Modelo 720 is the return you use to tell the Spanish Tax Agency (Agencia Tributaria) about the bank accounts, investments and real estate you own outside Spain. Filing it doesn’t cost anything, and it only applies if you’re a tax resident in Spain and one of its three reporting categories is worth more than €50,000 on December 31. For what you hold at the end of 2026, the filing window runs from January 1 to March 31, 2027.
If you’ve just moved here, it’s normal that this wasn’t on your radar: your account back home, your brokerage or the family house are still there, and now Spain wants to know about them. The penalties that scare people most, €5,000 per data item, stopped applying in 2022. What hasn’t changed is the obligation to report.
Here’s who has to file, how each category is calculated, when you file again, how to submit it, what the penalties are today and what to do if you’re late.
- ✓It’s an informational return: nothing is paid with it. It applies to Spanish tax residents with more than €50,000 in any one of three categories: accounts; securities, funds and insurance; real estate.
- ✓It’s filed between January 1 and March 31 of the following year. For tax year 2026, the deadline is March 31, 2027.
- ✓You only file again if a category grows by more than €20,000 or if you sell, close or stop owning something you already reported.
- ✓Since 2022, general penalties apply: €20 per data item if you don’t file (between €300 and €20,000), and half that if you file late on your own initiative.
Do you want a expert consultation? Contact us and we will help you.
What Modelo 720 Is (and What It Isn’t)
Modelo 720 is an annual informational return that Spanish tax residents use to report their assets and rights abroad to the Spanish Tax Agency: bank accounts, securities, funds, insurance, annuities and real estate. It comes from the eighteenth additional provision of Spain’s General Tax Law (Ley General Tributaria) and is governed by Order HAP/72/2013.
“Informational” means it doesn’t calculate any tax: the income those assets produce is taxed on your Personal Income Tax (IRPF) return. Modelo 720 lets the Tax Agency know what you own and cross-check it against everything else. That’s why it isn’t a “file once and forget” form, and why you can’t ignore it because “there are no fines anymore.”
Who Has to File Modelo 720
Spanish tax residents have to file, both individuals and companies, as long as they exceed the thresholds. So do permanent establishments of non-residents and entities without legal personality, such as undistributed estates (herencia yacente) or co-ownership arrangements. Nationality doesn’t matter: an American, a Colombian or a German living in Spain is just as bound by it as any Spaniard.
You’re a tax resident if you spend more than 183 days in a calendar year in Spain or if your main economic interests are based here. Residency is also presumed if your spouse and dependent minor children live here. We cover this in detail in our guide to tax residency in Spain.
You don’t have to be the owner. Authorized signers, beneficiaries and anyone with a power of disposal also report. So does the beneficial owner: whoever actually controls the asset, even if it’s in someone else’s name.
If You Just Moved to Spain: Your First Year
Tax residency is measured by calendar year. If you arrived in 2026 and spend more than 183 days in Spain this year, you’re a tax resident for all of 2026. What you hold abroad on December 31, 2026 is what counts for the Modelo 720 due by March 31, 2027.
Here’s an example with numbers: an American retiree settles in Valencia in February 2026 with €90,000 in a US bank account and €60,000 in mutual funds held with a US firm. She spends more than 183 days in Spain, so she’s a tax resident that year and must report both categories by March 31, 2027. It’s the typical profile we describe in our article on the tax implications of the non-lucrative visa.
If Your Company Is Relocating Employees to Spain
Modelo 720 is the employee’s personal obligation, not the company’s. Even so, HR teams should add it to the relocation checklist:
- The Beckham Law changes the answer: if the employee opts into the impatriate regime (Beckham Law), they don’t have to file Modelo 720. Their family is only exempt if they’ve also opted into the regime.
- Group accounts have their own rule: an employee authorized on a foreign subsidiary’s account doesn’t report it if the Spanish parent company records it in its consolidated accounts or the notes to them.
Ideally, review this before the employee’s first December 31 in Spain, alongside the visa, as part of your employee relocation to Spain.
The €50,000 Rule: What Goes in Each Category
Modelo 720 bundles three separate reporting obligations, and each one has its own €50,000 threshold. You don’t add up everything you own abroad: you look at one category at a time, and if one exceeds the threshold, you report that whole category.
To put it in practical terms: you have €40,000 in a German bank account and a €70,000 stock portfolio with a brokerage in Ireland. The accounts category doesn’t reach the threshold; the securities category does. You report the securities only.
Watch out for two details that change the math. Negative account balances are netted against positive ones to see whether you reach the threshold. And life insurance that only covers death, with no surrender value, isn’t reported.
Shared Accounts and Assets: The Total Value Counts
The threshold is based on the asset’s total value, not your share. If you and your spouse share an account back home with €80,000, you both report the full €80,000 and state your ownership percentage, even though “your half” is €40,000.
One point that often confuses married couples: the account may be community property under Spanish rules but held in one spouse’s name. In that case, the other spouse also reports it, as beneficial owner of 50%, as long as they’re a Spanish tax resident too.
Who Doesn’t Have to File Even With Assets Abroad
These are the situations we see most often:
- People taxed under the Beckham Law: according to the Spanish Tax Agency, those who opt into the impatriate regime (Beckham Law) don’t have to file, because they aren’t taxed on their total income.
- Foreign securities held with a Spanish custodian: foreign shares or funds held with an entity incorporated or established in Spain that already reports to the Tax Agency don’t go on Modelo 720.
- Non-residents for tax purposes, even if they have an NIE (Foreigner Identification Number), a home or a bank account in Spain.
- People who were never required to file: if you never exceeded the threshold, you don’t have to report closing an account or selling an asset.
- Companies that record those assets in their accounting, under the conditions set by the regulations.
A detail worth knowing early: being an authorized signer only triggers reporting for accounts. If you’re authorized on a relative’s securities portfolio, that doesn’t require you to file Modelo 720 for those securities.
Filing Deadline and When to File Again
Modelo 720 is filed from January 1 to March 31 of the year after the one being reported, under article 7 of Order HAP/72/2013. For what you hold on December 31, 2026, the deadline is March 31, 2027.
After your first filing, you only have to file again for a category if one of these things happens:
- It grows by more than €20,000 compared with the value that triggered your last filing. For accounts, both the December 31 balance and the last-quarter average balance are compared.
- You stop owning something you already reported: you sell it, close the account or your authorization is revoked. You report the date and the value at that point.
An example with numbers: in March 2026 you reported accounts worth €60,000. On December 31, 2026 you have €78,000: that’s €18,000 more, so you don’t file that category again. If you had €85,000, the increase would be €25,000 and you’d need to file again by March 31, 2027.
How to File Modelo 720, Step by Step
Modelo 720 can only be filed online, through the Spanish Tax Agency’s official e-portal: there’s no PDF form to fill out. If you want the official text, the BOE (Official State Gazette) publishes Order HAP/72/2013 as a PDF, and the Tax Agency’s official FAQ (in Spanish) can be downloaded as a PDF from the e-portal.
- Gather your December 31 statements, the last-quarter average balance for each account and the deeds for any property.
- Convert amounts to euros and keep a record of the exchange rate you used.
- Work out each category separately and decide which ones you need to report.
- Sign in to the e-portal with a digital certificate, a Spanish electronic ID card or another method the Tax Agency accepts.
- Choose how to file: the online form (up to 40,000 records) or a file generated with compatible software.
- Submit the return and save the receipt, which includes a 16-character secure verification code.
A tip that saves time: the same shares bought on different dates go in separate records. A duly authorized third party, such as your tax advisor, can also file on your behalf.
Do you want a expert consultation? Contact us and we will help you.
Modelo 720 Penalties Today: What Changed After the CJEU Ruling and Law 5/2022
Since March 11, 2022, Modelo 720 has been subject to the general penalty rules in articles 198 and 199 of the General Tax Law. The change came with Law 5/2022. Earlier, on January 27, 2022, the Court of Justice of the European Union (CJEU) had ruled that the previous regime breached EU law (case C-788/19).
Each category is penalized separately, because each one is a distinct obligation. And the 50% reduction only applies if you file before the Tax Agency asks you to.
Put in numbers: you forgot to report a single account and you file on your own initiative in June. With so few data items, the fine stays at the €150 minimum; after a formal request, the minimum is €300. Under the old rules, those same cases started at €1,500 and €10,000.
The €10,000 and €1,500 minimum fines you still see online are no longer in force. But don’t read it the other way either: if the Tax Agency finds assets that don’t match the income you’ve reported, the problem is no longer Modelo 720, it’s your Personal Income Tax.
If You Missed the Deadline: How to Get Up to Date
If you had to file and didn’t, the sensible move is usually to file as soon as possible, on your own initiative. The law halves the penalty when there hasn’t been a formal request first. In practice:
- Check which tax years were affected and which categories exceeded the threshold in each.
- Review your Personal Income Tax for those years: unreported interest, dividends or gains weigh more than Modelo 720.
- Review Wealth Tax if it applied to you.
- If you’ve already received a formal request, answer it on time and with professional advice, as we do in tax inspections and formal requests.
Knowing whether Modelo 720 applies to you is the easy part; what prevents problems is making sure it matches your income, your assets and what the Tax Agency already receives from other countries. At ILLAY Legal, we review your assets abroad category by category and check whether the Beckham Law or another exception frees you from filing. If you’re behind, we prepare the voluntary filing through our personal tax returns service, fully online and in your language. Tell us which countries you hold accounts, investments or property in, their approximate balances and when you moved to Spain, and we’ll tell you whether you need to file Modelo 720 and how to get up to date.
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Frequently Asked Questions About Modelo 720
Do I Have to Report My US Brokerage Account on Modelo 720?
If you’re a Spanish tax resident and the brokerage holds your assets outside Spain, yes, it counts. Cash goes in the accounts category and stocks, ETFs or mutual funds in the securities category, each with its own €50,000 threshold. A typical account at a US brokerage held in the US falls into this case. What matters is where the assets are held in custody, not the app you use. If you’re unsure, ask your broker to confirm in writing where your assets are held and whether it reports to the Spanish Tax Agency.
Is Cryptocurrency Reported on Modelo 720?
No. Crypto held in custody abroad goes on a different return, Modelo 721, which has applied since tax year 2023. It works in a similar way: it’s filed between January 1 and March 31, and it only applies if your combined crypto held abroad is worth more than €50,000 on December 31. If you have accounts or shares abroad and crypto on a foreign exchange, you may need to file both returns.
I Inherited a Home in My Home Country. Do I Need to File?
Yes, if you’re a Spanish tax resident and your real estate category exceeds €50,000 on December 31. You report it from the time you become the owner, even if you share it with siblings: the property’s total value counts, and you state your percentage. While the estate is still undistributed, the estate itself may have to file. Keep in mind that Modelo 720 doesn’t replace Spanish Inheritance Tax, which is analyzed separately.
I Own a Vacation Home in Spain but Live in the US. Do I File Modelo 720?
No. Modelo 720 only applies to Spanish tax residents, plus permanent establishments and certain entities. Having an NIE, a home or a bank account in Spain doesn’t make you a tax resident. If you earn income here, your obligations fall under Non-Resident Income Tax (IRNR), which we explain in our guide to taxes in Spain for non-residents. Just note that if you spend more than 183 days here in the year you move, you’re a resident for that whole year.
Can I Correct a Modelo 720 I Already Filed?
Yes. If you left an asset out, you file a supplementary return with the missing records. If you’d rather redo it entirely, you file a replacement return, which cancels the earlier one for the same year. And if you only need to change data for something already reported, you do it through the Tax Agency’s service for reviewing and amending informational returns. It’s best to fix it quickly: an error the Tax Agency detects is penalized under article 199 of the General Tax Law.
Does Filing an FBAR or FATCA Report in the US Cover Modelo 720?
No. They’re separate obligations in separate countries: filing an FBAR or any other US foreign asset report doesn’t exempt you from Modelo 720 in Spain, and vice versa. In practice, you want the figures to match, because tax authorities exchange information. If you’re a US citizen and a Spanish tax resident, you’ll usually need to meet both requirements every year, each with its own deadlines and thresholds.
