Modelo 720 in 2026: what you actually need to declare

Modelo 720 has three separate categories, each with its own €50,000 threshold:

• Category 1 - Bank accounts. Current accounts, savings accounts, fixed-term deposits, in any foreign bank. Threshold tested on the value at 31 December OR the average of the final quarter, whichever is higher.
• Category 2 - Securities, rights, insurance, and annuities. Shares, funds, ETFs, UK ISAs, UK SIPPs (in some cases), life insurance with surrender value, annuities, certain crypto holdings. Threshold tested on year-end values.
• Category 3 - Real estate. Foreign-situs property, beneficial interests in property, time-shares. Threshold tested on acquisition cost.

If any single category exceeds €50,000 at year-end, the WHOLE category must be disclosed in full. The other categories are not required to be disclosed if they don't exceed €50,000.

Once you have filed Modelo 720 for a category, you only need to refile that category if the year-end value has INCREASED by €20,000 or more compared to the most recent declaration. Decreases do not trigger refiling.

You always need to refile if you have closed accounts, sold positions, or otherwise divested from any declared asset during the year (regardless of value change).

First-time filers in 2026 will declare based on 31 December 2026 values, with the filing window 1 January to 31 March 2027.

Particular UK asset treatments:

• UK ISAs - DECLARABLE as securities (Category 2). The ISA wrapper does not exist in Spanish law; Spain sees the underlying investments. Aggregate ISA values with other Category 2 assets to test the €50k threshold.
• UK SIPPs - GENERALLY NOT declarable in Category 2 if it's a pure pension wrapper that you cannot freely access (preservation age, no surrender value). Once you reach preservation age (typically 55, rising to 57 from 2028) it may become declarable. This is one of the most contested areas — get specialist advice.
• UK life insurance - declarable if it has a surrender value (whole of life, investment-linked). Term life with no surrender value is not declarable.
• UK property held in your own name - declarable in Category 3 at acquisition cost (not market value). Stamp duty paid is included in acquisition cost.
• Crypto on overseas exchanges - declarable in Category 2 since 2023. Spanish-exchange crypto holdings are declarable via Modelo 721 instead.

Before 2022, Modelo 720 penalties were notoriously brutal: a minimum penalty of 150% of the unpaid tax, treatment of undeclared assets as unjustified gains taxed at 47%, flat €5,000 fines per missing data point with no minimum.

The European Court of Justice ruled in January 2022 (Case C-788/19) that this regime violated EU law on free movement of capital. Spain has since reformed:

• Penalties for late filing are now proportionate to standard Spanish tax penalties (typically 20-50%)
• Undeclared assets are no longer automatically treated as unjustified gains
• The flat per-data-point fines are largely gone

The obligation remains. The penalty regime is now in line with other tax filing obligations. Late filing or non-filing still triggers regularisation, but the regime is no longer the financial death sentence it was pre-2022.

Holders of Beckham Law status are EXEMPT from Modelo 720 for the duration of the regime. This is one of the structural advantages of the regime — no foreign-asset reporting burden during the six years.

At regime exit, Modelo 720 obligation kicks in for the following year if your foreign assets exceed the thresholds at that point.