Every company with salaried staff pays a social security contribution for vocational training every month. A portion of this comes back in the form of training credit, which is spent on courses for the workforce and recovered by deducting it from Social Security contributions. It is money already paid. And in most SMEs, it expires every 31 December without anyone having touched it.
Meanwhile, there is a training that from February 2025 is mandatory for any company using artificial intelligence: the AI literacy of Article 4 of the EU AI Act. Putting the two things together seems obvious. What is not so obvious is how, because "rebatable" is not a label that a course carries: it is a process carried out by the company, with specific requirements. This guide walks through them one by one.
How much credit your company has
The credit is calculated based on what the company contributed for vocational training the previous year, applying a percentage set each year by the Budget Law, which depends on the workforce size:
- From 1 to 5 people: a guaranteed minimum of €420 a year, regardless of the contribution.
- From 6 to 9: 100% of the amount contributed (and never less than €420).
- From 10 to 49: 75%.
- From 50 to 249: 60%.
- 250 or more: 50%.
For a company with fewer than 50 people, the actual credit usually ranges between those €420 and a few thousand. It can be checked in the FUNDAE application with a digital certificate, or your accountant or payroll firm can look it up. A detail that almost no one takes advantage of: companies with fewer than 50 workers can accumulate unspent credit from one year into the following two, by ticking the corresponding option before 30 June.
There is a counterpart for workforces of 6 people or more: the company must contribute a portion of the cost from its own funds, from 5% (from 6 to 9) to 40% (250 or more). In practice, this is almost a formality, because that portion can be covered by the salary of the hours during which the workforce trains within the working day, with no additional outlay. Micro-enterprises of up to 5 people contribute nothing.
What FUNDAE does not do
It is worth debunking two ideas before moving on. First: FUNDAE does not approve courses. There is no "rebated course" seal that a provider can display. What exists is a training action that your company notifies, delivers according to certain requirements, and rebates afterwards. Second: it is not a subsidy. No one transfers money to you; the company deducts the amount from the contribution statement of the month following the end of the course, within the same calendar year.
Therefore, when a provider tells you "this course is rebatable", what they are actually telling you is "this course meets the requirements for you to rebate it". The responsibility, and the file, lie with the company.
The five steps
- Check the available credit and decide who manages the process: the company itself in the FUNDAE application, or an organising entity (usually the accountant or payroll firm or a registered training centre) that does it on its behalf and groups several companies together.
- Notify the start of the training action at least 2 working days in advance: content, hours, modality, participants, dates. If there are employee representatives / works council, they must be informed beforehand and have 15 working days to give their opinion.
- Deliver the training in compliance with the modality's requirements (for e-learning, those in the next section).
- Notify the completion with the list of participants who have finished and the cost, which must be backed by an invoice in the company's name.
- Apply the rebate to the following month's contributions. And keep the file for four years, which is the period during which the Spanish public employment service can request it.
What FUNDAE requires when the course is online
Online training is called, in their vocabulary, e-learning, and it has its own rules. The ones that really matter are these:
- A platform available 24 hours a day, which records the activity of each participant and allows continuous monitoring of their progress.
- Learning controls: for a person to be counted as trained, they must have completed at least 75% of the periodic monitoring controls planned in the course. In e-learning, attendance is not measured by connection hours; this is what is measured.
- A tutor with methodological training in online teaching or at least 30 hours of experience, reachable through the platform itself, with a maximum of 80 participants per tutor.
- Data backups and access to the platform for monitoring and control actions by the administration, if any.
- A financial cap: FUNDAE recognises a maximum of €7.5 per hour per participant in e-learning. The rebate never exceeds the actual cost of the course.
The numbers with our course
At NAiOS Academy we have published "IA con criterio · Alfabetización en IA (art. 4 AI Act)": five pathways by role of between 2 and 6 hours, 83 lessons with voiceover, a final exam with a 75% threshold and a verifiable certificate, from €30 per person. With the module of €7.5 per hour, the calculation is simple:
- 2-hour pathway (all staff): up to €15 rebatable per person, half the course.
- Pathway of 4 hours or more (intensive users, sensitive areas, management, IT): the full €30. The credit covers the entire course.
With the guaranteed minimum of €420, a micro-enterprise can train its entire workforce and have credit left over. And if planned in the last quarter, Article 4 compliance is met just before the year's credit expires.
Which part of the file is generated automatically
Inspections for Article 4 and FUNDAE ask for similar things: who did what, when, and with what result. The platform generates these as the course progresses. Each completed lesson is dated; the initial diagnostic, the chapter questions and the exam are recorded with their scores; the certificate carries a code and a QR code that anyone can verify. When the company purchases the course for its team through NAiOS Classroom, the training manager sees the progress of each person on their dashboard, who has finished and who is halfway through, and can export it to attach to the completion notification.
What is not generated automatically, and must be finalised before notifying the start, is the tutoring: who answers the participants' questions during the course and with what response commitment. We organise this with you and your organising entity, with the number of hours to be declared per pathway, so that the start notification is correct the first time around.
How to get started
Three things, in this order. First, ask your accountant or payroll firm how much credit you have this year and whether they already act as an organising entity; if not, we work with one. Second, decide which pathway corresponds to each person: someone who writes emails cannot be trained in the same way as someone who makes decisions about CVs, and this, in addition to being required by Article 4, determines the hours to be declared. Third, write to us from the contact page with your approximate workforce size, and we will send you the schedule and the actual cost after the rebate.
In summary
- Training credit is money already contributed, with a minimum of €420 a year, and it expires on 31 December. Companies with fewer than 50 people can accumulate it by requesting it before 30 June.
- FUNDAE does not approve courses: the company applies the rebate, notifying the action at least 2 working days before starting and applying the deduction to the contribution upon completion.
- In e-learning, anyone who completes at least 75% of the learning controls counts, with one tutor for every 80 participants and a cap of €7.5 per hour per person.
- With a pathway of 4 hours or more, the AI literacy course from NAiOS Academy is fully covered by the credit. The dated lessons, scores and verifiable certificate constitute the file required by both FUNDAE and Article 4.
Sources
- FUNDAE: rebating scheduled actions — how the credit and the rebate work.
- FUNDAE: frequently asked questions — notification deadlines, e-learning requirements and tutoring.
- Ley 30/2015, regulating the Vocational Training System for employment, Real Decreto 694/2017 and Orden TMS/368/2019 — credit, co-financing, credit reservation, tutors in e-learning and the 75% of controls criterion. The credit percentages by workforce size are set each year by the State General Budget Law.
- Mandatory training in AI (Art. 4 AI Act): what it requires and how to prove it — the obligation that this guide helps to finance.
This article is for informational purposes and does not constitute legal or employment advice. The percentages, modules and deadlines are those in force at the date of publication; confirm them with your accountant or payroll firm or on the FUNDAE website before notifying a training action.
