Modelo 174 — Spain’s annual card-issuer return
Spain’s tax agency has had merchant acquiring data for years. From the 2026 financial year it also gets the other side: every card you issue, who holds it, and what went on and off it. Real Decreto 253/2025 added a new article 38 ter to the Spanish tax procedure regulation (RGAT, Real Decreto 1065/2007), and Orden HAC/747/2025 of 27 June 2025 approved a new return to carry it: modelo 174, “Declaración informativa sobre todo tipo de tarjetas”. It is annual. The first file covers 2026 and is due between 1 and 31 January 2027. The data for that file is being generated now, so issuers that have not mapped their card ledger to the new fields are already building it retrospectively.
1. Who files: issuers, including passported ones
Article 15 of the order does not define the filers itself. It points back to article 38 ter.1 RGAT, which is where any scoping memo should start. The article names three groups:
| Limb | Who | Condition |
|---|---|---|
| 38 ter.1(a) | Credit institutions and other entities engaged in banking or credit business | Issue cards of any kind |
| 38 ter.1(b) | Payment institutions, e-money institutions and, in general, any other issuer of the cards in scope | Issue cards of any kind |
| Final paragraph | Spanish branches of EU and third-country entities, and those entities operating in Spain under the freedom to provide services | For services, only to the extent they issue cards to persons or entities resident in Spain, or to Spanish permanent establishments of non-residents |
The last row is the one that matters for fintechs. An e-money institution licensed in another member state that issues cards to Spanish residents cross-border, with no Spanish branch, is a filer. The test for a passported issuer is the residence of the cardholder, not where the programme is run or where the BIN is sponsored.
Article 38 ter was inserted by article 2.4 of Real Decreto 253/2025 (BOE-A-2025-6599). It entered into force on 1 January 2026 and applies for the first time to the information returns for 2026.
2. Which cards, and the €25,000 exclusion
The scope is deliberately wide. Article 38 ter.1 covers cards of every type, physical or virtual, that offer cash, debit, deferred debit, credit or electronic-money functions, in any currency. A virtual card in a wallet, a prepaid e-money card and a corporate credit card are all in.
The only carve-out is a size test in article 38 ter.2, repeated in article 16 of the order. A card is excluded when both its total debits (cargos) and its total credits (abonos) recorded in the year are below €25,000. Read the conjunction carefully:
- Debits €18,000 and credits €19,500: both below €25,000, so the card is excluded.
- Debits €9,000 and credits €31,000: credits reach the threshold, so the card is reported, with all its figures.
- Debits €26,000 and credits €4,000 on a credit card: debits reach the threshold, so the card is reported.
The test runs per card, on the year’s totals. It is not a test per customer or per contract. Two cards under one contract are assessed separately.
3. What goes in the file: the Annex IV fields
Article 38 ter.3 lists the content in eight letters, (a) to (h). Annex IV to the order turns that into a message structure. The format and technical design are published on the AEAT’s electronic office under article 19. Annex IV organises the record like this:
| Block | Fields | Notes |
|---|---|---|
| Cabecera | Modelo, Ejercicio, Version; declarant name and NIF; contact phone and name | Schema version list L0 has one value, 1.0 |
| Declarado (repeating) | TipoComunicacion, IDRegistro | A0 new record, A1 modification (correcting a record error), A2 deletion. IDRegistro is up to 50 characters |
| Contrato | NumeroContrato; TitularContrato | The contract number the issuer formalised for the cards. The holder has a name, a Spanish NIF or a foreign ID (IDOtro), a date of birth for natural persons, and a country of residence |
| Tarjetadeclarada (repeating) | Numero (PAN), Tipo | PAN numeric up to 19 digits. Type list L6: 1 credit, 2 debit, 3 deferred debit, 4 e-money, 5 cash, 6 other |
| Declarado (per card) | TipoDeclarado and identity fields | List L4: 1 holder, 2 authorised, 3 beneficiary, 4 other |
| AbonosTarjeta / RecargasTarjeta | Count and amount of credits; count and amount of cash top-ups | Cash loads are shown separately from total credits |
| CargosTarjeta / GastosTarjeta / EfectivoTarjeta | Count and amount of debits; of payments at merchants; of cash withdrawals | Merchant spend and ATM cash are broken out from total debits |
| IDCuenta | IBAN, or Otro (Type + ID), and optional SWIFT | The account the card is issued against or where its activity is recorded. Where there is no IBAN, list L5 separates 1 a non-internal account from 2 an internal account of the entity |
Foreign identifiers use list L3: 02 VAT number, 03 passport, 04 tax identification number of the country of residence, 05 certificate of residence, 06 other supporting document. Article 38 ter.3(b) sets the order of preference. Give the Spanish tax number if there is one. Otherwise give the passport or a valid identity number from the person’s country of origin, with the issuing country.
Amounts are decimal (20,2). Counts are numeric up to nine digits. Country codes follow the list in annex II of Orden EHA/3496/2011.
4. Three worked scenarios
Scenario one — a passported prepaid programme. Facts: an e-money institution authorised in another member state issues virtual prepaid cards to Spanish residents under the freedom to provide services. It has no Spanish branch. Rule: the final paragraph of article 38 ter.1 brings it in for cards issued to Spanish residents. Article 38 ter.2 then removes every card below €25,000 on both sides. What the team does: it flags Spanish residence at card level from onboarding data and runs the two-sided threshold on each card’s 2026 totals. The e-money funding account goes in IDCuenta. Outcome: most low-value cards drop out. The file carries the high-load cards, with type 4 (e-money) and the cash top-up block completed where customers loaded cash at retail points.
Scenario two — corporate expense cards. Facts: a payment institution provides a Spanish SL with a business payment account and twelve employee debit cards. Two cards pass €25,000 in debits during the year. Rule: the contract holder is the SL (letter b). Each card’s holder and any authorised users are declared under letter (e). The threshold applies card by card. What the team does: it declares one contract with the SL as TitularContrato and two Tarjetadeclarada entries, each naming the employee as TipoDeclarado 1. Both point to the same IBAN. Outcome: ten cards are excluded. The same IBAN also appears in your modelo 196 file for the SL’s account, so the two returns must match.
Scenario three — a rejected record in February. Facts: the issuer submits in January 2027. The response message accepts most records but rejects some because the holder’s NIF does not match the name. Rule: article 18.2 of the order accepts only records with no ground for rejection. The response lists accepted and rejected records with the reason. Where at least one record is accepted, it includes a 16-character secure verification code (CSV) with the date and time. Rejected records must be corrected and filed again. What the team does: it fixes the identity data and resubmits those records as new submissions. For a record that was accepted but later proves wrong, it uses A1 or A2 against the original IDRegistro. Outcome: the CSV and response message are the evidence of filing, and the team stores them with the IDRegistro map.
5. Building the dataset now for a January 2027 filing
Modelo 174 is annual, but the data is a full-year aggregate. Most of the work is in 2026, not in January 2027:
- Accumulate six counters per card from 1 January 2026. These are credits, cash top-ups, debits, merchant payments and cash withdrawals, each with a count and an amount. Credits and debits are totals. The other three are subsets that Annex IV reports separately.
- Keep contract and card as separate keys. The file nests cards under contracts. A card replaced after loss gets a new PAN, and the regulation measures the threshold per card. The text does not say how a replacement PAN is aggregated with the old one. Pick a documented rule and check it against the AEAT’s technical documentation.
- Capture authorised users and beneficiaries as persons, not free text. Each needs a name, an identifier, a residence country and, for individuals, a date of birth.
- Resolve the account link. Where the card sits on an IBAN, use it. Where it draws on an internal ledger account with no IBAN, use the Otro block with type 1 or 2.
- Decide residence at card level for passported business. The obligation for services turns on Spanish residence. Store the residence date so you can explain a customer who moved during the year.
Filing follows articles 16 and 17 of Orden HAP/2194/2013, the general order for electronic filing of information returns. Article 18 of HAC/747/2025 disapplies article 16.2(c) and article 17.1(c) and (e) of that order. Final disposition 2 adds modelo 174 to the list of returns in article 1.3 of HAP/2194/2013.
6. How modelo 174 fits with 170, 196 and 171
Orden HAC/747/2025 is a package, and a firm that issues, acquires and keeps accounts will file most of it:
| Return | Side of the card | Frequency | First period |
|---|---|---|---|
| Modelo 174 (new) | Issuing: cards, holders, annual flows, linked account | Annual, 1–31 January | Financial year 2026, filed January 2027 |
| Modelo 170 | Acquiring: merchant collections by card and mobile-number payment | Monthly | January 2026, filed February 2026 |
| Modelo 196 | The account behind the card, with holders, authorised persons and beneficial owners | Monthly | January 2026, filed February 2026 |
| Modelo 171 | Cash deposits and withdrawals, and collections of documents | Annual (Orden EHA/98/2010 as amended) | Amended version applies from financial year 2026, filed January 2027 |
Final disposition 3 of the order sets these dates. It enters into force on 1 January 2026. It applies first to the January 2026 monthly returns for modelos 170 and 196, and to the 2026 annual returns for 171, 181 and 174, filed in January 2027.
A cash top-up at an agent or ATM can appear in more than one place. It shows in the RecargasTarjeta block of modelo 174 and may also appear in modelo 171, depending on how the operation is structured. Map each cash product to the returns it feeds before year-end, so the two figures can be explained if the AEAT compares them.
FAQ
When is the first modelo 174 due?
Between 1 and 31 January 2027, for the 2026 financial year. Article 17 of Orden HAC/747/2025 sets the January window, and final disposition 3 makes 2026 the first year.
Is there a minimum threshold?
Yes. Cards whose total debits and total credits for the year are both below €25,000 are excluded under article 38 ter.2 RGAT. If either total reaches €25,000, the card is reported.
Do virtual and prepaid cards count?
Yes. The article covers physical and virtual cards with cash, debit, deferred debit, credit or e-money functions, in any currency. Type 4 in list L6 is the e-money card.
We issue cross-border from another member state. Are we in scope?
Yes, for cards issued to persons or entities resident in Spain, or to Spanish permanent establishments of non-residents. Article 38 ter.1 names entities operating under the freedom to provide services on that basis.
Does modelo 174 replace modelo 170?
No. Modelo 170 covers acquiring, meaning collections by merchants. Modelo 174 covers issuing. A firm doing both files both.
How are errors corrected?
Rejected records are corrected and submitted again. A record that was accepted but is wrong goes back as A1 (modification) or A2 (deletion) against its original IDRegistro.
Which cardholders appear in the file?
The contract holder, and for each card its holder and any authorised persons or beneficiaries, each with an identifier, residence country and, for individuals, a date of birth.
7. What to do, today
- Confirm you are a filer by cardholder residence. Passported issuers are named in article 38 ter.1.
- Start the six per-card counters from 1 January 2026 if you have not. Rebuilding them from raw transactions in January 2027 is where errors come from.
- Apply the €25,000 test to both sides of each card. Store the result, so you can show why a card was left out.
- Use the same account identifiers as modelo 196. The same IBAN should appear the same way in both returns.
- Plan the January 2027 window now. It overlaps with modelo 171 and the December monthly returns for 170 and 196.
Related: Modelo 170 — Spain’s monthly card and mobile-payment return · Modelo 196 — Spain’s monthly account return · The Spanish reporting calendar
