Modelo 720 Spain 2026: Foreign Asset Reporting Deadlines

Modelo 720 is Spain’s mandatory declaration of overseas assets for tax residents — a single form that has caused more anxiety among British and international expats than any other piece of Spanish paperwork. The good news for 2026: since the 2022 CJEU ruling (Court of Justice of the EU, Case C-788/19), the disproportionate penalties that used to terrify late filers have been struck down. The bad news: the filing obligation itself has not gone away. If you are a Spanish tax resident, you still file, every year between 1 January and 31 March.

Who Must File

Modelo 720 (Declaracion sobre bienes y derechos situados en el extranjero) is required by all Spanish tax residents — meaning anyone resident more than 183 days per year, or whose centre of economic activities is in Spain. Non-residents do not file. The filer assesses three categories of foreign assets independently: bank accounts abroad, securities and financial investments held abroad, and real estate located abroad. Each category has its own threshold and its own line on the form.

The 50,000 EUR Trigger Per Category

You must file Modelo 720 if you hold foreign assets worth over 50,000 EUR in any of the three categories — not as a combined total, but per category. A Spanish tax resident with 40,000 EUR in a UK savings account, 45,000 EUR in a US brokerage, and a 200,000 EUR flat in France is over the threshold only on the real estate category and files only that line. Once the 50,000 EUR threshold is crossed in a category, the filer reports all assets in that category, not just the slice above the trigger.

The Annual Filing Window: 1 January to 31 March

The filing window opens 1 January and closes 31 March each year, covering the prior calendar year’s positions. The form is filed electronically through the Agencia Tributaria portal using a digital certificate or Cl@ve PIN. After the first filing, you only need to refile if (a) any reportable category increases by more than 20,000 EUR compared to the last filed value, or (b) you cease to hold a previously reported asset. This makes Modelo 720 lighter in steady years and heavier when you sell, transfer, or accumulate.

The 2022 CJEU Ruling — What Actually Changed

For nearly a decade, late or incomplete Modelo 720 filings carried penalties that could exceed the value of the assets themselves. The Court of Justice of the European Union ruled these disproportionate (Case C-788/19, January 2022), and Spain has since adjusted the regime. What has NOT changed: the obligation to file remains, late filing still triggers standard surcharges and interest, and unreported foreign income can still be reassessed under general tax rules. The CJEU ruling fixed the penalty calibration; it did not eliminate the duty.

Frequently Asked Questions

Do I file Modelo 720 if my UK pension is below 50,000 EUR?

No, not on the basis of the pension alone. Pension funds typically count as foreign securities/investments. If the total of foreign securities does not exceed 50,000 EUR you do not file that category. Recheck each year as values move.

What about cryptocurrencies held abroad?

Spain has introduced a parallel declaration (Modelo 721) for cryptocurrency held in foreign exchanges — separate from Modelo 720. The 50,000 EUR threshold applies. Do not conflate the two forms.

If my spouse and I hold a joint UK account, who files?

Each tax resident files on their share. If both spouses are Spanish tax residents and the account is jointly held 50/50, each files their 50% share against their personal threshold. If the account is held 100% by one spouse, only that spouse files.

Reviewed by: Maria Luisa de Castro, Expert in Off-plan Property Investment, CostaLuz Lawyers. Last updated: May 2026.