The intensification of the economic globalizationcombined with the accelerated development of Technological and digital solutions applied to the financial sector, has created an environment conducive to the emergence of new financial agents or intermediaries and payment methods.Within the framework of the European Union, regulatory initiatives aimed at harmonizing financial services have made it easier for payment entities and electronic money entities to operate in Spain, even from other Member States or third countries, under the freedom to provide services and without needing a physical structure in national territory. In Spain, this evolution has been accompanied by the consolidation of alternative payment instruments, such as payment accounts, cards in their various forms, and mobile phone-based systems, which have demonstrated remarkable efficiency in terms of speed, availability, and operational simplification of financial transactions.

In it scope of money laundering preventionThe relevance acquired by these new agents and payment systems justified their inclusion in the scope of Law 10/2010, of April 28, on the prevention of money laundering and the financing of terrorism. From this inclusion onwards, payment entities and electronic money entities must comply with the due diligence, formal identification and information communication obligations established in the law and its implementing regulations. These requirements affect both resident entities and non-resident entities that operate through branches or provide services without a permanent establishment in Spain. Among the most significant obligations is the periodic provision of information to the Financial Ownership File, which expanded its scope to include, in addition to traditional bank accounts, payment accounts and other similar instruments. This file requires monthly communication of beneficial owners and other essential information for financial traceability.

In this context, it was evident that need to update part of the national financial reporting obligations to allow the AEAT database to have the financial data available at the appropriate frequency for its use and management.  To this end, the Royal Decree 253/2025, of April 1 (BOE 2 April) addresses a reform of the General Regulation of the actions and procedures of tax management and inspection and development of the common rules of the procedures for the application of taxes, approved by Royal Decree 1065/2007, of 27 July, specifically of its articles 37, 38 and 38 bis, with the purpose of adjusting the tax framework to the operational reality of the new means of payment and the new financial agents not included in the current subjective scope of these obligations. This update aims to strengthen the fight against tax fraud, increase the effectiveness of collection procedures, and improve the assistance services provided to taxpayers. The implementation of these changes at the level of declaration models was articulated through the Order HAC/747/2025, of June 27 (Official State Gazette, July 15).

One of the most relevant changes consists of the expansion of the subjective scope of those required to report. Following the reform, payment entities and electronic money entities are expressly included as being required to provide information, along with traditional financial entities.. This obligation extends to all entities defined in the aforementioned articles that develop services in Spain, including foreign entities that operate without a permanent establishment, provided that such services are directed to natural or legal persons resident or permanent establishments of non-residents in Spanish territory. This expansion guarantees equal treatment from both a tax and a jurisdictional perspective.  

As regards the objective scope, the obligation provided for in article 37 of the RGAT, corresponding to model 196, now includes a broader set of financial products, encompassing all types of accounts, both traditional bank accounts and non-bank accounts, current accounts, savings accounts, time deposits, credit accounts, payment accounts and any other accounts regardless of the modality or name they adopt, even if there is no remuneration, withholding or payment on account.

Article 38 bis, corresponding to model 170, is redefined to cover any type of card, with physical or virtual support, that offers cash, debit, deferred debit, credit and electronic money functions, as well as systems that operate through mobile phone numbers, used in the management of collections by entrepreneurs and professionals. This update to the information reflects the evolution of electronic commerce and especially electronic or digital payments.  It should be emphasized that this information will only be provided regarding payments received by business owners and professionals. Therefore, for the system of collections through mobile phone numbers, currently in Spain and mainly through Bizum, the reporting entities will only report those operations in which the recipient has a non-private contract (Bizum operations between individuals (C2C) are excluded).

In addition, the frequency of information delivery is modified: Both the information on accounts and that relating to payment systems using cards or mobile phones changes from annual to monthly, which allows the Administration to have more current and useful data for the performance of its functions.  The €3,000 threshold that limited the reporting obligation regarding card payments is also eliminated, in order to avoid the loss of relevant information. However, in the case of accounts, the obligation to communicate economic data remains only in the last monthly period of the financial year.

This set of modifications also updates the subjective scope of the informative declarations of model 171, "Annual informative declaration of taxes, dispositions of funds and collections of any document", and of model 181 "Informative declaration of loans and credits, and financial operations related to real estate". The format of this latest model is also updated, becoming XML.

Finally, a new article 38 ter is incorporated which introduces a specific annual reporting obligation on transactions carried out with any type of card. This obligation includes the total annual amount of payments, charges, top-ups, cash withdrawals and expenses made at establishments. Only cards whose annual transaction volume, including charges and credits, does not exceed 25,000 euros are excluded, which allows the information effort to be focused on those cards that may have a greater impact on tax control.

Overall, the reform aims to adapt tax regulations to a rapidly evolving financial ecosystem, ensuring that the Administration has sufficiently detailed, periodic and comprehensive information to effectively address new challenges in tax fraud, collection efficiency and taxpayer assistance. Starting in February 2026, information corresponding to the new monthly models 196 and 170 will begin to be received, and that is when work can begin with this new database.

With the aim of disseminating knowledge of these updates, information activities have been carried out consisting of sending informational communications, an informative webinar has been given and the corresponding information has been published. Frequently asked questions have also been prepared, based especially on the questions received at the seminar, which will be published on the website. From a technical point of view, both the technical documentation and external testing services have been available for months.