Spanish Models 196 & 170
Spanish Tax Agency Models 170 and 196 are monthly reporting requirements for payment activity connected to Spain, giving tax authorities greater visibility into payment flows.
- Applies to banks, PSPs, and EMIs with Spanish-linked activity
- Covers payments, accounts, and digital wallets
- Requires monthly XML submissions to the Spanish Tax Agency
- Aims to improve tax transparency and detect undeclared income
- Legal Basis: Royal Decree 253/2025 (1 Apr 2025) amending the RGAT
What’s the scope?
Entities in scope
Banks, Payment Institutions (PIs), and Electronic Money Institutions (EMIs) connected to Spain, including branches and passported firms operating in Spain.
Customer nexus
Model 196: Customers with Spanish tax residency or a Spanish permanent establishment
Model 170: Merchants or professional activities connected to Spain
Activity covered
Model 196: Managing accounts and wallets (the “containers” of money)
Model 170: Collecting merchant payments via card, mobile, or POS (the movement of money)
Deadline
First submission due end of February 2026, covering January 2026 data.
Reporting frequency
Monthly reporting for both Model 170 and Model 196.
File format
XML files aligned with the official XSD schema, validated prior to submission.
Data fields needed for submission
Model 196:
Accounts & wallets
Covers where money is held in accounts and digital wallets connected to Spain. This includes customer identification details and reportable balances for individuals and businesses.
- Accounts: Account ID or reference, account type, open/close dates, and reportable balances
- Individuals: Full name, TIN (or passport/ID and issuing country if no TIN), residence, date of birth
- Corporates: Entity name, TIN (or registration/ID and issuing country), and UBO details (same fields as individuals)
Model 170:
Card & mobile payments
Covers how money moves through merchant payment activity connected to Spain. This includes card and mobile payments, transaction counts, and total amounts processed.
- Payments: Payment type (card/mobile), reporting period, transaction count, total amounts
- Merchants: Merchant name, TIN (or registration/ID and issuing country), settlement account / IBAN
- Channel: POS or terminal ID (if applicable) and payment instrument reference (card or payment ID)
Reporting considerations to keep in mind
Model 196
December Reporting Complexity
December submissions are more extensive, requiring year-end balances, average Q4 balances, and annual totals in addition to standard monthly data.
Model 170
Expanded Scope
The €3,000 reporting threshold has been removed. All in-scope merchant payment activity connected to Spain must now be reported.
Steps to submission
A practical step-by-step overview of how to prepare, validate, and submit Model 170 and 196 reports to the Spanish Tax Agency.
Identify in-scope customers
Tag customers as “Spain reportable” based on tax residency, merchant activity, and account usage to drive monthly extracts.
Validate tax residency vs KYC
Cross-check TIN/VAT, addresses, and declared residency against KYC data and remediate gaps early.
Prepare and submit XML
Generate, validate, batch (max 10,000 records per file), and submit compliant XML files to the Spanish Tax Agency (AEAT).