CDTI R&D+i Grants 2024-2027: what changes and how it affects your company

Key data

Companies working with CDTI financing have an urgent task ahead: to verify whether the conditions of their projects remain valid following the modification published on April 11, 2026. The Order CNU/331/2026 modifies the regulatory bases approved just a year earlier through the Order CNU/161/2025, of February 7, which means that the rules of the game have changed in the middle of the validity period of the State Plan 2024-2027.

This is not a new regulation: it is a modification of existing conditions. This means that projects that were already approved or in process may be affected by the new criteria, especially regarding eligible expenses, execution deadlines or justification requirements.

What does this regulation establish?

Order CNU/331/2026 introduces changes to the regulatory bases that the CDTI uses to manage public grant calls within the framework of the State Plan for Scientific and Technical Research and Innovation 2024-2027. These bases are the reference document that determines how to access financing, what expenses are eligible, what deadlines apply and how project execution is justified.

According to available information, the changes may affect the following aspects:

• Eligibility criteria: conditions that the company or project must meet to access the grant.
• Amounts: maximum amounts, co-financing percentages or applicable financing brackets.
• Deadlines: dates for application, execution or justification of projects.
• Expense justification: required documentation and types of admissible costs.

The regulation being modified, the Order CNU/161/2025, was approved on February 7, 2025 and established the general framework for grants for the entire 2024-2027 period. The April 2026 modification updates that framework without completely replacing it, so both orders must be read together to understand the current conditions.

The specific details of each change are not broken down in the available information. To know the exact details of which articles or conditions are modified, it is necessary to consult the complete text in the BOE (BOE-A-2026-8122).

Economic and operational impact

The impact of this modification depends directly on what specific aspects have changed. However, there are three risk scenarios that every company with CDTI projects must evaluate:

• Expenses already incurred that cease to be eligible: if the new bases modify the types of admissible costs, expenses already incurred may not be justifiable, which would generate a risk of reimbursement of the grant received.
• Projects in the application phase that do not meet the new criteria: an application prepared under the 2025 bases may not comply with the requirements modified in 2026, which would require reformulating the proposal.
• Execution or justification deadlines that have changed: if deadlines have been shortened or modified, the company may incur non-compliance without knowing it if it does not review the new conditions in time.

From an operational perspective, this modification requires R&D, financial and legal teams to coordinate to review the status of each active project against the new bases.

Who does it affect?

• SMEs with R&D+i projects financed by the CDTI within the framework of the State Plan 2024-2027, both in execution and application phases.
• Large companies with research or technological development projects that have active or pending CDTI grants.
• R&D and finance departments responsible for managing calls and justifying expenses to the CDTI.
• CFOs and financial directors who must evaluate the risk of reimbursement or changes in the financing conditions of ongoing projects.
• Advisors, grant managers and consulting firms that process CDTI grants on behalf of their clients.
• Research entities and technology centers that participate in collaborative projects with companies under this grant framework.

Practical example

An SME in the technology sector submitted in 2025 a software development project under the regulatory bases of Order CNU/161/2025. The project was approved and is currently in execution, with personnel and subcontracting expenses already incurred.

Following the publication of Order CNU/331/2026, the company's R&D manager must verify whether the new bases modify any of these critical elements for their project:

1. Whether subcontracting expenses remain eligible at the same percentages as when the project was approved.
2. Whether the final justification deadline has changed, which could advance the deadline for submitting documentation.
3. Whether the company's eligibility criteria continue to be met under the new conditions (for example, if requirements regarding size, sector or type of activity have been modified).

If any of these points have changed, the company must contact the CDTI to learn how it affects their specific project and whether it is necessary to submit additional documentation or reformulate any aspect of the execution.

What should companies do now?

1. Download and read the complete text of Order CNU/331/2026 available in the BOE (BOE-A-2026-8122) to identify exactly which articles of the original bases have been modified.
2. Compare the new conditions with the current status of each active CDTI project: eligibility of expenses, execution deadlines and justification requirements.
3. Identify whether there are expenses already incurred that may be affected by changes in eligibility criteria, to assess the risk of reimbursement.
4. Review applications in preparation