Modelo 720: Your Broker Gave You a Spanish IBAN, But Your ETFs Can Still Require Reporting

Modelo 720: Your Broker Gave You a Spanish IBAN, But Your ETFs Can Still Require Reporting

Your broker sends a notice: “we’ve migrated your account to a Spanish IBAN.” And a rumor spreads, especially in investing forums, that this exempts you from Spain’s modelo 720 foreign-asset reporting form. For the cash account, that’s true. For the ETFs or funds sitting in the same broker’s custody account, it almost never is, and they’re two separate obligations governed by two separate rules.

Mixing the two is the mistake that’s spreading fastest right now among people investing through brokers like Trade Republic, DeGiro or similar, many of which have recently moved their clients’ cash accounts from a German or Dutch IBAN to a Spanish one, while the securities (custody) account stays exactly where it was.

What the modelo 720 is and the three things it covers

The modelo 720 is an informative return, not a tax settlement: you don’t pay anything for filing it, but skipping it (when it applies) has real consequences. It covers three blocks of assets held abroad, each with its own €50,000 threshold: bank accounts, securities and rights (shares, funds, life insurance, annuities), and real estate.1

What matters for this article is that accounts and securities are separate blocks, governed by separate articles of the implementing regulation, each with its own test for whether something counts as “abroad” for reporting purposes.

Why a Spanish IBAN DOES exempt the cash account

Let’s start with what’s true. Article 42 bis of the regulation that develops the modelo 720 requires reporting accounts “located abroad, opened at institutions engaged in banking or credit business.”2 That’s the key phrase: located abroad. A binding ruling from Spain’s Directorate-General for Taxes (DGT) from December 2025, about a German broker that migrated a client’s cash account to a Spanish IBAN through its branch in Spain, confirms this without hedging: from the migration onward, “the bank account must be understood to be located in Spain and, therefore, not subject to the reporting obligation (…) regardless of whether the quantitative threshold” of €50,000 is exceeded.3

The Agencia Tributaria’s own FAQ for the modelo 720 says the same thing: if your account migrated to a financial institution established in Spain, it stops requiring reporting (unless the migration closed the old account and opened a new one, in which case that closure is reported the year it happened).4

So far, the rumor is right: a cash account with a Spanish IBAN no longer counts as “abroad.” The problem is that most brokers migrate the cash account first (or only), while the securities account, where your ETFs, shares and funds actually sit, stays held at the parent entity, outside Spain. And there the test is a different one.

Why your ETFs don’t get exempted by the same IBAN

Securities and shares or units in foreign funds or ETFs fall under article 42 ter of the same regulation, not article 42 bis. Its second paragraph requires reporting “shares and units in the share capital or assets of collective investment institutions located abroad” that you hold.5

The test here is not the IBAN of your cash account: it’s where the share or unit is held in custody and, above all, whether the entity holding it is registered as a distributor with Spain’s securities regulator (CNMV) or has a representative in Spain. A binding ruling from June 2025, about someone who had bought ETFs through a German broker operating under a European passport (freedom to provide services, with no branch or representative in Spain), makes this plain: since the entity holding the ETFs in custody “cannot be considered obliged to supply the Spanish tax authority” with the equivalent information, “the consultant becomes subject to the obligation to file” the modelo 720 for those ETFs.6

In other words: a broker giving you a Spanish IBAN for cash changes nothing about where your ETFs are actually held, or about whether that broker is registered as a distributor in Spain. Those are two different questions, and the second one is what actually decides whether you have to report your securities.

When you ARE exempt: a registered distributor or representative in Spain

There’s a real exception, and it’s worth knowing because you might already meet it without realizing. If you buy your funds or ETFs through an entity that is registered with the CNMV as a distributor of those collective investment institutions in Spain, or through the Spain-based representative of the foreign fund manager, you don’t have to report them on the modelo 720: the reporting obligation for those securities falls on the distributor or representative, not on you.7

The June 2025 ruling reaffirms this 2013 criterion as still-current doctrine: the exception only applies while your securities stay “registered by their holders with those distributors or representatives.”6 If you bought the ETF directly through an app or foreign broker that isn’t registered as a distributor of that specific fund in Spain, the typical case of buying the same ISIN through a pan-European platform with no office here, the exception doesn’t cover you, and the obligation is yours.

It’s the same “registered distributor” requirement that decides whether your fund-to-fund transfers get tax deferral or not: the question “is my broker registered as a distributor of this specific product with the CNMV?” answers two separate tax questions with a single fact.

How to check whether your broker or fund is registered with the CNMV

Since everything hinges on that one fact, it’s worth knowing how to check it yourself. The CNMV keeps public, free official registries, and two of them are useful here:

Two caveats, because the registry doesn’t settle everything on its own. Being able to buy the ETF through the app doesn’t mean it’s registered; and the fund appearing in the registry doesn’t guarantee that your particular holding is channelled through that Spanish distributor, which is what the exception requires (that your securities are “recorded by their holders” with it). If you’re still unsure after checking, the exact question to put to your broker is: “is there a distributor or representative registered with the CNMV that assumes the obligation to report my securities on the modelo 720?” That answer settles it. You can start from the CNMV official registries hub.

The threshold and the deadline

For the securities block, you only need to report if the combined value of shares, units, life insurance and annuities held abroad exceeds €50,000 at December 31; below that, there’s no obligation (for none of the three blocks, each measured separately).5 The deadline runs from January 1 to March 31 of the year following the one the information refers to.5

And once you’ve filed the modelo 720 for the first time, you don’t automatically have to file it again every year: you only need to refile that block if its combined value rises by more than €20,000 compared to the amount that triggered your last filing (or if you stop holding something you’d previously reported, in which case you report the disposal).5

If you’ve gone years without filing, the situation has changed

Until 2022, failing to file the modelo 720 when it applied carried a brutal regime: the gain was treated as taxable with no statute of limitations ever applying, and the specific fines were fixed and very high. The Court of Justice of the European Union ruled that regime contrary to EU law in January 2022, for being disproportionate.8 Spain repealed it a few weeks later.9

Since then, two things change if the tax authority later discovers an unreported asset. First, the unjustified capital gain reverts to the general rule: it’s attributed to the tax year in which it’s discovered, unless you can prove you already held the asset before the statute-of-limitations period began (the standard 4 years).10 Second, if you simply file late on your own initiative, without a prior request from the tax authority, the general penalties for any late informative return apply: €10 per omitted data point, with a minimum of €150 and a maximum of €10,000 (half of what it would cost if they catch it first).11

This isn’t an argument for ignoring the obligation, the fine is still real, and an unreported gain can still be adjusted with a surcharge, but if you’ve had a foreign broker for a while and weren’t sure whether it applied to you, the cheapest way out remains the same as always: check it now and, if it applies, file on your own initiative as soon as possible rather than waiting to be asked.

A note on crypto

If you also hold cryptocurrency on a foreign exchange, that obligation runs through its own form (the modelo 721) with its own rules, separate from the modelo 720.12 We won’t get into it here to avoid mixing two returns with their own requirements; if it applies to you, treat it as a separate question.

How does Cuéntamo help with this?

Cuéntamo’s investment module brings together positions spread across brokers, shares, ETFs, funds, crypto, deposits, in one place, with the current value of each. It doesn’t file the modelo 720 for you (that’s a return filed directly with the Agencia Tributaria), but having a clear view of what you hold, where, and for how much is the first step to knowing whether you’re approaching the €50,000 threshold in any of the three blocks, especially if you invest across several brokers and nobody else gives you that combined picture.

If you’re just getting started and want the basics straight before getting into the tax side, how to start investing from scratch is a good place to begin; and if you already have a portfolio, how your investments are taxed in Spain fills in the rest of the map: dividends, capital gains and pension plans.

Frequently asked questions

My broker gave me a Spanish IBAN. Do I no longer need to file the modelo 720?

It depends on what you hold. If we’re only talking about the cash account, and the migration was carried out by a Spain-based branch of your broker, that account stops counting as “abroad” and no longer counts toward the modelo 720. But if you hold ETFs, funds or shares in the same broker’s custody account, that part is governed by a different test (where it’s held in custody, and whether the broker is registered as a distributor in Spain), and the IBAN migration typically doesn’t touch it.

How much do I need to have invested before my ETFs require reporting?

The threshold is a combined €50,000 across all foreign securities, units, life insurance and annuities, as of December 31. Below that figure, there’s no obligation in that block.

I already reported my ETFs last year. Do I have to do it again this year?

Only if that block’s combined value has risen by more than €20,000 since the amount that triggered your last filing, or if you’ve stopped holding something you previously reported (in which case you report the disposal).

What happens if I never filed and I should have?

Since 2022, the modelo 720 no longer carries the aggravated penalty regime or the unlimited statute of limitations it had before the Court of Justice of the European Union struck it down. The general penalties for any late informative return now apply, and an unreported gain reverts to the ordinary statute of limitations. Even so, the sooner you regularize it on your own initiative, the lower the penalty.

Do my cryptocurrencies on a foreign exchange fall under this modelo 720?

No, they go through a separate form (the modelo 721), with its own rules. If you hold crypto abroad in addition to ETFs, these are two separate obligations that need to be checked independently.

References

Figures for 2026. The €50,000 threshold and the January 1–March 31 filing window for the securities block have been in force since article 42 ter was added to the regulation in 2013 (Royal Decree 1558/2012); the general penalty regime and the ordinary statute of limitations for unjustified gains have been in force since March 2022 (Law 5/2022).

This article is checked against official sources and reviewed periodically. If you spot anything out of date, email us at [email protected].

  1. Eighteenth additional provision of the General Tax Act (Ley 58/2003): taxpayers must report on “accounts located abroad” (letter a), “any securities, assets, rights or shares (…) held or located abroad” (letter b), and “real estate (…) located abroad” (letter c). Each block carries its own €50,000 threshold in the implementing regulation. ↩︎

  2. Article 42 bis, paragraph 1, of the regulation approved by Royal Decree 1065/2007: the obligation to report “all accounts (…) located abroad, opened at institutions engaged in banking or credit business.” Paragraph 4.e) sets the threshold: no obligation if the balances “combined, do not exceed €50,000.” ↩︎

  3. DGT binding ruling V2475-25, of 12 December 2025: on the migration of a cash account from a German broker to a Spanish IBAN through its Spain-based branch, it concludes that “following that migration, the bank account must be understood to be located in Spain and, therefore, not subject to the reporting obligation (…) regardless of whether the quantitative threshold is exceeded.” The ruling only addresses the cash account: the same consultant also held a securities account, which falls outside this answer. ↩︎

  4. Modelo 720 FAQ, Agencia Tributaria: “There is no obligation to report on the modelo 720 a bank account originally located abroad (…) once it has migrated to a financial institution established in Spain. Where the migration resulted in the termination of that account and the opening of a new one at the Spain-based institution, that termination is reported on the modelo 720 for the year it occurred.” ↩︎

  5. Article 42 ter of the regulation approved by Royal Decree 1065/2007. Paragraph 2: the obligation to report “shares and units in the share capital or assets of collective investment institutions located abroad.” Paragraph 4.c): combined €50,000 threshold. Paragraph 5: the return “must be filed between January 1 and March 31 of the year following” the one it refers to; and “filing in subsequent years is only mandatory when the combined value (…) has increased by more than €20,000 compared to the amount that triggered the last filing.” ↩︎ ↩︎ ↩︎ ↩︎

  6. DGT binding ruling V1013-25, of 17 June 2025: on ETFs bought through a German broker operating under freedom to provide services, with no branch or representative in Spain, it concludes that the custodian entity “cannot be considered obliged to supply the Spanish tax authority” with the equivalent information, so “the consultant becomes subject to the obligation to file” the modelo 720. ↩︎ ↩︎

  7. DGT binding ruling V0443-13, of 13 February 2013: securities “whose holding is channeled through distributor entities based in Spanish territory (…) or through the Spain-based representative of the managing company (…) as long as those securities remain registered by their holders with those distributors or representatives” fall outside the obligation in article 42 ter.2, because that information is already supplied by the distributor or representative. The 2025 ruling V1013-25 reaffirms this criterion as still current. ↩︎

  8. Preamble of Law 5/2022, of 9 March: “the Court of Justice of the European Union (First Chamber), in its judgment of 27 January 2022 in case C-788/19, has determined that certain aspects of the legal regime associated with the obligation to report assets and rights abroad (modelo 720) breach EU law.” ↩︎

  9. Sole repealing provision of Law 5/2022: expressly repeals “the first and second additional provisions of Law 7/2012,” which contained the modelo 720’s specific aggravated penalty regime. ↩︎

  10. Article 39 of the Personal Income Tax Act (Ley 35/2006), as redrafted by the fifth final provision of Law 5/2022: unjustified capital gains “shall be included in the general taxable base for the tax period in which they are discovered, unless the taxpayer sufficiently proves that they held the assets or rights concerned since a date earlier than the statute-of-limitations period.” ↩︎

  11. Article 198, paragraphs 1 and 2, of the General Tax Act (Ley 58/2003): for informative returns of the kind covered by article 93 of the act, the penalty is “a fixed fine of €20 per data point (…) with a minimum of €300 and a maximum of €20,000”; and “where the return is filed late without a prior request from the tax authority, the penalty and its minimum and maximum limits are halved.” ↩︎

  12. The obligation to report virtual currencies held abroad sits in letter d) of the eighteenth additional provision of the General Tax Act, developed in its own article of the regulation and with its own filing form (the modelo 721), separate from the modelo 720. ↩︎

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