Modelo 720: Foreign Asset Declaration in Spain (2026)

What Is Modelo 720 and Who Must File?

Modelo 720 is Spain's annual informational return for foreign-held assets. It is not a tax in itself — you do not pay anything by filing it. What you are doing is telling Hacienda that, as a Spanish tax resident, you hold assets outside Spain above certain thresholds. The form was created in 2012 to fight tax evasion, and for a decade it carried some of the most aggressive penalties in any European tax system. Those penalties were struck down by the Court of Justice of the European Union in 2022, but the obligation to file remains very much alive.

You must file Modelo 720 if you are a Spanish tax resident in the reporting year and you hold foreign assets that cross any of the three thresholds explained below. If you are unsure whether you are a Spanish tax resident in the first place, start with our guide on Spanish tax residency — your filing obligation depends entirely on that answer.

Non-residents do not file Modelo 720. Neither do companies in most cases (they have other reporting). The obligation targets individuals and certain collective entities. If you became resident part-way through the year, you generally still file for that full calendar year, because Spanish tax residency is determined on a year-by-year basis and you are treated as resident for the entire fiscal year.

The Three Reporting Categories and the €50,000 Test

Modelo 720 splits your foreign wealth into three independent blocks. Each block has its own €50,000 threshold, and the test is applied per block — not on the sum. This is the single most misunderstood mechanic of the form:

Block 1 — Bank accounts abroad: current accounts, savings accounts, time deposits, and similar products held with non-Spanish credit institutions. You also report accounts where you are only an authorised signatory or beneficial owner, not just the holder.
Block 2 — Securities, rights, insurance, and foreign-held income:shares, investment fund units, bonds, life insurance policies with surrender value, annuities, and participations in foreign collective investment vehicles.
Block 3 — Real estate abroad: any property you own outside Spain, plus timeshares and similar rights over property.

You owe a filing in a given block only if the aggregated value of the assets in that block exceeded €50,000 on 31 December of the reporting year, or the average balance in the last quarter (for bank accounts). If your bank accounts abroad total €48,000 and your foreign shares total €200,000, you do not file Block 1 — you only file Block 2. The blocks are independent, and there is no aggregation across them.

For jointly owned assets, you report the full value of the asset and identify your ownership percentage. So if you and a partner share a €400,000 property abroad 50/50, you each file a Modelo 720 for that property at its full value and declare your 50% interest. This often surprises expat couples who assume they only report their share.

Modelo 721: Crypto Assets Held Abroad

From the 2023 tax year onward (first filed in early 2024), Spain added a separate informational form for cryptocurrency held abroad: Modelo 721. It sits alongside Modelo 720 but is a different return, with its own form and its own threshold.

Modelo 721 applies to virtual currencies held abroad — typically balances on non-Spanish exchanges (Coinbase, Kraken, Binance international entities) or in self-custody wallets where the entity providing the service is non-resident. You file if the aggregated value of your foreign-held crypto exceeded €50,000 on 31 December of the reporting year.

Note two subtleties. First, self-custody is grey: Hacienda has generally taken the view that if you hold the keys directly and no third-party service is provided from abroad, the reporting obligation is less clear, and other forms (like Modelo 172 for Spanish-resident custodians) may apply instead. Second, crypto held with a Spanish-licensed exchange generally does not go on Modelo 721 because it is already reported domestically. When in doubt, document the custodian's legal seat.

When Do You Have to File Again After the First Year?

After the year you first file a given block, you only have to re-file that block in future years if one of these conditions is met:

The aggregated value in that block grew by more than €20,000 compared to your last declared value.
You ceased to hold any asset you previously declared (sold, closed, transferred) — you must report the disposal.
You became a new owner or signatory of any asset in that block that, combined with the existing ones, keeps you above €50,000.

This means many expats file Modelo 720 once and then do not file it again for several years — until a block crosses the €20,000 increment or they dispose of an asset. It is critical to keep a personal spreadsheet of the last declared values per asset, because Hacienda will use those as the baseline when assessing whether a re-filing was required.

Deadline, Filing Channel, and What You Need to Prepare

The deadline for Modelo 720 and Modelo 721 is 31 March of the year following the reporting year. For the 2025 fiscal year, you file between 1 January and 31 March 2026. Filing is done exclusively online through the Agencia Tributaria e-office. You need a digital certificate, an electronic DNI, or a Cl@ve PIN to authenticate.

For each asset you declare, you typically need:

The type of asset and a proper sub-key code (the form uses internal keys).
The country code (ISO).
The identifying number (IBAN, ISIN, cadastral reference, wallet identifier).
The institution name and address (for bank/securities).
The acquisition date and acquisition value.
The 31 December balance and, for bank accounts, the last-quarter average balance.
Your ownership percentage if joint.

Gathering this information is the hard part. If you have accounts spread across multiple countries, broker platforms, and real estate, plan to start in January — not March — because year-end statements from foreign banks and brokers often arrive in mid-February.

The Post-2022 Penalty Regime: What Actually Changed

Until 2022, Modelo 720 had three extraordinary penalties that made it uniquely feared among European tax forms: (1) a €5,000-per-data-point fine with a €10,000 minimum for late or incorrect filings, (2) treatment of undeclared foreign assets as unjustified capital gains taxable at the highest marginal IRPF rate regardless of when they were acquired, and (3) a 150% surcharge on top of that tax bill. Combined, the regime could produce penalties that exceeded the value of the undeclared asset itself.

In Case C-788/19, decided on 27 January 2022, the Court of Justice of the European Union ruled that Spain's Modelo 720 penalty regime was incompatible with the free movement of capital and was disproportionate. Spain reformed the regime through Law 5/2022, in force from March 2022. The current situation is far more reasonable:

Formal penalties for late or incomplete filings now fall under the General Tax Law, typically €20 per data point with a €300 minimum and €20,000 maximum — an order of magnitude below the old regime.
The unjustified capital gains rule is gone: undeclared foreign assets are no longer automatically treated as undeclared income of the most recent non-prescribed year.
The 150% surcharge is gone.
Standard statute-of-limitations rules apply again, so undeclared income can only be reassessed for years still within the general four-year window.

That said, the obligation to file is still active, and failing to file still carries real fines. Some taxpayers who were sanctioned under the old regime have been able to reclaim penalties through administrative routes; if you paid a pre-2022 sanction, consult a specialist.

Common Mistakes That Still Trigger Fines

Treating the €50,000 as aggregated. The threshold is per block, not on total foreign assets.
Forgetting signatory-only accounts. You report accounts where you are the authorised signatory even if you are not the legal owner — common in expats with parental or business accounts.
Omitting dormant accounts. Accounts you rarely use still count if you are the holder or signatory and balances cross thresholds.
Reporting your share instead of full value. For jointly held assets you report the full asset value and then separately state your ownership percentage.
Not re-filing after a €20,000 increase. Many expats file once and assume they are done forever.
Forgetting life insurance with surrender value. Whole-life policies, unit-linked products, and similar insurance contracts held abroad sit in Block 2.
Mixing Modelo 720 and Modelo 721. Crypto held abroad goes on 721, not 720, even if the values are similar in shape.

Beckham Law, Non-Lucrative Visa, and Modelo 720

Your visa and tax regime directly change your Modelo 720 obligations.

If you are under the Beckham Law, you are taxed as a non-resident for most income despite physically living in Spain. Accordingly, Beckham Law beneficiaries are exempt from Modelo 720 during the years the regime applies (typically six). This is one of the most underrated benefits of the regime for expats with significant foreign assets. If you drop out of Beckham early or your six-year window ends, you move back into the standard Modelo 720 regime from that point forward.

If you are on the Non-Lucrative Visa, you are a full Spanish tax resident taxed on worldwide income and wealth. Modelo 720 applies in full. Retirees on NLV are in fact the single most common profile filing Modelo 720, because they typically have foreign pensions, brokerage accounts, and sometimes property in their home country.

How Modelo 720 Fits With Your Renta and Wealth Tax

Modelo 720 is informational, but it is closely cross-referenced with two other returns that you do pay tax on:

Your annual income tax return — see our expat Renta guide — includes worldwide dividends, interest, and capital gains, including those generated by the accounts and securities you declare on Modelo 720. Hacienda regularly compares dividend flows reported under CRS (the international information exchange standard) with what you declare on your Renta, using the Modelo 720 as a map.

The Wealth Tax and Solidarity Tax on Large Fortunes pick up your global net worth above regional thresholds. The assets you list on Modelo 720 feed directly into the Wealth Tax base if you cross those thresholds. Inconsistencies between the two returns are a classic audit trigger.

How to Prepare Your 720 Without a Gestoría

If you want to file Modelo 720 yourself, here is a realistic workflow that avoids the usual traps:

Inventory every foreign financial relationship. Bank accounts, broker accounts, pension accounts, life insurance policies, foreign employer equity plans, crypto exchange accounts. Include dormant ones.
Classify into blocks. Bank accounts (Block 1), securities and insurance (Block 2), real estate (Block 3). Crypto goes on a separate 721.
Pull 31 December values (and last-quarter average balances for bank accounts) from year-end statements.
Apply the threshold test per block. If a block is under €50,000, you do not file for that block.
Compare with last year's declared values if you have filed before. Check the €20,000 increment rule and any disposals.
File online via the Agencia Tributaria portal with a digital certificate or Cl@ve. Save the PDF confirmation and your data sheet.

Budget several hours the first year — gathering identifiers, IBANs, institution addresses, and acquisition values for every asset is tedious. Subsequent years are faster because your baseline already exists.

How Noburo Helps With Modelo 720

Noburo prepares your Modelo 720 and Modelo 721 alongside your Renta, reviewing your foreign asset schedule, applying the block thresholds, and cross-checking the values against the data you report on your income tax return and — where applicable — your Wealth Tax return. You receive a plain-English summary of every line, the exact numbers that will be submitted, and the step-by-step Cl@ve filing instructions so you stay in full control of what is sent in your name.

If you are considering becoming Spanish tax resident or you have just moved and are not sure when your first Modelo 720 is due, reach out before 31 December so we can plan the opening-position inventory properly.