Spain is one of the few countries where a tax resident must file a separate annual information return on assets held abroad. Modelo 720 creates no tax by itself — it is pure compliance — yet for a decade it sat at the centre of Europe's loudest tax dispute: draconian penalties, a CJEU ruling and the 2022 reform. Data as of July 2026.
Who files and what is reported
The obligation applies to Spanish tax residents under the general IRPF regime. The threshold is €50,000 — assessed not across all assets combined but per each of three independent blocks (AEAT):
| Block | Covers | Threshold |
|---|---|---|
| 1. Accounts | Accounts with foreign banks | €50,000 |
| 2. Securities and rights | Securities, shares, rights, insurance policies, annuities | €50,000 |
| 3. Real estate | Foreign real estate and rights over it | €50,000 |
The filing window runs from January 1 to March 31 of the year following the reporting year: for 2025, the deadline was March 31, 2026. Electronic filing only. A repeat filing is required only when a block has grown by more than €20,000 since the last return filed, or when previously declared positions were closed or disposed of (AEAT FAQ).
Crypto assets sit outside Modelo 720: since reporting year 2023 they are declared on a separate Modelo 721 — same €50,000 threshold, same March 31 deadline.
Penalties: before and after the CJEU
The old regime was punitive: a 150% surcharge on the assessed tax, fixed €5,000 fines per undisclosed data item, and imprescriptibilidad — undeclared assets could be imputed as income with no statute of limitations. On 27 January 2022 the Court of Justice of the EU held in C-788/19 that this construction breached the free movement of capital.
Ley 5/2022 of 9 March 2022 normalised the regime: the special fines and imprescriptibilidad were repealed, and undeclared gains can now be assessed only within the general four-year limitation period of the LGT. Penalties paid under the old regime were recovered through revocación.
What applies now is the general penalty regime of articles 198–199 LGT. The figures below are indicative — exact amounts depend on how the breach is qualified; check the AEAT FAQ.
| Scenario | Penalty |
|---|---|
| Old regime (repealed 2022) | 150% surcharge + €5,000 per item, no limitation period |
| Late filing before any AEAT request | ~€10 per data item, min €150, max €10,000 per block |
| After a request / inaccurate data | €20 per item, min €300, max €20,000 |
Where practice stands in 2026
The CJEU struck down the sanctions, not the declaration. AEAT actively matches returns against CRS feeds: a resident's foreign account is visible to the tax office with or without a 720. A missed filing today means a moderate fine, not a disaster — the standard move is voluntary late filing before AEAT issues a formal request.
A separate angle is the Beckham regime. Its beneficiaries are formally residents but are taxed under IRNR rules, so residents' information duties do not reach them: no 720, no 721, no worldwide wealth tax return. The obligation switches on from the first year after the regime ends, together with worldwide IRPF — which is why the exit from the regime deserves planning in advance.
FAQ
Is Modelo 720 filed every year?
No. A new filing is due only when a block has grown by more than €20,000 since the last return, or when previously declared positions were closed or sold.
Is the €50,000 threshold assessed across all assets combined?
No — per block. A €30,000 account plus a €40,000 property trigger nothing; assets aggregate only inside each block.
What happens if I file late now?
General LGT fines with €150–300 minimums, not the old 150% surcharge — plus ordinary assessment of any undeclared income within the four-year limitation period.
Do Beckham regime holders file Modelo 720?
No — not for the entire life of the regime. The duty starts with the first year on the general IRPF after the regime ends.
Where does a foreign brokerage account go?
Securities and rights form the second block, assessed separately from the bank accounts block.