What Hacienda Sees About Your Cards and Bank Accounts (2026): Modelo 174, 196 and Foreign Cards

From 2026, Spain’s tax agency receives far more data about how residents pay for things. Card issuers now file a yearly return on every card above a threshold. Banks and payment firms report accounts every month instead of once a year, and the net now reaches EU fintechs that serve Spain from abroad. If you live on the Costa on a UK pension, US savings or an EU salary and pay by card, the obvious question is whether Hacienda can see that spending, and whether money earned abroad and spent here will look like income you have hidden.

This guide sets out what each report contains and when it starts. It also covers where your particular card sits, what no report sends, and where the tax exposure actually is. The short answer is that Hacienda gets totals with no purchase detail. Spending is not taxable income, and the risk sits with the income that feeds the account.

Last verified: 28 September 2026.

The new card return: Modelo 174

Real Decreto 253/2025 added a new article 38 ter to Spain’s general tax management and inspection regulations. It obliges card issuers to file a yearly return on every type of card, physical or virtual, whether they work as debit, credit, deferred debit, prepaid or e-money, in any currency. The form is Modelo 174, approved by Orden HAC/747/2025. Issuers file it between 1 and 31 January for the previous year, so the first return, covering 2026, reaches Hacienda in January 2027.

Who has to file:

• Spanish banks and other credit institutions.
• Payment institutions, e-money institutions and any other card issuer.
• Spanish branches of banks from other EU countries or from outside the EU.
• EU entities that operate in Spain under libre prestación de servicios — free provision of services, the passport that lets an EU-licensed firm serve Spanish customers without a branch. They file only for cards issued to people resident in Spain.

For each card, the return gives:

• the contract number and the contract holder;
• the name, tax number, country of residence and date of birth of the cardholder and anyone authorised to use the card;
• the card number and type;
• the number and total of amounts credited to the card during the year, with cash top-ups shown separately;
• the number and total of charges, split between payments in shops and cash withdrawals;
• the IBAN of the account the card is linked to.

It carries no merchant names, no dates and no locations. Hacienda learns how much went through the card in a year and nothing about where it went.

The threshold is easy to misread. A card is left out only if its total charges and its total credits were each below 25,000 euros in the year. The two figures are not added together, and either one reaching 25,000 euros brings the card into the return. A card that took 24,000 euros of spending and received 26,000 euros of payments is reported.

Accounts: reported monthly since January 2026

The same decree rewrote the account return. Modelo 196 is now filed every month, starting with January 2026 data, which was filed in February 2026. It covers every kind of account, including those at payment and e-money institutions. It also covers EU firms operating in Spain under free provision, for accounts belonging to Spanish residents, and it absorbed the old separate return for non-residents’ accounts.

The return names the account holders and their beneficial owners. It also names the representatives, authorised signatories and anyone else with power over the account. Once a year, in the December return, it adds the balance at 31 December, the average balance for October to December, and the total paid in and out over the year.

Cash has its own channel. Deposits and withdrawals of cash over 3,000 euros are reported on Modelo 171, and from 2026 that includes EU firms operating in Spain when the customer is resident here. The same Orden HAC/747/2025 sets the first Modelo 171 on the new rules for 2026, filed in January 2027.

Where your card sits

Put the two returns together and each kind of card lands in a different place. This is our reading of the decree and the order.

• A card from a Spanish bank. It is on Modelo 174 once it crosses the 25,000-euro threshold, and its account is on Modelo 196 every month.
• A card from an EU bank or fintech that operates in Spain, through a Spanish branch or under free provision. It is treated like a Spanish card for a Spanish-resident cardholder. Whether a particular firm operates in Spain is a fact about that firm; the Banco de España keeps the public register.
• A card from an EU bank that does not operate in Spain. It is outside Modelo 174. Its home country sends Spain a yearly account report under the Common Reporting Standard, the international system tax authorities use to swap account data.
• A UK card. It is outside Modelo 174, because UK firms lost their EU passport when the Brexit transition ended in 2020. The account behind it still reaches Spain. HMRC sends a yearly Common Reporting Standard report with the balance at year end and the totals of interest, dividends and sale proceeds. From 2026 data, the UK’s updated rules add e-money institutions and some e-money products, with the first reports due in 2027.
• A US card. It is outside Modelo 174. The United States is not in the Common Reporting Standard. Under the 2013 FATCA agreement it sends Spain only deposit interest over 10 dollars and US-source income, and only for accounts the US bank has on file as belonging to a Spanish resident. It sends no balance.

What no report sends

None of these channels sends Spain your individual card purchases, from any country. The Spanish returns give yearly or monthly totals. The Common Reporting Standard gives balances and income, and it leaves out a credit card account that is in credit only because you overpaid it. FATCA gives interest and US income.

That is the bulk picture. Hacienda can still ask about a named person. Article 26 of the 2013 UK-Spain tax treaty obliges each country to exchange information that is “foreseeably relevant” to the other’s taxes. It also says a country may not refuse “solely because the information is held by a bank”. Our reading is that a Spanish inspection asking the UK about a specific resident can obtain that person’s UK bank records, card statements included. In the tribunal cases we read where card data mattered, it came from targeted inspections and information requests, not from any automatic feed.

Money sent by family is a separate question. Spain taxes a gift to the person who receives it, and in Andalucía a gift from a parent carries about 1% of the normal tax only when you declare it in time. Our guide to gift tax on money from family abroad covers the rules, the two-month deadline and the 2026 deed threshold.

Spending is not income

A Spanish tax resident is taxed on worldwide income. Article 2 of the income tax law covers all income, wherever it was produced. Spending is not income, though, and paying for your life here with money from abroad is not a taxable event. The questions that matter are about the money going into the account:

• Is the income declared? A pension, salary, rent, interest, dividends or a gain paid into a foreign account belongs on your declaración de la renta — annual income tax return in Spain, with relief for tax already paid abroad under the relevant treaty.
• Does the account belong on Modelo 720? Foreign accounts must be declared by 31 March when their combined balance at 31 December, or their combined average balance for October to December, is over 50,000 euros. After that, you file again when either figure rises by more than 20,000 euros. Accounts you can sign on count as well as accounts in your name.
• Does your lifestyle match your declared income? The Agencia Tributaria’s 2026 control plan lists gaps between people’s standard of living, their visible wealth and the income they declare as a line of work. It also names neobank accounts used to hide income or assets abroad.

This is where the card return matters. Modelo 174 does not tax anything, but from January 2027 it gives Hacienda a clean annual spending figure for every Spanish and EU-passported card over the threshold. If that figure runs well ahead of the income you declare, and nothing else explains it, it is the kind of mismatch the control plan describes. The fix has not changed. Declare the income and file the 720. Moving your spending to a UK card does not remove the income question.

Card data can work for you

Spending records cut both ways in residence disputes. In resolution 00/04045/2020 of 28 March 2023, Spain’s central tax tribunal accepted card payments made in physical shops as evidence of presence in the country. It also said online purchases prove nothing about where you were, and that someone else can use your card. If you ever need to show where you spent the year, card statements from shops are evidence you already hold.

If a letter arrives

Hacienda’s questions arrive in writing, as a requerimiento — formal request for information or as a proposed assessment, by post or in your electronic notifications mailbox. The deadline is printed on the letter, so read it the day it arrives and note exactly what it asks for. If the question is about foreign income or an unfiled 720, this is the point to bring in a gestor — licensed administrative and tax agent or a tax adviser who handles international cases.

The five-minute version

• From 2026, card issuers report yearly card totals to Hacienda on Modelo 174, with the first return in January 2027. The return carries no merchants, dates or places.
• A card is left out only if both its charges and its credits stayed below 25,000 euros in the year; the two are not added together.
• Spanish banks, Spanish branches of foreign banks and EU firms serving Spain under free provision all report. UK and US cards are outside the card return.
• UK accounts still reach Spain every year through the Common Reporting Standard, and UK e-money joins from 2026 data. US accounts send interest and US income. Hacienda can also ask the UK about a named person.
• Spending is not income. The exposure is undeclared income paid into the account, a missing Modelo 720, or a lifestyle well ahead of declared income.
• Card payments in shops can prove where you were, which helps in a residence dispute.

Related guides

• Living in Spain on a Foreign Credit Card (2026): What Hacienda Sees, Spanish Cards, Everyday Use and Car Hire
• Business and Personal Cards in Spain (2026): What Hacienda Sees for Autónomos, SL Owners and Directors of Foreign Companies
• Getting a Spanish Credit Card as a Resident (2026): Which Banks, What to Bring, and the Revolving Trap
• Keeping a UK, US or EU Credit Card After You Move to Spain (2026): What Changes, What It Costs, What It Cannot Do
• Car Hire Card Rules for Spain Residents (2026): Why Desks Refuse Cards, at Málaga and Back Home
• Cash Payment Rules in Spain: What Hacienda Can See (And What They’re Watching)
• Modelo 720 in Spain: The Overseas Asset Declaration Guide (2026)
• Tax Residency in Spain: Complete Guide for Expats (2026)
• Keeping a Non-EU Bank Account While Living in Spain: What CRD VI Changes on 11 January 2027, and What It Does Not
• Income Tax in Spain (IRPF): Rates, Deadlines & What Expats Actually Pay
• Missed a Government Notification in Spain? What Happens and How to Fix It

General information, not legal advice, current as of 28 September 2026. Primary sources: Real Decreto 253/2025 (BOE 2 April 2025), Orden HAC/747/2025 (BOE 15 July 2025), the Agencia Tributaria’s 2026 tax control plan (BOE-A-2026-5843), Ley 35/2006 art. 2, Directive 2014/107/EU, HMRC’s International Exchange of Information manual and its June 2025 impact note on the updated Common Reporting Standard, the UK-Spain double taxation convention of 14 March 2013, the Spain-US FATCA agreement of 2013, and TEAC resolution 00/04045/2020.