You hold Bitcoin on Binance, Ethereum on Kraken and some USDT on KuCoin. If the combined value exceeds €50,000 at 31 December, the Spanish tax agency wants to know about it. That is what Modelo 721 is for.
What is Modelo 721?
Modelo 721 is an informational return that must be filed by Spanish tax residents holding cryptocurrencies in the custody of a foreign provider.
It is not a tax. You pay nothing when you file it. You simply tell the Spanish tax agency what you hold and where you hold it.
It has been in force since 2023 (Royal Decree 249/2023) and is filed every year in the first quarter.
Who has to file Modelo 721?
You must file Modelo 721 if you meet all of these conditions:
- You are a Spanish tax resident (more than 183 days a year)
- You hold crypto on foreign exchanges or custodians
- The combined value exceeds €50,000 at 31 December
If you hold €30,000 on Binance and €25,000 on Kraken, that adds up to €55,000 → you have to file.
If your total is only €40,000 → you are under no obligation.
When is Modelo 721 filed?
| Tax year | Filing window |
|---|---|
| 2025 | 1 January - 31 March 2026 |
The window runs from 1 January to 31 March of the year following the tax year.
If you file after 31 March it counts as late filing and a penalty may follow.
Which exchanges count as foreign?
This is the key question. An exchange triggers Modelo 721 if it does not report to the Spanish tax agency (it does not file Modelo 172 and Modelo 173).
Important: many exchanges are registered with the Bank of Spain yet operate from abroad and do not report to the Spanish tax agency. Being “registered” does not mean you are off the hook.
Exchanges that DO require Modelo 721
These exchanges do not report to the Spanish tax agency (data updated to December 2025):
| Exchange | Country | Modelo 721? |
|---|---|---|
| Coinbase | Ireland | Yes |
| Kraken | Ireland | Yes |
| Crypto.com | Malta | Yes |
| Bitstamp | Luxembourg | Yes |
| Bitpanda | Austria | Yes |
| eToro | Cyprus | Yes |
| Gemini | Ireland | Yes |
| Bitvavo | Netherlands | Yes |
| Trade Republic | Germany | Yes |
| Revolut | United Kingdom | Yes |
| Kriptomat | Estonia | Yes |
| WhiteBit | Lithuania | Yes |
| YouHodler | Switzerland | Yes |
| KuCoin | Seychelles | Yes |
| Bybit | Dubai | Yes |
| OKX | Seychelles | Yes |
Exchanges that do NOT require Modelo 721
These exchanges do report to the Spanish tax agency (they have a Spanish tax number and file Modelo 172 and Modelo 173):
| Exchange | Modelo 721? |
|---|---|
| Bit2Me | No |
| Criptan | No |
| Bitnovo | No |
| Bitbase | No |
| Binance Spain (Spanish entity) | No |
If all your crypto sits on Spanish exchanges that report, you do not have to file the 721.
Do cold wallets count towards Modelo 721?
No. Non-custodial wallets (Ledger, Trezor, Metamask) do not count towards Modelo 721.
The 721 only applies to crypto held by third-party custodians (exchanges). If you control the private keys, there is nothing to report.
What information has to be declared?
For every foreign exchange you must report:
- Identification of the exchange: full name, country, registered address
- Type of cryptocurrency: BTC, ETH, USDT, etc. (one line for each)
- Balance at 31 December: number of units and valuation in euros
- Average balance in the fourth quarter: optional but advisable
The valuation in euros is made at the exchange rate of 31 December.
What if I already filed the 721 last year?
You only have to file again if:
- The combined value has increased by more than €20,000 compared with the last return
- You have opened an account on a new foreign exchange
- You have closed a position you previously declared
If your portfolio is worth the same (or less), you do not have to file again.
Penalties for not filing Modelo 721
| Infringement | Penalty |
|---|---|
| Failure to file | €5,000 per omitted item (minimum €10,000) |
| Incorrect or incomplete data | €150 per item |
| Late filing (with no formal demand) | €300 |
The 721 penalties are very steep. Not filing can end up costing more than any tax you might owe.
Frequently asked questions
Do I have to file the 721 if I have not sold anything?
Yes. Modelo 721 is informational. It declares what you hold, not what you have earned. Whether you have sold or not makes no difference.
What if I hold less than €50,000?
You are under no obligation to file. The threshold is €50,000 combined across all foreign exchanges.
Is Binance a foreign exchange?
It depends. Binance.com (the global platform based in the Cayman Islands) does require Modelo 721. Binance Spain, however (the entity with Spanish tax number B01929306), does report to the Spanish tax agency and does not require the 721. Check which entity holds your account.
Can I file late?
Yes, but with a €300 penalty if you do so voluntarily. If the Spanish tax agency issues a formal demand first, the penalty rises to €5,000 per item.
Does the Spanish tax agency know I hold crypto on Binance?
Yes. Thanks to the DAC8 Directive and international agreements, exchanges report information on their users to the tax authorities. The Spanish tax agency cross-checks that data against your return.
Summary
- What it is: an informational return for crypto on foreign exchanges
- Who: Spanish tax residents with more than €50,000
- When: from 1 January to 31 March
- Where: the AEAT electronic office
- Penalties: up to €5,000 per undeclared item
Need help with your Modelo 721?
At colvence we prepare your Modelo 721 with all the right figures. We download your history, calculate the balances and file it for you.
Víctor Lázaro
Tax adviser, colvence.com
