If you became a Spanish tax resident at any point and still hold assets abroad, there is a form that tracks them. It is called Modelo 720 — foreign asset declaration, and its filing window opened on January 1. The deadline is March 31. There are no extensions.

This is not a tax payment. It is an information return. Spain wants to know what you own outside its borders: bank accounts, investment portfolios, real estate, and life insurance policies. If the aggregate value of any category exceeds €50,000, you must report it. Every year. Electronically. Through the Agencia Tributaria — Spanish Tax Agency website.

The form has been around since 2012. What changed is how seriously Spain enforces it, and how little you can hide.

You must file Modelo 720 if you meet all three conditions:

1. You were a Spanish tax resident in 2025. This generally means you spent 183+ days in Spain, or your economic interests are centered here. If you filed a Spanish income tax return, you are almost certainly a tax resident. (If you are unsure, the 183-day rule is more nuanced than it sounds.)

2. You hold foreign assets exceeding €50,000 in any category. The categories are separate. You could have €40,000 in foreign bank accounts, and €200,000 in a UK pension, and only need to report the pension. The threshold applies per category, not in total.

The categories:

3. Something changed since your last filing. If you filed before and the value in any category increased by more than €20,000, you must file again. If nothing changed significantly, you can skip that year.

Forgetting investment accounts. That old Vanguard IRA. The UK ISA you stopped contributing to. The pension from a job you left in 2019. If it exists and exceeds €50,000, it needs to be on the form.

Using the wrong valuation date. You report values as of December 31, 2025. Not today. Not when you bought it. The year-end balance is what matters.

Missing the bank account average balance rule. For bank accounts, you report both the December 31 balance AND the highest quarterly average balance during the year. Whichever is higher triggers the threshold.

Thinking the ECJ ruling eliminated the form. It did not. The European Court of Justice ruled in 2022 that Spain's original penalties were disproportionate. Spain reduced the fines. The form still exists. The obligation still applies. The penalties, while smaller, still include fines of €100-150 per data item for late or incorrect filings. (The full Modelo 720 requirements and history are here.)

The old regime could impose penalties exceeding the value of the unreported assets. That is gone. The current penalty structure:

Late filing: €100-150 per data item, capped at €20,000.

Failure to file: €100-150 per data item, minimum €300, capped at €20,000

The Agencia Tributaria has automatic information exchange agreements with over 100 countries. They receive data on your foreign accounts whether you file or not. The form is how you prove you disclosed voluntarily.

You cannot file on paper. The process requires a digital certificate (certificado digital — digital certificate) or Cl@ve — online ID system credentials.

If you do not have either, getting a certificado digital takes 1-2 weeks. You need to request it online through the FNMT — Royal Mint website, then verify your identity in person at a Social Security office or other authorized location. Do this now if you have not already. Waiting until March leaves you no margin.

Most expats use a gestor — tax administrator for this filing. Expect to pay €150-300 depending on complexity. Book now. Every gestor on the Costa del Sol is overloaded in March.

If you want to file yourself, the form is available through the Agencia Tributaria sede electrónica — electronic office at sede.agenciatributaria.gob.es. Search for "Modelo 720" in the procedures section.

Now through February: Gather your December 31, 2025, statements. Contact your gestor if using one. March 1-15: File if possible. Systems are less congested. Gestors have capacity. March 16-30: The crush. Everyone who waited. Gestors overbooked. System slower. March 31: Hard deadline. No extensions. No excuses. (Full tax calendar here.)

Two phrases if you are calling your gestor this week:

"¿Tengo que presentar el Modelo 720 este año?" — Do I need to file the Modelo 720 this year?

"¿Puede revisar mis activos en el extranjero?" — Can you review my foreign assets?

Spain's visibility into your foreign financial life is not theoretical. Automatic exchange agreements mean the Agencia Tributaria likely already has data on your accounts in the UK, US, and most of Europe. Modelo 720 is not how they find out. It is how you demonstrate you disclosed it yourself. The filing window is open, the deadline is March 31, and your gestor is about to get very busy. This is the admin task that rewards early action.

Go deeper: If you are still sorting out whether you are technically a Spanish tax resident, the residency rules are more nuanced than "183 days." The criteria, the exceptions, and the Beckham Law option are all worth understanding before you file anything.

→ Tax residency in Spain: The complete guide for 2026

Enjoy the weekend — A. and the fully declared WaypointSur team

PS: Know someone who just moved to Spain or holds foreign assets they haven’t thought about since arriving? Forward this to them. They will get the same newsletter, free. That is how Waypoint Sur grows, one useful step forward at a time.