DAC7 Platform Reporting for Short-Let Landlords in Spain: What Airbnb, Booking.com and Vrbo Tell AEAT About Your Rental Income

What is DAC7 and why does it matter for your Spanish rental income?

DAC7 is the shorthand for Council Directive (EU) 2021/514 of 22 March 2021, which amended Directive 2011/16/EU on administrative cooperation in the field of taxation. It forces digital platform operators to collect information about the sellers using their platforms and report it automatically to tax authorities. Spain transposed it through Ley 13/2023, de 24 de mayo (BOE-A-2023-12204), which added Disposicion Adicional 25 to the Ley General Tributaria (Ley 58/2003), with effect from 1 January 2023. The practical consequence for a non-resident landlord renting out a Costa del Sol property on Airbnb, Booking.com or Vrbo is that the platform now tells AEAT your gross rental income, your property address and the bank account where the money landed, and it does so without asking you.

This matters because AEAT already receives your Modelo 210 non-resident rental income tax filings (see our non-resident income tax Modelo 210 guide). DAC7 gives the tax authority a second, independent data feed that it can cross-reference against what you self-report. A mismatch between the platform’s gross figure and your Modelo 210 net figure is not evidence of evasion on its own, since EU and EEA resident landlords can deduct expenses, but it is the kind of discrepancy that triggers the risk factors behind an AEAT inspection.

What data does the platform send to AEAT about your rentals?

The platform operator, not you, files the report. Under Real Decreto 117/2024, de 30 de enero (BOE-A-2024-1771), which develops the due diligence rules, and Orden HAC/72/2024, de 1 de febrero (BOE-A-2024-2092), which approves the forms, the platform must report the following for each reportable seller who carried out a relevant activity during the year.

For every seller, whether an individual or a company, the platform reports the identifying information it collected through its due diligence procedures: name and address, tax identification number with the issuing Member State, VAT number where applicable, and, for individuals, date of birth. It also reports the financial account identifier (the IBAN) where the consideration was paid, each Member State in which the seller is resident, the total consideration paid or credited per quarter, the number of relevant activities per quarter, and any commissions, fees, commissions, taxes or similar amounts withheld or collected by the platform.

For property rentals specifically, the platform must additionally report the address of each property, the cadastral reference number (referencia catastral) or its equivalent in other jurisdictions, the number of days each property was rented during the period, and the property type. This is confirmed by the AEAT’s own FAQ page for sellers, last updated 9 June 2026.

Data field	What the platform reports	What you file on Modelo 210
Gross rental income	Total consideration paid or credited, per quarter	Net income after deductible expenses (EU/EEA residents)
Property address	Full address of each listed property	Not filed (Modelo 210 is per taxpayer, not per property)
Cadastral reference	Referencia catastral or equivalent	Not filed
Days rented	Number of days each property was rented	Not filed
Bank account	IBAN where payments were received	Not filed
Commissions	Fees and taxes withheld by the platform	Claimed as a deductible expense
Seller identity	Name, TIN, VAT number, residency Member State	NIE and fiscal residence

The table shows the structural mismatch. The platform reports gross income and the bank account that received it, while your Modelo 210 reports net income after deductions. AEAT can see both sides and reconcile them.

Which Spanish tax forms implement DAC7 (and which do not)?

The DAC7 platform reporting system in Spain uses two forms, both approved by Orden HAC/72/2024 (BOE-A-2024-2092):

• Modelo 040 is the census declaration of registration, modification and deregistration in the registry of platform operators. A platform files this when it starts operating in Spain, when its details change, or when it ceases activity.
• Modelo 238 is the annual informative declaration for the communication of information by platform operators. This is the form that carries the seller-level data: income, property addresses, bank accounts, days rented.

A common confusion, reinforced by much of the online commentary, is that Modelo 172, 173 and 721 are DAC7 forms. They are not. Modelo 172 is an annual informative declaration on virtual currency balances held by exchanges on behalf of third parties. Modelo 173 is an informative declaration on operations with virtual currencies. Modelo 721 is a declaration on virtual currencies located abroad. All three are crypto-asset reporting forms approved under the broader transparency framework introduced by Ley 13/2023 and subsequent orders (notably Orden HFP/886/2023 and Orden HFP/887/2023), and they have nothing to do with platform operators reporting landlord income. If you read that DAC7 means filing Modelo 172, 173 or 721 as a landlord, that source is conflating two separate reporting regimes.

Who is a reportable seller and who is excluded?

DAC7 defines a reportable seller as any seller who has carried out a relevant activity through a platform during the reporting period. Relevant activities, as listed by the AEAT FAQ, are the sale of goods, the provision of personal services, the leasing or temporary transfer of use of immovable property (residential and commercial, plus parking spaces), and the leasing of any mode of transport. For a short-let landlord, the relevant activity is the temporary transfer of use of immovable property.

The directive carves out certain excluded sellers, and these exclusions matter because they determine whether the platform reports your data at all:

Exclusion category	Threshold	Applies to short-let landlords?
State entities	Any governmental body	No
Listed-company group entities	Share capital traded on a recognised stock exchange	No (unless you are a listed hotel group)
High-volume property rental	More than 2,000 rentals of a single marketed property in the reporting period	No (this is designed for hotel chains and large tour operators)
Casual goods seller	Fewer than 30 sales AND total consideration under EUR 2,000	No (this is for goods, not property rentals)

The property-rental exclusion of more than 2,000 rentals per property per year is the one that catches attention, but it is calibrated for volume operators. A landlord renting out a two-bedroom apartment in Nueva Andalucia or a holiday home in Estepona for 30, 60 or even 150 nights a year is a reportable seller. The platform will collect your details, report your income and list your property.

How does the platform get your information?

The platform operator is legally required to apply due diligence procedures. These include identifying the seller, collecting the required information, verifying it, determining the seller’s Member State of residence and, for property rentals, collecting information on each rented property. The seller has a corresponding obligation to provide the information the platform requests.

If a seller does not provide the required information, the platform must send two reminders. If 60 calendar days pass from the initial request without the information being supplied, the platform must either close the seller’s account and prevent re-registration, or withhold payment of the consideration until the seller complies. This is set out in section 5 of Disposicion Adicional 25 of the Ley General Tributaria.

The platform must also inform each reportable natural-person seller that the information will be provided to the tax authority and transferred to the seller’s Member State of residence, with sufficient advance notice for the seller to exercise data protection rights. This is a notification, not a consent request: the reporting obligation is mandatory.

What happens when AEAT cross-references platform data with your Modelo 210?

AEAT receives the Modelo 238 data and shares it with the tax authority of the Member State in which the seller is resident and, for property rentals, with the authority of the State in which the property is located. For a non-resident landlord renting Spanish property, AEAT is both the recipient and the cross-referencing authority.

The cross-reference is straightforward in concept. The platform reports your gross rental income. Your Modelo 210, filed quarterly within the first 20 days of April, July, October and January, reports your net rental income. For EU, Iceland and Norway residents, the 19 per cent IRNR rate applies and deductible expenses can be offset against gross rent. For residents of the rest of the world, the 24 per cent rate applies on gross income with no deductions. If the platform’s gross figure and your Modelo 210 net figure diverge in a way that cannot be explained by documented expenses, the file becomes a candidate for review. Our Modelo 216 withholding guide explains how the payer-side withholding system works alongside Modelo 210.

The Andalusia short-let rules add a further layer. Since the Decreto-ley of February 2025, tourist lets require VFT registration and, where a community of owners exists, a 60 per cent community approval. A platform reporting your rental activity to AEAT also surfaces whether you are letting legally under the VFT short-let rules and the short-let rental tax compliance regime.

What are the platform’s obligations and penalties?

The platform operator bears the primary compliance burden. Under Disposicion Adicional 25 of the Ley General Tributaria, sections 2, 3 and 4 establish the infringement and sanction regime for non-compliance with the registration, due diligence and reporting obligations. A platform that fails to register, fails to apply due diligence, or fails to file Modelo 238 faces penalties under the General Tax Law. Non-EU platform operators (those without tax residence in the EU) must register in one EU Member State, and section 6 allows AEAT to deregister a non-compliant operator from the census after two formal demands.

The platform must retain all documentary evidence, records and information used in the due diligence procedures for 10 years following the end of the reference period, and make it available to the tax authority on request.

What should a non-resident short-let landlord do?

The practical steps are simple, even if the legal machinery behind them is not:

1. Declare what the platform reports. Your Modelo 210 quarterly filings should reflect the gross income the platform will report, minus your documented deductible expenses if you are an EU, Iceland or Norway resident. Keep invoices and receipts for every expense you claim.
2. Respond to the platform’s information requests. When Airbnb, Booking.com or Vrbo asks for your tax identification number, address and property details, provide them. If you do not, the platform is legally required to close your account or withhold your payouts after 60 days and two reminders.
3. Keep your cadastral reference handy. The platform reports the referencia catastral of each property. You can find it on your IBI receipt or on the Catastro Sede Electronica. If the platform cannot obtain it, it will report the address and property type, but providing the reference speeds up AEAT’s reconciliation.
4. Expect cross-referencing, not a new tax. DAC7 does not create a new tax liability. It gives AEAT the data to check that what you file matches what the platform paid you. The risk is not the reporting itself but the gap between the two figures.

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.