Modelo 720 and 721 Spain 2026: Foreign Assets Declaration for Residents

Modelo 720 is the informative declaration of assets and rights located outside Spain, governed by Article 42 bis, 42 ter and the eighteenth additional provision of the General Tax Law. You pay nothing by filing it. You are telling the Agencia Tributaria that you, as a Spanish tax resident, control foreign assets above the thresholds.

You are a Spanish tax resident for a calendar year if any of the following is true: you spent more than 183 days in Spain that year, your main economic interests sit in Spain, or your non-separated spouse and minor children habitually reside here. If you hold a Non-Lucrative Visa or a Digital Nomad Visa and live in Spain on it, you are almost certainly resident, even when your employer and bank accounts sit abroad. The residency test is covered in detail in our guide to Spain residency paths in 2026.

Modelo 720 covers three categories, each with its own EUR 50,000 threshold calculated in isolation:

• Category 1. Accounts at foreign financial institutions. Current accounts, savings accounts, deposits, credit balances. You declare if the sum of year-end balances OR the sum of average Q4 balances exceeds EUR 50,000.
• Category 2. Securities, rights, insurance and life or disability annuities deposited, managed or obtained abroad. Shares, bonds, funds, participations in foreign entities, unit-linked policies, private pensions in payment outside the Spanish public system.
• Category 3. Real estate and rights over real estate located abroad. A flat in London, a plot in Florida, a holiday house in France.

If no single category crosses EUR 50,000, you file nothing. If one category crosses the line, you declare that category in full, including items below EUR 50,000 inside it.

Modelo 721 is the equivalent form for virtual currencies held in custody by persons or entities that provide services outside Spain. It was created by Royal Decree 249/2023 and the first filing window ran in early 2024 for 2023 holdings. By the 2026 window it is a routine fourth form alongside the three categories of 720. The threshold is EUR 50,000 in the aggregate crypto balance across all non-Spanish custodians at 31 December 2025, valued in euros at that date. Self-custodied wallets sit outside Modelo 721 because there is no third-party custodian abroad. Balances at a Spanish-regulated exchange are already reported via Modelo 172 and 173, so you do not file 721 for those. In practice 721 catches residents who kept accounts on Binance, Kraken, Coinbase, Bitstamp or similar platforms registered outside Spain. A modest BTC or ETH balance from 2021 can trigger it.

How do you file Modelo 720 and 721 in 2026?

Both forms are electronic only, via the Agencia Tributaria portal. There is no paper route. You need a digital certificate, DNIe or Cl@ve PIN. A gestor or tax lawyer with your power of attorney can file on your behalf, which is what most foreign residents arrange for the first year.

1. Confirm tax residency for 2025. Count days, check whether family and economic centre sit in Spain, and request a residency certificate from the AEAT if you need it for a double-tax treaty.
2. Gather year-end statements for 31 December 2025 from every foreign bank, broker, insurer, pension provider and crypto platform. Category 1 accounts also require the average balance for Q4 2025.
3. Value real estate abroad at acquisition cost in euros, converted at the ECB rate on the purchase date, not current market value. Keep the escritura, purchase contract or equivalent.
4. Convert currencies to euros at the official exchange rate published by the Banco Central Europeo or Banco de España for 31 December 2025.
5. Check the EUR 20,000 refiling rule. If you already filed 720 in a previous year for a given category, you refile only when the total for that category has grown by more than EUR 20,000 above the last declared figure, or when you have fully disposed of a declared asset.
6. File Modelo 720 online under Sede Electrónica, Impuestos y Tasas, Modelo 720. File Modelo 721 under the same menu. Both open on 1 January 2026 and close on 31 March 2026.
7. Keep the acknowledgement PDF and supporting file for at least four years, the general statute of limitations under Article 66 of the Ley General Tributaria. For omitted assets the clock may start later, so retain evidence longer.

The official instructions and the filing portal sit on the AEAT site: Modelo 720 at sede.agenciatributaria.gob.es. Read the instrucciones PDF each year. The AEAT occasionally tightens the technical schema without changing the law.

What penalties apply after the 2022 reform?

For a decade Modelo 720 carried a notorious regime: EUR 5,000 per undeclared item with a EUR 10,000 floor, treatment of undeclared assets as unjustified capital gains with no statute of limitations, and a 150% proportional fine on top. In January 2022 the Court of Justice of the European Union, in case C-788/19, ruled that regime disproportionate and contrary to EU free movement of capital. Spain repealed it through Ley 5/2022 of 9 March 2022.

Infractions related to Modelo 720 and 721 now fall under the general regime of the Ley General Tributaria. The ranges that apply in 2026 look like this:

Infraction	Legal basis	Penalty
Failure to file when obliged	Art. 198 LGT	EUR 200 fixed, reduced to EUR 100 if filed voluntarily late without prior AEAT request
Filing late without prior request	Art. 198 LGT	EUR 100 fixed
Filing with incomplete, inaccurate or false data	Art. 199 LGT	EUR 150 to EUR 250 per data group, with graduated increases
Filing by non-electronic means when electronic is mandatory	Art. 199 LGT	EUR 250 minimum
Omitted asset treated as unjustified capital gain (IRPF)	Art. 39 LIRPF, general rules	Standard tax plus late-payment interest and sanctions of 50% to 150%, with the four-year statute of limitations now applying

The critical shift is the fifth row. Before 2022, an undeclared foreign asset discovered by Hacienda was imputed as income in the oldest non-prescribed year with no time limit, which in practice meant forever. The general four-year statute of limitations now applies, and the tax authority has to prove the undeclared asset corresponds to undeclared income, rather than to savings from years already prescribed. That is a very different conversation at the Inspección office.

Penalties for Modelo 721 follow the same general LGT regime. The AEAT has been publishing requirement letters for 2023 and 2024 filings through 2025 and 2026, so this is not theoretical.

What traps actually catch first-time filers?

The people who get into trouble are rarely the ones hiding money. They are the ones who assumed something innocuous did not count. A short list of what we see repeatedly among foreign residents on the Costa Blanca:

Joint accounts and signatories. If you are joint holder, authorised signatory or beneficial owner of a foreign account, you declare the full balance, not your share. Two spouses with a joint UK account of GBP 60,000 both file for the whole balance.

Pension pots. A UK SIPP, a German Riester, a US 401(k) or a Dutch pensioen still in accumulation generally sits in Category 2 and counts toward the EUR 50,000 threshold. State pensions in payment usually stay outside 720 because there is no capital, but private and occupational pots are in.

Old investment accounts from before moving. A dormant brokerage account held since 2008 counts the same as one opened yesterday. Residency in Spain, not the account's age, is what matters.

Crypto on foreign platforms. Many residents still believe Modelo 721 is optional or deferred. It is neither. The threshold is low and the custodian's registered address determines whether the holding sits in 720, 721 or stays with the Spanish Modelo 172/173 system.

Exchange rate on acquisition. Foreign property is declared at acquisition cost in euros using the ECB rate on the day of purchase, not today's rate. A house bought in London in 2004 for GBP 350,000 goes on 720 at the historic euro figure. Document the conversion.

Refiling the wrong year. If a category grew by more than EUR 20,000 above the last declared figure, you refile the whole category, not the increment. People who report only the growth get a correction request.

Mixing up residency timing. Under Spanish rules you are resident for the whole calendar year or not at all. There is no split-year treatment comparable to the UK. If you moved to Spain in September 2025 and crossed the 183-day test, you are resident for all of 2025 and the 31 December balances are relevant.

Modelo 720 is informative, but what you declare on it has to be consistent with your IRPF return (worldwide income as a resident), your wealth tax filing if the regional threshold is crossed, and any future capital gains calculations. A quiet inconsistency between 720 and IRPF triggers inspection letters. If you also own Spanish property, the Modelo 210 regime stops applying once you become resident and IRPF takes over, a separate transition to manage.

FAQ

Does Modelo 720 create any tax to pay? No. It is a purely informative return. Tax, if any, arises through IRPF (worldwide income), wealth tax (Impuesto sobre el Patrimonio) in regions where it applies, or capital gains when you eventually sell. The form itself produces no liquidación.

I moved to Spain in 2025 on a Non-Lucrative Visa. Do I file for the first time in 2026? If you became tax resident in 2025 and any of the three Modelo 720 categories, or the Modelo 721 crypto threshold, was above EUR 50,000 at 31 December 2025 or at any relevant measuring point, yes. The first filing covers your foreign assets as of the end of your first resident year. Specific rules for US citizens sit in our note on American buyers and Spanish tax in 2026.

I already filed 720 in 2023. Must I refile every year? Not automatically. You refile only when a category's total has grown by more than EUR 20,000 above the last declared figure, or when you have disposed of a declared asset (closed the account, sold the property, cancelled the policy). If nothing material changed, you do nothing.

Are the old EUR 5,000-per-item fines still possible? No. They were struck down by CJEU case C-788/19 and formally removed by Ley 5/2022. The regime that applies in 2026 is the general LGT framework, with much lower fixed fines and a normal four-year limitation period for underlying income tax.

Do I file Modelo 721 for self-custodied crypto in a Ledger or a software wallet? No. Modelo 721 is specifically for virtual currencies held in custody by a person or entity providing services outside Spain. A private wallet you control yourself has no foreign custodian. It may still be reportable through other obligations if used for transactions, and it will matter on sale for capital gains.

Next steps

If you expect to file Modelo 720 or 721 for the first time in the January to March 2026 window, pull your 31 December statements now and brief a Spanish tax professional before the end of January. For a wider purchase view, see our guide for foreign buyers.