Frequently asked questions about form 196 (fiscal year 2026 and subsequent years)

No. The beneficial owners are informed about all those declared, whatever their status.

The field “Exception” must be reported with the value “L17- Exception identification=1” when, in accordance with the provisions of article 4.2 of Law 10/2010, of April 28, there is no obligation to identify the beneficial owner.

In relation to the provisions of Article 4.2 b) of Law 10/2010, of April 28, those entities that are listed on a regulated market under the terms provided for in Article 3.6.a) are not obliged to identify the beneficial owner. i) of Directive (EU) 2015/849 and in Article 9.4 of the Regulation of Law 10/2010, of April 28, on the prevention of money laundering and the financing of terrorism, approved by Royal Decree 304/2014, of May 5.

It must be completed for declared minors or persons with disabilities, both residents and non-residents.

Yes, in form 196, non-resident accounts, with and without a permanent establishment, will be reported. The new model 196 integrates the previous informative declaration on accounts of non-residents without a permanent establishment (model 291).

*If the declarant is an entity that operates in Spain under the freedom to provide services regime, see question in section 7 entitled "On which accounts must entities under the Freedom to Provide Services (LPS) report?".

The data of the declarant will be reported in a single record with its corresponding IDRegistro, using the declarant key L3 = T (full ownership holder), and the account data.

Since it is not an error, the record will be sent with Communication Type L1= A0 (Record Registration). It should be noted that a registration cannot be submitted in a period for a record that has already been declared as registered in that same period. In other words, if a name and surname were declared in January, and subsequently changed, the new name and surname must be declared in February with code A0.

In the event that the declarant is identified with a NIF, it is remembered that the system for identifying natural persons requires a validation between NIF and name and surnames. Therefore, for the new identification to be accepted, the name and surname must have been previously modified in the census.

To minimize identification errors and ensure correct identification of those declared, please note that, for the purpose of pre-validating tax identification numbers (NIFs), a tax identification assistance service is available on the AEAT website (common, moreover, to the informative declarations to be submitted by taxpayers), at the following link:

Tax Agency: Tax identification

Yes, it is a required field regardless of the declared key. This refers to the tax status of the person declared (owner, authorized person, etc.).

The value “Residence indicator-L13” = “1” will be entered if the declarant is a resident or a non-resident with a permanent establishment.

The value “Residence indicator-L13” = “2” will be entered if the declarant is a non-resident without a permanent establishment.

Tax Agency: Tax identification

If you have a NIF assigned by the Spanish Tax Administration, you will report this NIF in the NIF field, and the TIN in the TIN field. If you do not have a Spanish NIF, you will only report the TIN in the IDOtro field.

To identify a non-resident, the identification types used in the country of residence will be used, and their corresponding values are:

• 02: NIF-VAT

• 03: Passport

• 04: Official ID issued by the country or territory of residence

• 05: Residence certificate

• 06: Other documentary proof

The declaration for the month in which the revocation occurs will include the date of revocation, without the need to report said authorized person in subsequent declarations. Nor is it necessary to report authorizations revoked throughout the year in the December declaration.