Modelo 171 — cash deposits and withdrawals over €3,000

From 1 January 2026, Modelo 171 is no longer a bank-only return. Royal Decree 253/2025 rewrote Article 38 of the Spanish tax procedure regulation (RGAT, Royal Decree 1065/2007). Since then, e-money institutions and payment institutions must report cash deposits, withdrawals and collections above EUR 3,000 made in the accounts they manage. Spanish branches of EU institutions are covered, and so are EU institutions operating in Spain under the freedom to provide services, for their Spanish-resident customers. The first return under the new scope covers calendar year 2026 and is due in January 2027. This guide covers who files, what counts as a reportable operation, the record layout, how Modelo 171 sits next to Modelo 196 and the SEPBLAC monthly declaration, and four worked cases.

1. What Modelo 171 is

Modelo 171 is the AEAT’s annual informative return of imposiciones, disposiciones de fondos y cobros de cualquier documento: deposits, withdrawals and collections paid in coins or banknotes. It was approved by Orden EHA/98/2010. Orden HAC/747/2025 (BOE no. 169, 15 July 2025) amended that order to follow the new Article 38. It rewrote Article 3 (who files) and Article 4 (content), removed the old paper annex, and replaced the record design with the one in its Annex V.

Article 6 of the 2010 order still says March. That window was moved to January by Orden HFP/1106/2017, and the 2025 order confirms January 2027 for the first return. Plan for January.

2. Who files since 2026

Article 38(1) RGAT has always covered credit institutions and other entities engaged in banking or credit business, their Spanish branches, and EU or third-country entities operating in Spain under the freedom to provide services. The latter report only where the person making the operation is resident in Spain or is a Spanish permanent establishment of a non-resident.

Article 38(2), in the version in force since 1 January 2026, adds a second group for letter (b) operations only:

• e-money institutions and payment institutions, for operations made in the accounts they manage;
• Spanish branches of e-money and payment institutions from other EU member states;
• EU e-money and payment institutions operating in Spain under the freedom to provide services, for operations by Spanish residents or Spanish permanent establishments of non-residents.

Two limits follow from the text. First, the new group reports only cash operations (letter (b)). It does not report loan balances, which have moved to the new Modelo 181. Second, the obligation attaches to “accounts they manage”. An e-money institution that never touches cash, and whose customers cannot load or withdraw cash in any form, has nothing to report. It should still document why, because the obligation applies to it as an entity.

That reach is the same pattern the 2025 reform applied to Modelo 196, which since January 2026 covers e-money and payment institutions, Spanish branches and freedom-of-services firms on a monthly basis. Firms already set up for Modelo 196 have most of the perimeter work done. They need to add the cash-event layer.

3. What counts as a reportable operation

The trigger is physical cash: moneda metálica o billetes de banco. The amount is tested per operation, against EUR 3,000. Operations in other currencies are converted at the official euro exchange rate published by the ECB. The phrase “by any physical or electronic means” means the channel does not matter. A cash withdrawal at an ATM, a cash deposit at a counter or a cash load through an agent are all in scope if the cash moves into or out of an account the firm manages.

The record uses four operation keys:

Each record also states who carried out the operation, using the declared-person key: T for the account holder, A for an authorised person, O for others. The person reported is the one who made the operation, not automatically the account holder. A third party who pays cash into a customer’s account is reported with key O, together with the account it went into.

The content required by Article 4 of the 2010 order is short: the name and tax ID of the person, the date, the nature of the operation, the amount in euro, and the account debited or credited.

4. The record layout and the filing

The file is fixed-width, 500 positions per record, with one type-1 declarant record and one type-2 record per operation. The points that most often fail validation for a payment firm are these:

• Declarant NIF (positions 9–17), right-aligned with the check character last. A Spanish branch files under its own Spanish NIF.
• Declared NIF (positions 18–26): only Spanish-issued NIFs. For minors under 14 or legally incapacitated persons, the legal representative’s NIF goes in positions 27–35.
• Non-residents: the NIF field can be blank. Position 76 gives the document type (1 passport, 2 national ID valid in the country of origin, 3 other), positions 77–96 the document number, and 97–98 the country code under Orden EHA/3496/2011.
• Account code type (position 100): C for an IBAN, O for an internal identifier. The IBAN is mandatory if the declarant is entered in the Banco de España register of entities “or, where applicable, its European equivalent”. A passported EU institution with IBANs should report the IBAN.
• Date (positions 125–132) as AAAAMMDD, operation key at 133, amount in euro without sign or decimal point, the last two digits being cents.
• Complementary or substitute returns: C or S at positions 121–122, with the earlier return’s number at 123–135.

Filing is electronic through the AEAT electronic office, procedure GI33, either by file upload or online form. Under the 2010 order, returns of up to 5,000,000 records are filed online and larger ones on physical media. The data must pass the AEAT validation before submission.

5. Modelo 171, Modelo 196 and the SEPBLAC monthly declaration

The same cash operation can touch three regimes, and they do not substitute for each other.

The split is clean once you see it. The SEPBLAC cash item under letter (a) excludes account operations. Modelo 171 covers only account operations. A cash payment into an account is a Modelo 171 event at EUR 3,000.01, whatever its size. A large cash operation outside any account is a SEPBLAC event above EUR 30,000. A money remitter taking cash for a transfer without an account is in the letter (b) regime at EUR 1,500.

6. Four worked scenarios

Scenario one — an EU e-money institution under the freedom to provide services. A Luxembourg-authorised e-money institution serves Spanish residents from Luxembourg with no Spanish branch. Its debit card lets customers withdraw cash at ATMs, with a daily limit of EUR 1,000. Rule: Article 38(2) RGAT brings it into scope for Spanish residents, but each operation must exceed EUR 3,000. What compliance does: confirms the limit is enforced technically and that no other cash channel exists, then records a nil assessment for 2026 signed by the reporting owner. Outcome: no records to report. The file shows why, and the assessment is repeated if the limit changes.

Scenario two — cash loading through an agent network. A Spanish payment institution lets merchants pay cash into their payment accounts at partner points of sale. One merchant pays EUR 4,200 in on 3 March and EUR 2,900 on 4 March. Rule: the threshold is per operation. What the reporting team does: reports the EUR 4,200 deposit with key A, the merchant’s NIF, key T and the IBAN. The EUR 2,900 deposit is not reported in Modelo 171. Outcome: one record. The pattern of deposits just under EUR 3,000 is passed to the AML team, because structuring is a monitoring question, not a tax-reporting one.

Scenario three — a third party pays in. A relative pays EUR 6,000 in cash into a customer’s account at a Spanish branch of a German e-money institution. Rule: the record identifies the person who made the operation. What the team does: reports the relative’s NIF with key O, the amount, the date and the customer’s IBAN. If the relative is a non-resident without a Spanish NIF, it fills positions 76–98 with the passport number and country code. Outcome: one record, with the correct person. A file that reports the account holder instead identifies the wrong taxpayer.

Scenario four — a correction after filing. In February 2027 the firm finds that a migration bug dropped twelve qualifying withdrawals from its January return. Rule: the order allows complementary returns for omitted records. What the team does: files a complementary return, with C in position 121 and the original return’s number in positions 123–135, containing only the twelve missing records. Outcome: the return is complete. A substitute return (S) would only be used to replace the whole earlier filing.

7. FAQ

8. What to do, today

• List every channel through which cash can enter or leave an account you manage: ATMs, agents, cash-in partners, branches. If there is none, write that down and have it signed off.
• For each channel, check whether a single operation can exceed EUR 3,000. If limits prevent it, record the limits and who can change them.
• Reuse your Modelo 196 perimeter: the same Spanish branches, freedom-of-services customers and NIF data feed Modelo 171.
• Make sure the cash event carries the identity of the person who performed it, not just the account holder. Agent and cash-in feeds often lose this.
• Build the type-1 and type-2 records against Annex V of Orden HAC/747/2025 and run them through the AEAT validation in Q4 2026, using real 2026 data.
• Put 31 January 2027 in the reporting calendar, with a complementary-return procedure behind it.

Related: Modelo 196 is monthly now · SEPBLAC monthly declaration (DMO) · Modelo 170