Modelo 720 in 2026: Declaring Foreign Assets as a Spanish Tax Resident

An informative declaration, not a tax: Modelo 720 tells the Agencia Tributaria what you hold abroad. If you are a Spanish tax resident with foreign accounts, securities or property worth more than EUR 50,000 in any one category, you must file it by 31 March each year. The old confiscatory penalties died in 2022, but the obligation itself is very much alive.

What is Modelo 720 and who must file it?

Modelo 720 is an annual informative tax return that Spanish tax residents file with the Agencia Tributaria to report assets and rights held outside Spain. It was introduced by Law 7/2012 as an anti-fraud measure, and the legal basis now sits in the Disposición Adicional Decimoctava of the Ley General Tributaria (Law 58/2003). It is an information declaration, not a tax assessment: filing it does not itself trigger a tax charge, but failing to file is a tax offence.

Anyone considered a Spanish tax resident must file, including natural persons and legal entities resident in Spanish territory. The obligation extends beyond outright owners to authorised signatories, beneficiaries, usufructuaries and anyone with effective control of the asset. If you have moved to Spain under the Beckham Law special regime, check your status carefully: Beckham regime holders are taxed as non-residents on foreign income and are generally exempt from Modelo 720 during the regime period, but confirm this with a tax advisor.

What are the three asset blocks and the EUR 50,000 threshold?

Modelo 720 splits reportable assets into three independent blocks. Each block has its own EUR 50,000 threshold, applied to the combined value of all assets in that block. If a block’s total stays below EUR 50,000, you do not report it at all. If it exceeds EUR 50,000, you must report every asset within that block, not just the portion above the threshold.

Block	What it covers	Threshold trigger
Block I: Accounts	Current, savings and investment accounts at foreign financial institutions	Balance at 31 December exceeds EUR 50,000 OR average Q4 balance exceeds EUR 50,000
Block II: Securities and insurance	Shares, investment fund participations, life insurance and annuities held abroad	Fair market value at 31 December exceeds EUR 50,000
Block III: Real estate	Property and real estate rights (ownership, usufruct, use rights) located abroad	Acquisition cost exceeds EUR 50,000

A practical detail on Block III: the threshold uses acquisition cost, not current market value. A property bought for EUR 60,000 in 2010 that is now worth EUR 45,000 still triggers the filing obligation. For Block I, either the 31 December balance or the average Q4 balance crossing EUR 50,000 triggers reporting. The Agencia Tributaria’s official FAQs confirm that the three blocks are separate obligations filed on the same form.

When is the Modelo 720 deadline in 2026?

The filing window runs from 1 January to 31 March 2026, covering assets held as of 31 December 2025. The Agencia Tributaria’s submission periods page states that where technical reasons prevent online filing within the regulatory period, filing is permitted within the four calendar days following the deadline. Filing is electronic only, via the AEAT sede, and there is no paper option.

Do I need to file every year?

No. Once you have filed Modelo 720 for a given block, you only re-file that block when one of two things happens: the block’s value increases by more than EUR 20,000 compared with the last filed return, or a previously declared asset is sold, transferred or cancelled. The EUR 20,000 increment is measured per block, not per individual asset, and the comparison is against the last year you actually filed, not necessarily the immediately preceding year. The Agencia Tributaria’s filing frequency guidance illustrates this with a worked example: a taxpayer whose Q4 average balance rose EUR 15,000 one year and EUR 18,000 the next would not re-file until the cumulative increase against the last filed year crossed EUR 20,000.

What happened to the old penalties?

The original Modelo 720 penalty regime, introduced by Law 7/2012, was among the most severe in European tax law. Non-compliance triggered three consequences: undeclared assets were presumed to be unexplained wealth gains taxed in the oldest open period; there was no statute of limitations, so AEAT could pursue assets acquired decades earlier; and a 150% penalty was applied to the value of the undeclared assets, on top of fixed fines of EUR 5,000 per data item (minimum EUR 10,000). A taxpayer with EUR 500,000 of undeclared foreign assets could face penalties exceeding EUR 750,000, more than the assets themselves.

On 27 January 2022, the Court of Justice of the European Union ruled in Case C-788/19, Commission v. Kingdom of Spain that this regime violated Article 63 TFEU on the free movement of capital. The Court identified three specific failures: the irrebuttable presumption of unexplained gain, the disproportionate 150% sanction, and fixed fines out of all proportion to penalties for equivalent domestic reporting failures with no total cap. Crucially, the Court did not strike down the reporting obligation itself, only the penalty regime.

Spain responded with Law 5/2022 of 9 March, which abolished the special Modelo 720 sanctioning regime and aligned penalties with the general framework of the Ley General Tributaria. The unlimited statute of limitations was replaced by the standard four-year prescription period.

What penalties apply now under the reformed regime?

Since Law 5/2022, failures on Modelo 720 are sanctioned under the ordinary provisions of the Ley General Tributaria (Law 58/2003), specifically Article 198 on late or missing information declarations. The BOE consolidated text sets out the current figures:

Non-compliance	Current sanction under LGT Art. 198
Late filing without prior AEAT request	EUR 20 per data item, minimum EUR 300, maximum EUR 20,000
Filing after an AEAT request	Higher penalties under Art. 198.3, calibrated to turnover
Incomplete, inaccurate or false data (monetary)	Proportional fine up to 2% of undeclared amounts, minimum EUR 500
Incomplete, inaccurate or false data (non-monetary)	EUR 200 per data item

Late filing voluntarily presented before AEAT chases you halves the sanction and its minimum and maximum limits. The key point: these are ordinary informative-declaration penalties, the same ones that apply to domestic filings such as Modelo 347 or Modelo 190. The confiscatory 150% regime is gone.

Does Modelo 720 apply to property I own in the UK or Ireland?

Yes, if you are a Spanish tax resident. Block III covers real estate located abroad, including full ownership, usufruct and use rights. The threshold is acquisition cost, so a holiday home in the UK bought for EUR 120,000 is reportable regardless of its current market value. This is one of the most common triggers for British residents who have relocated to Spain, and it sits alongside the annual non-resident tax obligations on any Spanish property you may also own. If you are a non-resident owner of Spanish property, see our guide to annual property taxes for non-residents for the separate IBI and Modelo 210 regime.

What about cryptocurrency and Modelo 721?

Virtual currencies are not reported on Modelo 720. The Agencia Tributaria explicitly states on the Form 720 procedure page that the information declaration on virtual currencies located abroad is not required for the relevant fiscal years. Crypto assets held on foreign exchanges are instead declared on Modelo 721, a separate informative return introduced specifically for this purpose. If you hold crypto on a Spanish-registered exchange, different reporting rules apply through Modelo 172.

A worked example: a relocating buyer with UK assets

Consider a British buyer who becomes a Spanish tax resident in 2025 after purchasing a property on the Costa del Sol. At 31 December 2025 they hold: a UK current account with EUR 32,000, a UK savings account with EUR 28,000, a UK stocks and shares ISA valued at EUR 70,000, and a UK buy-to-let property acquired for EUR 180,000. Their filing position for the 2025 fiscal year (deadline 31 March 2026) would be:

Block	Total value	Above EUR 50,000?	File?
Block I: Accounts	EUR 60,000 (32,000 + 28,000)	Yes	Yes, report both accounts
Block II: Securities	EUR 70,000	Yes	Yes, report the ISA
Block III: Real estate	EUR 180,000 acquisition cost	Yes	Yes, report the buy-to-let

All three blocks exceed the threshold, so this taxpayer files all three on a single Modelo 720. Next year, they only re-file a block if it rises by more than EUR 20,000 against the 2025 figure or if an asset is sold. If they later sell the buy-to-let and the proceeds move the accounts block up by EUR 25,000, they re-file Block I and Block III (to report the cancellation). This is the kind of cross-border position that a Spanish tax advisor (asesor fiscal) should review before the 31 March deadline, especially if you are also navigating the US-Spain tax position or the post-Brexit 90/180 rule as part of your relocation.

The bottom line

Modelo 720 is a reporting obligation, not a tax, and the post-2022 penalty regime is proportionate. But the filing requirement itself is firm: if you are a Spanish tax resident with more than EUR 50,000 in any one of the three foreign-asset blocks, the 31 March deadline applies. File electronically through the AEAT sede, keep records of acquisition costs for property, and re-file only when a block moves by more than EUR 20,000 or an asset is disposed of. The old 150% penalty is dead, but non-filing still carries a real fine under the ordinary LGT regime.

This guide is general information, not legal or tax advice. Rules change and individual circumstances differ. Verify current requirements with an independent lawyer (abogado) or tax advisor (gestor/asesor fiscal) before acting.