Modelo 720 and 721 in Spain: Who Files and By When (2026)

Modelo 720 is the informational return Spanish tax residents file for assets held abroad: bank accounts, securities and real estate. Modelo 721 does the same for crypto held by a foreign custodian, usually an exchange. You file when a category is worth more than 50,000 € on 31 December. The window is 1 January to 31 March of the following year. After that you only file again if the category grew by more than 20,000 € since your last return, or if you closed out an asset you had declared. Neither form creates any tax to pay: they are information only.

Below: who has to file, how to calculate the thresholds, the penalties that apply after the 2022 EU court ruling, and what to watch for with crypto exchanges.

Who has to file

The obligation applies to Spanish tax residents, both individuals and companies. Owners are not the only ones who file. So does anyone with power over an asset: co-owners, authorised signatories on an account, beneficiaries.

You are usually tax resident if you spend more than 183 days a year in Spain or your main economic interests are here. Non-residents do not file these forms.

One special case is the inbound workers regime (régimen de impatriados, the "Beckham law"). People taxed under it are generally understood to be exempt from Modelo 720. For Modelo 721 the official position is less clear, so ask your adviser.

What goes on Modelo 720 and 721

The key point: the 50,000 € threshold applies to each category separately. With 40,000 € in a foreign bank and 40,000 € of shares at a foreign broker, you do not file Modelo 720, because neither category is over the line. Within a category, though, you add up all your accounts or holdings, even if each one is below 50,000 €.

Since 2024, crypto has its own form, Modelo 721, and is not reported on Modelo 720.

Modelo 721: exchange or self-custody

Modelo 721 only covers crypto whose private keys a foreign entity holds on your behalf. In practice, that means exchanges and custodial services based outside Spain.

• Self-custody wallets (Ledger, Trezor, MetaMask or any wallet where you hold the keys) are not reported on 721. Nobody else holds the coins, so there is no "asset held abroad". This position is commonly cited from DGT ruling V2290-23.
• Spanish providers (companies registered in Spain) are outside 721 too. They report to the AEAT themselves through Modelo 172.
• Foreign exchanges are in scope. Check your terms to see which legal entity your account is actually with: big exchanges often use different companies for different countries.

For 721, the 50,000 € threshold is the combined market value of all your crypto with foreign custodians on 31 December.

Deadlines and re-filing

• Deadline: 1 January to 31 March of the year after the one you report. Tax year 2025 was due by 31 March 2026, and tax year 2026 is due by 31 March 2027. Filing is online only, through the AEAT Sede Electrónica with a digital certificate or Cl@ve.
• First filing: the first year a category goes above 50,000 €.
• Filing again: only when the category's value has increased by more than 20,000 € compared with your last filed return. You compare the category total, not each asset.
• Closing an asset: if you closed a declared account, sold the securities or coins, or stopped being their owner, that has to be reported for that year even without a 20,000 € increase.

Penalties: what changed after 2022

Modelo 720 used to carry some of the harshest penalties in the EU: at least 5,000 € per missing piece of data (minimum 10,000 €), a 150% fine on the tax, and a rule that treated undeclared assets as unreported income with no statute of limitations.

On 27 January 2022 the EU Court of Justice (case C-788/19) ruled that this regime was disproportionate and breached the free movement of capital. Spain repealed the special penalties with Ley 5/2022 (published in the BOE on 10 March 2022). The duty to file stayed.

Today, 720 and 721 fall under the general rules of the Ley General Tributaria (arts. 198 and 199):

The fines are far lower now, but skipping the return is still a bad idea. Undeclared assets make it easier for the AEAT to notice unpaid tax on the income from them, and data exchanges between countries (CRS, DAC8) make that ever more likely.

Worked example: do you need to file?

On 31 December 2025 you have:

• crypto on Bybit worth 38,000 € and on Binance worth 17,000 € (both foreign entities);
• 30,000 € of BTC on your own Ledger;
• shares and ETFs at a foreign broker worth 42,000 €;
• 12,000 € in a foreign bank account, with a Q4 average balance of 15,000 €.

The next year. On 31 December 2026 your exchange crypto is worth 71,000 €. That is up 16,000 €, below the 20,000 € trigger, so you do not file again. Had it been 76,000 € (up 21,000 €), you would file 721 by 31 March 2027.

Now suppose that during 2026 you moved everything from Bybit to your own wallet. The Bybit holding on your previous return no longer exists. Many advisers recommend filing 721 that year to report the closure. Confirm with your asesor.

Checklist before 31 March

1. List every foreign account, broker, exchange and property where you are owner, co-owner or authorised person.
2. For each bank account, note the 31 December balance and the Q4 average balance.
3. For securities and ETFs, take the 31 December market value from the broker statement.
4. For crypto, take the 31 December balance on each foreign exchange. Leave out self-custody wallets.
5. Check which legal entity runs each exchange and broker: Spain or elsewhere.
6. Add up each category and compare it with 50,000 €.
7. If you have filed before, compare with your last return: did a category grow by more than 20,000 €, or did you close anything?
8. Get your digital certificate or Cl@ve sorted early and file before 31 March.
9. Keep the 31 December statements: you will need them if you are ever audited.

How Signae helps

Signae has a "Foreign assets" view that calculates 31 December values from your connected sources and tells you whether you cross the threshold:

• Modelo 721: crypto on foreign exchanges (Bybit, Binance and others), broken down by exchange. Self-custody wallets are left out;
• Modelo 720: securities and cash at foreign brokers, shown as separate categories;
• reminders of the 50,000 € threshold, the +20,000 € rule and the 31 March deadline.

Signae does not see bank accounts outside connected brokers or any real estate, so check those yourself. It values crypto from your transaction history, so compare the figures with your exchange's 31 December statement. Signae also calculates tax on your sales: see crypto tax in Spain and stock and dividend tax in Spain. To get all your accounts in one place, read tracking a stock and crypto portfolio.

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