You hold Bitcoin on Coinbase, Ethereum on Kraken and some USDT on Bybit. If the combined value exceeds €50,000 at 31 December, the Spanish tax agency wants to know about it. That is what Modelo 721 is for.
What is Modelo 721?
Modelo 721 is an informational return that Spanish tax residents must file if they hold crypto in custody abroad.
It is not a tax. You pay nothing when you file it. You simply tell the tax agency what you hold and where you hold it.
It is governed by Royal Decree 249/2023 and Order HFP/886/2023. It was first filed in 2024, for the 2023 tax year, and since then it is filed in the first quarter of each year whenever the obligation applies.
Who has to file Modelo 721?
You must file Modelo 721 if you meet all of these conditions:
- You are tax resident in Spain (more than 183 days a year)
- You hold crypto on foreign exchanges or custodians
- The combined value exceeds €50,000 at 31 December
If you have €30,000 on Coinbase and €25,000 on Kraken, that adds up to €55,000 → you have to file it.
If you only have €40,000 in total → you are not required to.
When is Modelo 721 filed?
| Tax year | Filing period |
|---|---|
| 2025 | 1 January – 31 March 2026 |
| 2026 | 1 January – 31 March 2027 |
The filing period runs from 1 January to 31 March of the year after the tax year.
If you file after 31 March, it is late and there is a penalty, although a lower one if you file before the tax agency asks you to (more on this below).
Which exchanges count as foreign?
This is the key question. What decides whether an account falls under Modelo 721 is where the entity holding your crypto in custody is based: if it is a foreign entity, it counts; if it is a Spanish entity, it does not.
Important: an exchange being registered with the Bank of Spain, holding a MiCA licence or serving customers in Spain does not make it Spanish. If the entity your account is with is in Ireland, Malta or Austria, it is still a foreign custodian for Modelo 721 purposes. Modelos 172 and 173 are a separate obligation that applies to providers with a presence in Spain.
Exchanges that DO require Modelo 721
These exchanges hold assets through entities outside Spain. The table is a guide (October 2026): entities change as licences are granted, so check your terms of service to see which one your account is with.
| Exchange | Country of the entity for European customers | Modelo 721? |
|---|---|---|
| Coinbase | Luxembourg (previously Ireland) | Yes |
| Kraken | Ireland (Payward Europe) | Yes |
| Crypto.com | Malta | Yes |
| Bitstamp | Luxembourg | Yes |
| Bitpanda | Austria | Yes |
| eToro | Cyprus | Yes |
| Gemini | Malta | Yes |
| Bitvavo | Netherlands | Yes |
| Trade Republic | Germany | Yes |
| Revolut | Outside Spain (European entity) | Yes |
| Kriptomat | Estonia | Yes |
| WhiteBit | Lithuania | Yes |
| YouHodler | Switzerland | Yes |
| KuCoin | Austria (KuCoin EU) | Yes |
| Bybit | Austria (Bybit EU) | Yes |
| OKX | Malta (OKX Europe) | Yes |
If your account predates the European licence, the entity may have been a different one in some years (Seychelles, Dubai…). Either way, all of them are foreign for Modelo 721 purposes.
Exchanges that do NOT require Modelo 721
These exchanges hold assets through Spanish entities (and they also file Modelos 172/173):
| Exchange | Modelo 721? |
|---|---|
| Bit2Me | No |
| Criptan | No |
| Bitnovo | No |
| Bitbase | No |
If all your crypto is with Spanish custodians, you do not have to file Modelo 721.
What about Binance? Binance stopped operating in Spain on 1 July 2026 (we cover it here). For earlier years, whether your balances counted towards Modelo 721 depends on which entity held your funds in each period, and there is no single answer for every user. Our specialists review your case and give it the correct treatment.
Do cold wallets count towards Modelo 721?
No. Non-custodial wallets (Ledger, Trezor, Metamask) do not count towards Modelo 721.
Modelo 721 only covers crypto held by third-party custodians (exchanges). If you control the private keys, there is nothing to report.
What information has to be declared?
For each foreign exchange you must report:
- Exchange details: full name, country, address
- Type of crypto: BTC, ETH, USDT, etc. (one line for each)
- Balance at 31 December: number of units and their value in euros on that date
- Additions and disposals: if you add a coin for the first time or no longer hold one you had already declared, this is reported
What counts is the value at 31 December, not an average balance (the average balance for the last quarter is a Modelo 720 figure for bank accounts, not a Modelo 721 one).
What if I already filed Modelo 721 last year?
You only have to file it again if:
- The combined value has risen by more than €20,000 compared with the last return filed
- You have ceased to own coins you had already declared (you sold them, swapped them or moved them off the custodian): in that case you have to report that disposal
Opening an account on a new foreign exchange does not, on its own, require you to file again: it only matters if, with it, the combined value rises by more than €20,000 over what you last declared.
And watch out: selling everything does not get you off the hook. If you have already filed Modelo 721 and during the year you sell or withdraw those coins, you have to file Modelo 721 for that year to report the disposal.
If you still hold the same coins and the portfolio has only fallen (or risen by less than €20,000) because of price, you do not have to file it again. In-between cases, such as partial sales or transfers between foreign exchanges, are worth checking: our specialists review your case and give it the correct treatment.
Penalties for not filing Modelo 721
Modelo 721 is subject to the general penalty regime for informational returns (Articles 198 and 199 of the Spanish General Tax Act):
| Infringement | Penalty |
|---|---|
| Not filing (data omitted) | €20 per item or set of data, minimum €300 and maximum €20,000 |
| Filing late without a demand from the tax agency | €10 per item or set of data, minimum €150 and maximum €10,000 |
| Inaccurate or false data | General regime (Article 199) |
Examples:
- You omit 8 items: 8 × €20 = €160 → the €300 minimum applies.
- You omit 40 items: 40 × €20 = €800.
- You file those 40 items late, but before the tax agency asks: 40 × €10 = €400.
The figures of “€5,000 per item with a €10,000 minimum” that still do the rounds belonged to the old Modelo 720 penalty regime. They were struck down after the Court of Justice of the EU judgment of 27 January 2022 (C-788/19) and abolished by Law 5/2022. They do not apply to Modelo 721.
Moderate fines do not mean Modelo 721 does not matter: it is information the tax agency cross-checks against your income tax return.
Frequently asked questions
Do I have to file Modelo 721 if I have not sold anything?
Yes. Modelo 721 is informational. You declare what you hold, not what you have gained. Whether you have sold or not makes no difference.
What if I have less than €50,000?
You are not required to file it. The threshold is €50,000 combined across all foreign exchanges.
Is Binance a foreign exchange?
Binance stopped operating in Spain on 1 July 2026. For earlier years, it depends on which entity held your funds in each period, and there is no single answer. If you have already declared Binance balances on Modelo 721 and have moved them out, remember that this disposal must also be reported. Our specialists review your case and give it the correct treatment.
Can I file it late?
Yes. If you file it before the tax agency asks you to, the penalty is €10 per item or set of data, with a €150 minimum. If they ask you first, the full penalty applies: €20 per item, with a €300 minimum and a €20,000 maximum.
Does the tax agency know I hold crypto on a foreign exchange?
Increasingly, yes. The tax agency already receives data from exchanges with a presence in Spain (Modelos 172 and 173) and from Modelo 721 returns themselves. On top of that, the DAC8 Directive has applied since 1 January 2026: European exchanges have been collecting their customers’ data since that date and sending it to their own tax authority, which will exchange it with the Spanish one. The first exchange will take place by 30 September 2027 at the latest, with 2026 data.
Summary
- What it is: an informational return for crypto held on foreign exchanges
- Who files: Spanish tax residents with more than €50,000 at 31 December
- When: from 1 January to 31 March (for the 2026 tax year, by 31 March 2027)
- Where: the AEAT online portal (Sede Electrónica)
- Penalties: €20 per item (minimum €300, maximum €20,000); half that if you file late without a demand
Need help with your Modelo 721?
At CryptoImpuestos we prepare your Modelo 721 with all the right data. We download your history, calculate the balances and file it for you. Message us on WhatsApp.
Víctor Lázaro
Marketing Director, Cryptoimpuestos.es
