Overview of the changes
Order HAC/747/2025 introduced revised Models 196 and 170 with effect from 1 January 2026. Both models must be filed electronically in AEAT‑specified formats and are due during the calendar month following the month to which they relate, with the first live submissions made in February 2026 for January 2026 data. The expanded reporting regime affects a broader range of entities than the previous rules, including many organisations that may not previously have been affected.
Which organisations are now in scope
The new reporting obligations apply to a wide set of financial institutions and payment providers active in Spain. These include banks, credit institutions, payment institutions, electronic money institutions and their Spanish branches, as well as entities that hold accounts for residents or permanent establishments in Spain or provide card and mobile‑linked payment services to businesses operating in the Spanish market.
In practice, this means that groups with Spanish‑licensed entities, Spanish branches of non‑Spanish institutions or cross‑border payment operations into Spain may fall within scope even if their primary booking centre is elsewhere. Overall responsibility for these obligations typically sits with senior finance and compliance leadership, supported by relevant operational and IT teams where customer, account and transaction data is held in multiple systems. These stakeholders need clear visibility of which entities are affected, what must be reported and how the new process integrates with existing reporting cycles.
Model 196
Model 196 focuses on accounts held in financial institutions and related entities, capturing information about accounts opened or managed for residents and permanent establishments in Spain, as well as certain non‑resident accounts. Reporting is monthly, with institutions required to submit structured data on the accounts within scope, and an enhanced year‑end view. The model is designed to give the tax authorities a consistent view of account relationships and movements across all types of institutions, banks and non‑banks alike, which in turn increases expectations around data quality, completeness and timely updates.
Model 170
Model 170 focuses on payment flows rather than accounts, capturing monthly information on transactions carried out by businesses and professionals that use card-based collection systems and payments linked to mobile phone numbers. Entities that provide these payment services must submit detailed transaction data in line with the content defined for Model 170, covering collections processed for their merchant clients via any type of card and through mobile-associated payment channels. The aim is to give AEAT a clear view of collections managed through card and mobile infrastructure in Spain, complementing the account information reported via Model 196 and increasing transparency over domestic and cross-border payment activity.
Together, the two models therefore address different but connected dimensions of the same landscape: Model 196 looks at who holds which accounts and how these accounts move over time, while Model 170 focuses on how businesses and professionals receive payments through card and mobile channels. As a result, a single group may need to comply with one or both models depending on whether it holds accounts, processes payment collections, or performs both functions within its Spanish footprint.
How to comply with the reporting requirements
Given the monthly frequency and technical nature of the obligations, organisations need a structured approach that combines accurate interpretation of the rules with solid data and process foundations that will require coordinated action across tax, finance, IT, data and compliance teams. There are three broad delivery models typically considered: in‑house, via existing advisers, or using a specialised solution.
In‑house reporting
- Suitable where the organisation already has mature tax reporting infrastructure and strong IT support.
- Requires building or enhancing internal engines to generate the AEAT‑compliant electronic files, manage error handling and maintain up‑to‑date schema changes.
Accountant or tax adviser
- Works well for smaller institutions or those with limited internal tax capacity.
- The adviser interprets the legislation, prepares the monthly files from agreed data feeds and manages submissions and corrections on behalf of the entity.
Specialist solution provider, such as Tax Desk
- Suitable for institutions who want reliability and certainty. A dedicated solution can support the extraction, transformation and validation of data required for Models 196 and 170, using the detailed specifications in the Order and its annexes as the reference framework.
- This can help standardise monthly processes, reduce manual intervention and support consistent compliance across multiple Spanish entities and reporting models.
What are the challenges
For many organisations, the main challenges are not only technical but also operational. Account, customer and payment data may be distributed across multiple platforms, entities and geographies, requiring coordinated input from tax, finance, IT, data and compliance teams to build a repeatable process that meets the new standards. Institutions must ensure that their systems can capture all mandatory data points, keep documentation available for the applicable statute of limitations period and adapt quickly to any future updates to AEAT technical specifications.
Why financial institutions and PSPs choose Tax Desk
As a specialist financial solution provider, we work with firms across CESOP, Italian financial reporting and Spanish reporting. Tax Desk can support your company with impact assessments, operational design and an end‑to‑end managed reporting service for Spanish Models 196 and 170. Our solutions simplify day‑to‑day operations while maintaining full alignment with current Spanish regulatory requirements.
If you would like to understand how these Spanish regulatory reporting requirements apply to your business, our specialists are available to help.
We can confirm applicability, explain reporting obligations and outline the appropriate compliance framework based on your activities. https://www.taxdesk.com/services/spanish-compliance/
