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. Real Decreto 253/2025 rewrote article 37 of the Spanish tax procedure regulation (RGAT, Real Decreto 1065/2007) from 1 January 2026, and Orden HAC/747/2025 of 27 June 2025 approved a new modelo 196 to carry it: a declaración informativa mensual of accounts in all classes of financial institutions, with the annual summary of withholdings folded in. It applies for the first time to the January 2026 declaration, filed in February 2026. It repeals the annual model approved by Orden EHA/3300/2008 and absorbs modelo 291. It also adds beneficial owners to every account record. If your Spanish reporting calendar still shows one modelo 196 entry a year, it is eleven entries short.

1. Who files — and the two limbs that catch foreign firms

Article 2 of the order points to article 37.1 RGAT, which sets four limbs. Article 2.2 of the order adds the Banco de España and the registered entities holding non-resident accounts in Spain.

Firms that scoped their Spanish obligations around “do we have an establishment” will have concluded, wrongly, that modelo 196 does not reach them. One carve-out works the other way. For accounts in establishments outside Spain, there is no duty to report non-residents without a Spanish permanent establishment (art. 37.1, third paragraph).

The account concept is wide. Article 37.2 covers all kinds of accounts, banking or not, and expressly lists payment accounts, whatever they are called and even if they pay no interest. The type list in Annex I has separate codes for payment accounts (7) and e-money accounts (8).

2. What actually changed

Five changes matter operationally, and they compound:

• Frequency. Monthly, filed during the calendar month after the month declared (art. 5 of the order).
• Full refresh every month. Annex I says each monthly file covers all reportable information, sent as new records (“alta”), even if it was reported the month before. Modification and deletion keys are only for correcting records sent in error.
• Beneficial owners on every record. Article 37.2(b) now requires the titulares reales under article 4 of Ley 10/2010, alongside holders, representatives, authorised persons and beneficiaries.
• December carries the money. Balances at 31 December, the average balance for the fourth quarter, total annual debits and credits, the correspondence address, the dormancy flag, and income and withholdings go only in the period-12 file (art. 3.2 of the order).
• Modelo 291 absorbed. Non-resident account information moves into modelo 196, and modelo 291 disappears for later periods.

The frequency change is not “the same file, twelve times”. Months 1 to 11 are identity-and-population files: who held, was authorised on or benefited from which account at any moment in the month. Month 12 adds the financial layer for the whole year. Your January process and your December process are different builds.

3. The fields that decide whether a record is accepted

Annex I of Orden HAC/747/2025 defines the message. These are the fields that drive most of the build effort for a payment or e-money institution:

For non-residents without a permanent establishment, the record also needs the foreign TIN where the country issues one, date and place of birth, and the type of non-residence evidence (keys 1 to 6). Withholdings on those accounts do not go in modelo 196; they go in modelo 296.

4. How the return is actually created

The build has four stages, and the difficulty is concentrated in the second:

Filing follows the partial-acceptance rule in article 18.2 of the order. Clean records are accepted, rejected records come back with a reason, and if at least one record is accepted the response carries a 16-character secure verification code (CSV) with the date and time. Treat each month as a set of record statuses, not a single pass or fail.

5. Worked cases

Scenario 1 — a passported EMI with no Spanish branch.

Facts: an e-money institution licensed in another member state serves Spanish-resident customers under the freedom to provide services. Its Spanish reporting inventory lists only returns tied to an establishment.

What the rule says: limb 4 covers entities operating in Spain under the freedom to provide services, for accounts of Spanish residents. The return is monthly.

What the practitioner does: makes Spanish residence a maintained customer attribute, not a derived one. Audits NIF coverage across that population before the first filing, not after the first rejection. Builds the return as a scheduled monthly job reconciled to the account ledger. Uses the NoObligado key 2 only where article 28.3 RGAT genuinely applies, not as a way to clear a backlog.

Scenario 2 — a business account whose beneficial owners sit in the KYB tool.

Facts: a payment institution holds 4,000 Spanish SME accounts. Beneficial owners were captured during onboarding in a KYB system, as names and ownership percentages, with identity documents stored as images.

What the rule says: unless the holder is exempt under article 4 of Ley 10/2010 (Excepcion = 1), every record needs its beneficial owners with name and NIF, or a foreign identifier with type, date and place of birth for non-residents.

What the practitioner does: extracts beneficial-owner NIFs from the documents into structured fields. Adds the Excepcion decision as a stored attribute set by compliance, not inferred at run time. Schedules a refresh so a change in ownership reaches the next monthly file, because the order asks for persons who held the role “at any moment” of the period.

Scenario 3 — a December co-holder account.

Facts: a joint e-money account has two holders and closes a year with €3,200 at 31 December. It earned no interest.

What the rule says: article 4 of the order says balances and turnover are not split between holders. Each holder’s record carries the full account balance and totals. Income, if any, would be split by documented share, or equally without one.

What the practitioner does: reports two records in period 12, each with €3,200, the Q4 average and full annual turnover, and no RendmDinerarios block because there is no income. The December job reads balances at account level and then fans them out per declared person — the reverse of the income logic.

Sequencing note: firms that filed both modelo 196 and modelo 291 should map the old fields across before decommissioning either pipeline. The old orders still govern corrections to periods before 2026.

6. The returns around it

Orden HAC/747/2025 also approved the monthly modelo 170 (merchant collections by card and mobile-number payments) and a new annual modelo 174 for all card types, excluding cards under €25,000 of both annual debits and annual credits. It approved a new modelo 181 and amended modelo 171. An issuer-acquirer can touch four of these returns from one account master, so the account identifier should be the same in each.

FAQ

7. What to do, today

• Split the build in two. A monthly population-and-identity job, and a December job that adds balances, turnover and income.
• Feed beneficial owners from KYB as structured data. Names in free text will not pass validation.
• Store ClaveAlta events. Opening, closing and residence changes need dates, not a month-end snapshot.
• Keep the CSV and the record-level status for every month. Partial acceptance means some records stay open until resubmitted.
• Reconcile against modelo 170 and 174. The same account should carry the same identifier in every return.

Related: The Spanish reporting calendar · The FTF account-ownership register · Spain’s crypto information returns · Modelo 289 — Spain’s annual CRS account return · Modelo 290 — Spain’s FATCA account return · Modelo 170 — Spain’s monthly card and mobile-payment return · Modelo 174 — Spain’s annual card-issuer return