Blog
JANUARY 7, 2026 • 5 MIN READ
New Spanish AEAT Tax Reporting Requirements Explained: Models 196 and 170 (2026 Guide)
Fiona Jelly,
Founder & CEO of Complyfirst
Spain is continuing its move toward greater, more frequent visibility of payment activity, particularly across digital and cross-border business models.
These changes were introduced by Royal Decree 253/2025, published in April 2025, which amends the RGAT, and they apply to reporting periods starting from 1 January 2026.
In practical terms, this marks a shift for payment and e-money firms. What was previously annual, fragmented, or threshold-based becomes monthly, comprehensive, and operational. This is no longer a “periodic filing” obligation. It is an ongoing reporting process that must run reliably every month.
To understand the impact, it helps to look at what applied before, and what applies from 2026 onwards.
TL;DR
From 1 January 2026, the Spanish Tax Agency (AEAT) requires monthly tax reporting under Models 196 and 170. These obligations apply to payment institutions, electronic money institutions, banks, and other entities facilitating accounts or payment collections for Spanish merchants. Firms operating in Spain, including under freedom to provide services (FOS), must assess their data, systems, and reporting processes now to ensure timely compliance for the first filing in February 2026.
At a glance: what’s changed
Before (pre-2026)
- Model 196 was primarily an annual obligation and largely associated with banks
- Model 170 was filed annually and only once a €3,000 transaction threshold was exceeded
- Non-Spanish payment firms were often outside scope in practice
From 2026 onwards
- Model 196 must be filed monthly by banks, payment institutions, and EMIs
- Model 170 must be filed monthly, with no transaction threshold
- Cross-border firms operating in Spain under freedom to provide services (passporting) are explicitly in scope
From 2026, compliance moves from periodic reporting to a continuous monthly process.
Models 196 and 170 (Explained Without the Tax Jargon)
The simplest way to understand the two models is to separate where money sits from how money moves.
- Model 196 looks at the containers of money, i.e. accounts and wallets.
- Model 170 looks at the movement of money, i.e. card and mobile payments.
Together, they give the Agencia Estatal de Administración Tributaria (AEAT) a detailed, ongoing picture of payment activity connected to Spain.
Model 196: Financial Accounts (Where Money Sits)
Model 196 is a monthly declaration covering all financial accounts managed by regulated entities. This includes both traditional bank accounts and non-bank payment accounts.
Firms are required to report:
- All accounts opened, held, or closed during the period
- The people connected to those accounts, including account holders, beneficial owners, and authorised persons
- Account balances and holdings
- Any withholdings or account-related income
One practical point is worth calling out. While filings from January to November focus mainly on account existence and parties, the December filing is more extensive. It also includes year-end balances, average balances for the final quarter, and annual totals. For most firms, December will be the heaviest reporting month.
Two clarifications that are often missed:
- Non-resident accounts are included, with or without a Spanish permanent establishment
- Model 196 replaces the former Model 291 for non-resident accounts
Crypto and securities accounts are not in scope.
Model 170: Card and Mobile Payments (How Money Moves)
Model 170 focuses on payment collection activity carried out for merchants and professionals established in Spain.
Each month, firms must report information such as:
- Card payment transactions (physical and virtual)
- POS terminal activity
- Payments linked to mobile phone numbers
- Monthly transaction amounts and frequency
- Merchant identifiers and settlement accounts
There are two points that matter operationally.
- First, there is no minimum threshold. All in-scope transactions must be reported, regardless of value.
- Second, this model applies only to merchant payments. Consumer-to-consumer payments, such as transfers between individuals, are outside scope.
Reporting Timeline
- Effective date: 1 January 2026
- First filing: due in February 2026 (for January 2026 data)
- Frequency: Monthly submissions. Each filing is due by the end of the following month. For example, January data must be filed by the end of February.
Who Has to File Model 196 and 170?
The reporting obligation applies broadly across the payments ecosystem. Most payment and e-money firms will need to file both models.
In scope are:
- Payment institutions
- Electronic money institutions
- Banks and credit institutions
- Firms providing POS, acquiring, or payment collection services
- Spanish branches of EU and non-EU firms
- Firms operating under freedom to provide services (FOS), where authorised and registered with the Bank of Spain or the EBA
Freedom to provide services (FOS) is an EU principle that allows a company authorised in one EU Member State to offer services in another Member State without setting up a local branch or subsidiary there.
The determining factor is Spanish tax nexus.
Reporting applies where the merchant or account holder:
- Is resident in Spain, or
- Is a non-resident with a Spanish permanent establishment
It does not apply to tourists, temporary visitors, or foreign merchants with no Spanish establishment.
What matters is the status of the merchant or account holder, not where your firm is based or where the transaction technically takes place.
Establishment outside Spain does not remove the obligation if Spanish merchants or account holders are involved.
What Firms Should Be Doing in 2025
Firms that struggle with these obligations usually do so because preparation started too late.
During 2025, payment and e-money firms should:
- Confirm which entities, merchants, and accounts are in scope
- Clearly separate account data (Model 196) from transaction data (Model 170)
- Review AEAT technical specifications and XML schemas early
- Test whether systems can reliably produce monthly extracts
- Plan specifically for the heavier December Model 196 filing
- Run a dry-run of January 2026 data ahead of the first deadline
How Complyfirst Helps Firms Comply with Models 196 and 170
Most teams don’t struggle with understanding Models 196 and 170. They struggle with turning them into a process that runs smoothly every month. That’s what Complyfirst is for.
Complyfirst helps firms:
- Extract the required account and transaction data from existing systems on a monthly basis
- Transform that data into the format required for Models 196 and 170
- Generate AEAT-compliant XML files for submission
- Manage corrections, resubmissions, and ongoing changes once reporting is live
For firms operating cross-border or under freedom to provide services, Complyfirst helps apply the same reporting process consistently across entities.
The goal is simple: make monthly AEAT reporting predictable, repeatable, and low-drama.
For a full snapshot of Spanish tax models 196 and 170, you can watch the video snippet below from Fiona’s EU webinar session, or download a full PDF version right here.
FAQs
Yes, if you passport into Spain, and have Spanish-resident customers with accounts or wallets (Model 196), and/or card or mobile payment activity linked to Spain (Model 170).
IDOtro can be used, but only in the correct context. If the customer is a non-Spanish tax resident (resident abroad) and does not have a Spanish NIF, the foreign TIN should be reported in the IDOtro field, and “ClaveNoResidente” should be set to 2 (non-resident without permanent establishment).
If the customer is a Spanish tax resident, nationality is irrelevant and “ClaveNoResidente” must be set to 1. The expected identifier is a Spanish NIF. If the NIF is not yet available, select “declared without NIF temporarily” under “No Obligado,” as described as a transitory case under Art 28.3 RGAT.
Although the XML schema allows ID types such as 03 (passport) or 06 (other evidentiary document), using these for Spanish residents as a substitute for a NIF is not clearly described in the guidance/FAQs and may carry audit / interpretation risk.
For a Spanish tax resident, there is no clear regulatory flexibility to replace a required NIF with a driving licence. Where the NIF is missing, the appropriate mechanism is “declared without NIF temporarily” on a genuinely temporary basis while remediation is ongoing.
If the customer is a non-Spanish tax resident (resident abroad) and classified as ClaveNoResidente = 2, identification follows the non-resident regime. In that case, IDOtro may be used and IDType = 06 (“another evidentiary document”) may be used, and a driving licence number can be reported as the identifier.
Model 196 provides two values for L13:
- L13 = 1: “Other situations (residents and non-residents with permanent establishment)”
- L13 = 2: “Non-resident without permanent establishment”
Although “other” may suggest a residual category, it does not mean “unknown.” These are two clearly defined and mutually exclusive tax-status categories. There is no option for “residence not determined,” so L13 requires classification based on your firm’s due diligence (AML or CRS procedures).
Yes. Model 196 includes both resident and non-resident accounts.
No. All in-scope transactions must be reported.
Reporting applies from 1 January 2026, with first submissions due in February 2026.
Conclusion
Models 196 and 170 represent a significant expansion of Spanish tax reporting for payments and e-money firms. From 2026, compliance becomes monthly, technical, and continuous, including for firms operating cross-border into Spain.