Modelo 720: complete guide for 2026

Modelo 720 remains one of the most feared and complex obligations for taxpayers with assets outside Spain. We break down the keys to the 2026 campaign, the latest on cryptocurrencies and how to avoid penalties.

What exactly is Modelo 720?

Modelo 720 is an informational return — it does not involve any direct tax payment — on assets and rights located abroad. Its purpose is tax control, allowing the Spanish Tax Agency (AEAT) to know the overall wealth of its tax residents.

Despite its informational nature, it has historically been controversial because of its penalty regime, which was partially struck down by the European courts in 2022. However, the obligation to declare remains, and the penalties, although now more moderate, are still significant.

The 50,000-euro threshold

The golden rule of Modelo 720 is the 50,000-euro limit. You are required to file this return if you are the holder (or authorised person, representative, beneficiary, etc.) of assets abroad that exceed this combined value in any of the following three independent categories:

1. Accounts at financial institutions: Current accounts, savings accounts, term deposits, etc.
2. Securities and rights: Shares, investment funds, life or disability insurance, and life or temporary annuities.
3. Real estate: And rights over real estate located abroad.

Important: The categories are not added together. You can have 40,000 euros in accounts and 40,000 euros in shares (80,000 euros in total) and not be required to declare, because no single category exceeds 50,000 euros.

The big change: cryptocurrencies and Modelo 721

Until recently, there was some confusion as to whether cryptocurrencies should be included in Modelo 720. The definitive answer came with the creation of a specific return: Modelo 721.

• What is declared? Virtual currencies held abroad (on non-resident exchanges or custodians).
• When? If the combined balance as at 31 December exceeds 50,000 euros.
• And cold wallets? If you hold the private keys on a physical device (Ledger, Trezor) that is with you in Spain, they are technically not held abroad and are not declared in Modelo 721 (although they may be subject to Wealth Tax where applicable).

Deadlines and the consequences of errors

The filing period for the 2026 campaign (in respect of 2025 assets) is strict: from 1 January to 31 March 2026.

What happens if I file late?

Filing the return late without a prior request from the tax authorities carries penalties, but far smaller ones than if the Tax Agency requests it from you. The minimum penalty is usually 150 euros per group of data.

The danger of "unjustified capital gains"

The greatest risk of Modelo 720 is not the fine for failing to file, but the non-statute-barred nature (now qualified by the courts) of undeclared assets. If the Tax Agency discovers hidden assets, it could treat them as an unjustified capital gain and attribute them to the personal income tax (IRPF) of the oldest non-statute-barred year, with an additional penalty.

Checklist for a safe declaration

At JAIZME we recommend following these steps to avoid nasty surprises:

• Gather official documentation: Don't rely on your own notes. Ask your foreign banks for certificates of balances as at 31 December and the average balances of the last quarter.
• Check the exchange rate: If you hold assets in another currency, make sure to use the official exchange rate published by the ECB as at 31 December.
• Watch out for joint holders: If an account of 80,000 euros has two holders, both must file Modelo 720 reporting the total balance and their percentage of ownership (even if their share is only 40,000 euros, the obligation arises from the total balance of the account).
• Keep everything for 4 years: The general limitation period.

"Modelo 720 leaves no room for error. A small mistake in an account number or a date can trigger an audit procedure."