Model 721 for Cryptocurrencies in Spain 2025: Thresholds, Deadlines, and How to File
Informational content only; not tax or legal advice.
Why This Matters
If you keep cryptocurrency with a custodian outside Spain (on a foreign exchange/provider), you may have to report it to the Spanish Tax Agency (AEAT) via Model 721. Below you’ll find who is required to file, when (deadlines), what data is needed, and how to prepare without unnecessary errors.
What Is Model 721 and Who Must File It?
Model 721 is an informational return for virtual currencies held abroad (in custodial accounts with non-resident providers). Spanish tax residents (individuals and entities) must file if they are owners/beneficiaries/authorized persons or otherwise have disposal rights over coins that, as of December 31, are held with a foreign provider.
Important: this is specifically about custodial holdings with third parties. Self-custody (autocustodia)—where you control the keys—is not reportable under Model 721.
When Is Crypto Considered “Located Abroad”?
When the provider holding your keys (exchange/custodian) is not a Spanish resident and is not required to report in Spain. To understand a provider’s status, look at its jurisdiction/registrations.
Threshold, Deadlines, and Periodicity
Filing threshold: a €50,000 aggregate balance on December 31 across all virtual currencies held abroad. If you do not exceed the threshold, you do not file; if you exceed it, you report all positions.
Filing window: January 1 to March 31 of the year following the tax year.
Refiling: you file again only if your aggregate balance increases by more than €20,000 compared to the last return you filed, or if you cease to be obliged (e.g., you close positions)—in that case, you report the extinction (cessation) of the obligation for the year in question.
What Do You Report on Model 721?
Information is provided for each coin separately:
- Identification of each virtual currency;
- Balances as of December 31 and their value in euros;
- Custodian/provider details (legal name, country, contact/website).
Step-by-step preparation (to file without stress)
Before logging into AEAT’s e-office:
- List all foreign custodians/exchanges where you had a year-end balance on 12/31.
- Gather balances by coin as of 12/31 and the EUR conversion (save screenshots and/or CSVs).
- Note custodian details: legal name, country, official website/support.
- Ensure traceability: account IDs, CSV movement logs, screenshots of final year-end balances.
Filing with AEAT:
Find the Modelo 721 procedure on the tax agency’s website, follow the on-screen steps, enter your pre-collected data, and upload supporting documents if requested.
Document Checklist (for AEAT and Your Bank)
- CSV exports of year-end balances and transactions (per provider).
- Screenshots of final balances by coin and in EUR.
- Custodian card: legal name and country.
- Evidence of changes: account openings/closures, full disposals, transfers—useful to document the extinction of the obligation.
How It Relates to Other Forms: 714 (Wealth Tax) and MiCA/CNMV
Model 714 (Impuesto sobre el Patrimonio/Wealth Tax) is a separate obligation for taxpayers liable for the wealth tax. Check regional thresholds and rules.
MiCA and the provider list (CNMV): Spain is operating under a MiCA transition period. The CNMV publishes information about providers. This can affect who reports in Spain, but it does not remove your Model 721 obligation if your assets are custodially held with a non-resident provider.
FAQ
Does Model 721 apply to Spanish exchanges?
Resident providers report in Spain themselves; Model 721 targets foreign custody.
Do I have to file Model 721 every year?
Only if your aggregate balance rises by more than €20,000 versus your last filing, or if you terminate the obligation (sale/closure).
What happens if I fail to file Model 721 when required?
You may face penalties and requests for information from AEAT. Minimize risk by preparing solid evidence and filing on time.
Conclusion
In 2025, Model 721 is a routine requirement for investors with custodial crypto held outside Spain. Remember three pillars: the €50,000 year-end threshold, the Jan 1–Mar 31 filing window, and per-coin, per-custodian reporting. With a well-organized evidence pack (CSVs, screenshots, provider details), filing becomes a straightforward process.
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