Modelo 720: the dreaded reporting obligation for expatriates in Spain
The Modelo 720 is the informative declaration that all Spanish tax residents must file when their assets located outside Spain exceed 50 000 € in one of three categories: bank accounts, securities and life insurance, real estate. No tax arises from it - but the obligation is controlled, and it is the one that French leaders installed in Spain most often forget.
The Modelo 720 is a mandatory information declaration for any tax resident in Spain with property or rights located abroad. Although this is not a tax liability, failure to do so may result in penalties.
Who is affected and what are the thresholds?
You must present the Modelo 720 if the total value of your goods abroad exceeds 50 000 € in one of these three distinct categories:
- Bank accounts: Current accounts, A savings accounts, LDD accounts, N26 or Revolut accounts (if the IBAN is not Spanish).
- Values, rights, insurance and income: Stocks, bonds, investment portfolios, and especially French life insurance contracts.
- Real estate: Houses, apartments or land located outside Spain.
Important: The threshold of €50,000 is assessed by category. If you have €40,000 in bank accounts and €40,000 in life insurance, you are not subject to the reporting obligation.
Deadlines and sanctions in 2026
The declaration must be made electronically to the Agencia Tributaria (AEAT) between January 1 and March 31 of the year following the financial year concerned (e.g. before March 31, 2026 for the financial year 2025).
Following a condemnation by the Court of Justice of the European Union (CJEU) deeming the initial sanctions "disproportionate", Spain had to review its penalty regime. The extremely heavy fixed fixed fines have been abolished, and the general regime of tax sanctions now applies. However, the reporting obligation remains strictly in force.
How to declare the Modelo 720?
The declaration is made exclusively online, on the Agencia Tributaria website, with a digital certificate or Cl@ve identification. The process is divided into four steps:
- Gather the supporting documents : bank statements as of December 31 and average balances for the last quarter, surrender values of life insurance contracts, acquisition value of real estate.
- Identify the categories concerned : the threshold of €50,000 is assessed separately for accounts, securities and real estate.
- Fill out the form : each property is declared individually, with its identifiers (IBAN, contract number, cadastral reference) and its valuation.
- Submit before March 31 : no extension is planned, and the paper declaration does not exist.
Once the first declaration has been made, you only have to re-declare a category if its value increases by more than 20 000 € in relation to the last declaration filed, or if you cease to be the holder of declared property.
The most common errors
Forget neobanks. An N26 (German IBAN) or Revolut (Lithuanian or Irish IBAN) account is a foreign account within the meaning of Modelo 720, even if the application is in Spanish and the card used in Barcelona.
Ignore French life insurance. This is the most forgotten category among French expatriates: life insurance contracts fall into the “values, rights and insurance” category, for their surrender value as of December 31.
Believing that goods in France are outside the scope. Once you are a Spanish tax resident, your Parisian apartment, your French accounts and your PEA are assets abroad — from the Spanish point of view.
Confusing declaration and taxation. The Modelo 720 does not generate any taxes itself; some conclude that it is optional. The obligation is purely declarative, but it is monitored, and non-compliance remains punishable.
This reporting obligation primarily concerns managers who settle in Spain with a French structure : accounts, portfolios and assets held in France all fall within the scope of the Modelo 720 once Spanish tax residence has been acquired. To situate this declaration in all of your obligations, our France-Spain tax guide goes around the topic.
Frequently asked questions about the Modelo 720
Who must declare the Modelo 720 in Spain?
Any tax resident in Spain with property or rights located abroad whose total value exceeds €50,000 in one of the three categories (bank accounts, securities/life insurance, real estate). The threshold is assessed by distinct category.
What is the deadline for filing the Modelo 720?
The declaration must be made electronically to the Agencia Tributaria (AEAT) between January 1 and March 31 of the year following the financial year concerned (for example, before March 31, 2026 for the 2025 financial year).
What are the Modelo 720 sanctions in 2026?
Following the conviction by the CJEU deeming the initial sanctions “disproportionate”, the extremely heavy fixed fixed fines were removed. The general regime of tax sanctions now applies, but the reporting obligation remains strictly in force.
Do you have to redeposit the Modelo 720 every year?
No. Once the first declaration has been filed, a category only needs to be re-declared if its value increases by more than €20,000 compared to the last declaration, or if you cease to be the holder of declared property.
Is the Modelo 720 due under the Beckham law?
No for the beneficiary of the impatriate regime (consulta vinculante DGT V0092/2014), who is not taxed on his worldwide income. The ordinary tax resident spouse remains bound by the obligation, and the exemption ceases upon exit from the regime.
A Franco-Spanish tax question?
Accounts, life insurance, real estate remaining in France: a 30-minute diagnosis is enough to frame your reporting scope and secure your calendar.
Request a diagnosisOur Fractional CFOs in Barcelona cover this topic every week.
Sources and references
- Model 720 — Informative declaration of the properties and conditions located in the extra parts — Agencia Tributaria (AEAT), official procedure.
- Judgment C-788/19, European Commission v Kingdom of Spain — the Modelo 720 sanctions regime deemed contrary to Union law — Court of Justice of the European Union, January 27, 2022.
Let's talk about your project
Tell us your priority, situation and timeline. The first conversation helps define the scope and next steps.