Modelo 196 is monthly now — what changed in 2026
One of the largest changes to Spanish information reporting in years happened quietly: modelo 196 stopped being an annual return. Orden HAC/747/2025 of 27 June 2025 approved a new modelo 196 — a declaración informativa mensual of accounts in all classes of financial institutions, carrying the annual summary of withholdings alongside it. It applies for the first time to the January 2026 declaration, filed in February 2026, and it repeals the annual model approved by Orden EHA/3300/2008. If your Spanish reporting calendar still shows one modelo 196 entry a year, it is twelve entries short.
1. Who files — and the two limbs that catch foreign firms
The obliged population is broader than “banks”, and two of its four limbs are the reason this page belongs on a payments site:
| # | Obliged party |
|---|---|
| 1 | Credit institutions and other entities which, under the rules in force, engage in banking or credit business |
| 2 | Payment institutions and electronic money institutions |
| 3 | Branches situated in Spanish territory of entities in categories 1 and 2 from other EU member states or from third countries |
| 4 | Foreign entities operating in Spain under the freedom to provide services, in respect of accounts held by Spanish residents |
The scope also differs by entity type. Credit institutions and entities in banking or credit business report all accounts; payment institutions and e-money institutions report the accounts they manage.
2. What actually changed
Three changes matter operationally, and they compound:
- Frequency. The return moves from annual to monthly, filed during the calendar month following the month to which it refers.
- Consolidation of a second return. The new model integrates information on non-residents that was previously reported through modelo 291. One pipeline now serves what used to be two.
- Repeal of the old model. The annual modelo 196 approved by Orden EHA/3300/2008 is repealed, so there is no fallback to the prior format.
The frequency change is not simply “the same file, twelve times”. An annual return can be assembled once, reconciled against the year-end position and corrected before filing. A monthly return has to be produced by a process that runs unattended, which changes the control design more than it changes the data.
3. How the return is actually created
The build has four stages, and the difficulty is concentrated in the second:
| Stage | What happens | Where it breaks |
|---|---|---|
| Population | Identify the accounts in scope for the month — for a PI or EMI, the accounts it manages | Deciding what counts as an account you “manage” in a pooled or ledger-based product |
| Identification | Attach the holder’s tax identification data, and the authorised persons | Missing or unvalidated Spanish tax identifiers on customers onboarded before the obligation applied |
| Balances and amounts | Produce the balance and remuneration data the model requires | Period-end conventions, and accounts opened or closed mid-month |
| Validation and filing | Format, validate and submit through the tax authority’s channel | Rejections on identifier format rather than on substance |
4. A worked case
Facts: an e-money institution licensed in another member state serves Spanish resident customers cross-border under the freedom to provide services. It has no Spanish branch, and its Spanish reporting inventory lists only the returns tied to establishment.
What the rule says: limb 4 of the obliged-party list covers foreign entities operating in Spain under the freedom to provide services in respect of accounts held by Spanish residents. Absence of a branch does not remove the obligation, and the return is now monthly.
What the practitioner does: establishes a Spanish-resident flag as a maintained customer attribute rather than a derived one, audits tax identification coverage across that population before the first filing rather than after the first rejection, and builds the return as a scheduled monthly job with a reconciliation to the account ledger — because a manual monthly return is a control failure waiting for a holiday period.
Sequencing note: because the model also absorbs what was reported through modelo 291, a firm that filed both should map the old fields across before decommissioning either pipeline, and should keep the historical extracts available for any correction to a period filed under the previous regime.
FAQ
Does modelo 196 apply to payment and e-money institutions?
Yes — they are named expressly in the obliged-party list, and report the accounts they manage.
Do we file if we have no establishment in Spain?
Foreign entities operating in Spain under the freedom to provide services are covered in respect of accounts held by Spanish residents, so the absence of a branch is not determinative.
When did the monthly cycle start?
It applies for the first time to the declaration for January 2026, filed in February 2026, under Orden HAC/747/2025.
What happened to modelo 291?
Information on non-residents previously reported there is integrated into the new modelo 196.
Related: The Spanish reporting calendar · The FTF account-ownership register · Spain’s crypto information returns
