New Spanish AEAT Tax Reporting Requirements Explained: Models 196 and 170 (2026 Guide)

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.

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
  

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.

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:

1. Extract the required account and transaction data from existing systems on a monthly basis
2. Transform that data into the format required for Models 196 and 170
3. Generate AEAT-compliant XML files for submission
4. 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.

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.