing each document with the source permissions carried alongside the fragment, and a retrieval-and-synthesis phase where the system cites document, page and section, or acknowledges it has nothing to answer with. Anyone who wants to go deeper into that full process can read our page on internal search with RAG.
What a business can do while there's no call for applications
None of the above depends on a call for applications for the voucher existing. Auditing SharePoint permissions, writing a usage policy or designing a role-based adoption programme is work that improves how Copilot performs today, with or without public support behind it. The plan doesn't say whether work done before a call exists would count towards a future application for the voucher; what is certain today is that it leaves the business with a Copilot that actually works, not just one that's switched on.
Frequently asked questions
Can I start Copilot governance work before the voucher exists?
Yes. Reviewing permissions, labelling in Purview and writing a usage policy doesn't depend on any call for applications; it's configuration work that improves the tool from day one.
Does the role-based training in the Copilot process count towards the training condition the voucher mentions?
The plan doesn't spell this out, because there are no governing rules yet. What can be said is that generic training and training designed by job role are different things, and that the second comes closer to the workforce AI training condition the plan ties to the voucher.
Is the Copilot calculator useful if I haven't taken out the licence yet?
Yes, it is also useful for estimating the cost before deciding, comparing plans and the expected number of users.
Do I need Copilot already up and running to set up a RAG system over my documents?
No. They are two independent projects. A RAG can be built over a company's document corpus without Copilot being implemented, and the other way round.
Flagship project 11, Diffusion area, Plan IA360, La Moncloa, 21 September 2026. For the full design of the voucher, see the €600m voucher; for the rest of the plan, the complete guide to the Plan IA360.
Content last verified: 22 September 2026.