Modelo 720: Thresholds, Deadline and Rules (2026)

Modelo 720 is Spain’s annual declaration of foreign assets, due by March 31 once one asset category passes 50,000 euros. Spanish tax residents, individuals and entities, file Modelo 720 with the Agencia Tributaria under Real Decreto 1065/2007 once foreign bank accounts, securities or real estate pass 50,000 euros in one category; the annual window runs January 1 to March 31. This guide sets out who has to file, what counts toward the threshold in each of the three asset categories, and what changed in 2022 when the EU’s top court struck down the original penalty regime. It closes with what filing help costs and how to start your filing with a Spain-qualified tax advisor.

What is Modelo 720?

Spanish tax residents, individuals and entities, file Modelo 720 with the Agencia Tributaria under Real Decreto 1065/2007 once foreign bank accounts, securities or real estate pass 50,000 euros in one category; the annual window runs January 1 to March 31.

Modelo 720 is an informative return. It charges no tax on its own. Article 42 bis of Real Decreto 1065/2007 requires residents who hold a foreign account, act as its representative or authorized signatory, or are its beneficial owner, to declare it once the category crosses the threshold. Articles 42 ter and 54 bis of the same regulation set the equivalent obligation for the other two categories: securities, insurance policies and annuities, and real estate.

The three categories are assessed separately from one another. A resident with 80,000 euros in foreign bank accounts and 20,000 euros in foreign securities files only for the accounts category, because each category’s own threshold is what triggers that category’s own filing duty.

Who has to file Modelo 720?

Spanish tax residency is what triggers the obligation. Real Decreto 1065/2007 states that residents, both individuals and entities, must file when they hold a foreign account, act as its representative or authorized signatory, are its beneficiary, hold disposal powers over it, or are its beneficial owner.

That reach extends past sole ownership. A joint holder, an authorized signatory who never deposited a euro, and a beneficial owner who holds an asset through a nominee all count as someone the regulation asks to report, once the category they sit in crosses 50,000 euros.

The three categories run on the same threshold structure, each assessed on its own:

• Foreign bank accounts, under article 42 bis, where the 31 December balance or the average balance for the last quarter of the year, taken jointly across every account in the category, exceeds 50,000 euros.
• Securities, insurance policies and annuities held abroad, under article 42 ter of the same regulation.
• Real estate located abroad, under article 54 bis of the same regulation.

Crossing 50,000 euros in any one of those three categories creates the filing obligation for that category alone. A resident whose only foreign asset is a single category under the threshold has no Modelo 720 obligation at all.

What counts toward the 50,000-euro threshold in each category?

Each category’s threshold is tested jointly, across every asset the filer holds within it, not asset by asset. For the accounts category, Real Decreto 1065/2007 runs two separate tests: the balances at 31 December, and the average balances for the last quarter of the year. If either joint test exceeds 50,000 euros, every account in the category has to be reported, not only the accounts that pushed the total over the line.

The table below sets out the supported threshold test for each category and identifies where no valuation detail is stated.

Have the advisor handling your case confirm the valuation date and method for a securities or real-estate category before a return is due, since the wrong date can move a case across the threshold line either way.

Check whether you need to file Modelo 720

Modelo 720 tests three categories against one threshold structure, applied to the filer’s own numbers. A resident with foreign bank accounts, securities, insurance, annuities or real estate needs to check each category separately against the 50,000-euro line. The joint test for that category decides it, aggregated across every asset the category holds.

That check is easy to get wrong in a case with several accounts, a mixed portfolio, or an asset held jointly with someone else, because the aggregation and the beneficial-ownership rules both change what counts.

When is the Modelo 720 deadline?

You have from January 1 to March 31 of the year following the year the information concerns. Real Decreto 1065/2007 fixes that window for the informative return, and it repeats across each of the three asset categories.

The reference date sits inside that same year. A filer reporting foreign bank accounts, for example, works from the balances at 31 December of the previous year, or the average balance for that year’s last quarter, whichever test the category needs.

Miss the window and the return is still owed. A filer who realises late that a category crossed the threshold should confirm the late-filing route promptly. Waiting for the following year’s window does not settle a return already due.

Do you have to file Modelo 720 every year?

Not simply because a new year has started. Once a category has been declared, Real Decreto 1065/2007 requires another return when the joint value for that category rises by more than 20,000 euros compared with the figures that determined the last return filed.

A category that stays roughly level has not met the increase trigger. For example, an account category moving from 60,000 to 65,000 euros has not crossed the 20,000-euro increase. The cessation and disposal triggers below must still be checked separately.

Separate cessation and disposal triggers also apply. For foreign accounts, a later return is required when a previously reported holder, representative, authorised person, beneficiary, person with disposal power or beneficial owner ceases to have that status. For securities, rights, shares and units, a later return is required when the previously reported holding ends. The same applies when ownership of previously reported foreign real estate or a right over it ends. These triggers apply independently of the 20,000-euro increase test.

What happens if you don’t file, or file late?

Modelo 720 still has to be filed. The Court of Justice of the European Union struck down three specific consequences of non-compliance in Case C-788/19 on 27 January 2022, and it left the reporting obligation itself standing.

The Court found Spain had breached the free movement of capital in three ways. First, treating an undeclared foreign asset as an unjustified capital gain with no possibility, in practice, of the ordinary limitation period ever applying, though the presumption of an unjustified gain was not itself found disproportionate. Second, a proportional fine of 150% of the tax calculated on the undeclared assets. Third, flat-rate fines of 5,000 euros per missing or incorrect data item, with a 10,000-euro minimum, and 100 euros per item declared late, with a 1,500-euro minimum, both uncapped in total.

Ley 5/2022 replaced the struck-down figures with the general penalty regime in articles 198 and 199 of Ley 58/2003, the ordinary rules for a late or incorrect informative return. No Modelo 720-specific scale remains in force. The Agencia Tributaria confirms that the general penalties apply independently to each of the three reporting obligations. Confirm the amount applicable to the particular infringement before filing.

Is Modelo 720 the same as the US FBAR?

No. Modelo 720 is a Spanish filing made to the Agencia Tributaria by Spanish tax residents once a category passes 50,000 euros. The FBAR, FinCEN Form 114, is a separate US Treasury filing.

FinCEN’s own instructions require a US person with a financial interest in, or signature authority over, foreign financial accounts to file once those accounts aggregate over 10,000 dollars at any time in the calendar year, a lower and differently denominated threshold than Modelo 720’s. FinCEN’s definition of a reportable account covers securities, brokerage, savings and deposit accounts, plus a cash-value insurance policy or annuity, which lines up closely with Modelo 720’s own second category.

The FBAR and Modelo 720 differ in agency, currency and threshold. A taxpayer who is a US person and a Spanish tax resident at the same time can owe both returns, each assessed on its own numbers and its own deadline. The FBAR and Modelo 720 overlap for US taxpayers covers the detail of holding both obligations at once.

What is excluded from Modelo 720?

Two exclusions are addressed here. First, a category that stays under 50,000 euros carries no filing duty for that category, even when a different category the same filer holds is over the line, because Real Decreto 1065/2007 sets each of the three obligations independently.

Second, cryptocurrency held abroad is not reported on Modelo 720 at all. The Agencia Tributaria states plainly that virtual currencies are not covered by this return. A separate informative return, Modelo 721, exists for foreign-held virtual currency. Orden HFP/886/2023 states that it first applies to the 2023 tax year, with filing from 1 January to 31 March 2024.

Confirm any other claimed exclusion against the regulation before relying on it.

How do you file Modelo 720?

The return goes to the Agencia Tributaria. Confirm the current portal, credential and authorised-representative route before filing.

Self-filing requires the category definitions, joint-balance tests, increase trigger, and cessation or disposal triggers to be applied correctly. A mistake on an informative return can fall under the general LGT penalty regime described above.

A Spain tax adviser who already handles Modelo 720 filings can confirm the current portal requirements directly with AEAT before a return is due.

What does help with Modelo 720 filing cost?

Fees are set case by case, and you get a quote in writing before any work starts.

A single-category filing, one foreign account and nothing else, is generally a smaller task than a filing across all three categories, or one that also has to work out a joint holder’s share or a securities valuation date. A case with a re-filing question, a possible penalty exposure, or an overlap with the US FBAR adds work on top of the base filing.

Ask the specialist for a fixed quote once the categories involved are known.

Talk to a Spain tax specialist about your Modelo 720 filing

Advisors in Spain handles your Modelo 720 filing. The tax advisor handling your case confirms which categories apply to your own accounts, securities and property, and files Modelo 720 on that basis.