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

The criterion for determining whether an entity is required to submit the declaration is whether the entity is registered with the Bank of Spain as an entity authorized to operate in the Freedom to Provide Services or in the Register of the European Banking Authority (EBA).

Form 196 must include all accounts opened in the course of the activity for which the entity in LPS has been authorized.

Therefore, entities in LPS will report accounts in which the holder, bare owner or beneficiary is a resident or non-resident with a permanent establishment.

To determine the residence of its clients, the entity may use the due diligence procedures of CRS/DAC2, those derived from anti-money laundering obligations or any other regulations that may be applicable to them.

No, the type of accounts to be reported is that included in key L8 of Annex I of Order HAC747/2025, of June 27 (BOE of July 15).

The submission may be made by the taxpayer, an authorized representative or a social collaborator, who must have a recognized electronic certificate.

Applications that send information to web services must authenticate with the client's electronic certificate or qualified seal certificate.