Modelo 721 explained: who must file, deadlines and fines
Quick answer: Any Spanish tax resident who held more than €50,000 in crypto on non-Spanish exchanges on December 31 must file Modelo 721. The window is January 1 to March 31 of the following year. Missing the deadline triggers a €300 minimum fine.
"I have money on Binance, Coinbase and a hardware wallet. I don't know if I'm required to file Modelo 721 or which accounts I need to include."
Modelo 721 was created by Law 11/2021 and definitively approved for its first filing in 2024 (for fiscal year 2023). It is the "crypto" version of the classic Modelo 720 covering foreign bank accounts. Its purpose is informational: Hacienda wants visibility over crypto wealth held outside its direct jurisdiction.
The rule is simple in theory but nuanced in practice. You are required if the combined value of your holdings on non-Spanish exchanges exceeds €50,000 on December 31. The threshold is global, not per exchange: €30,000 on Binance + €25,000 on Kraken = €55,000, so you file. €40,000 on Coinbase alone means you don't.
One critical nuance: self-custody wallets (Ledger, Trezor, non-custodial MetaMask) are NOT included in Modelo 721. Only balances where a third party custodies for you count. It's an indirect incentive toward self-custody that many taxpayers overlook.
Step-by-step guide
- 1
Determine whether you are required
Sum the EUR-equivalent balances (at the 31/12 exchange rate) across all your non-Spanish exchanges. If the total exceeds €50,000, you are required to file. If lower, no Modelo 721 for that year.
- 2
Identify which platforms count as "non-resident"
Binance (Cayman), Kraken (US), Coinbase (US), Bybit (UAE), OKX (Seychelles), Bitfinex and most large names are NON-RESIDENT. Bit2Me, Binance Spain and others with a Spanish NIF ARE resident and do not count toward 721.
- 3
Collect required data per platform
Per platform: name, tax ID (if any), country, total balance in EUR on 31/12, and per-crypto breakdown (name, units, EUR value). Price comes from the exchange itself or the official year-end rate.
- 4
File electronically before March 31
File with digital certificate, electronic DNI or Cl@ve PIN via the AEAT electronic office under "All procedures > Taxes > Informational returns > Modelo 721".
- 5
Check whether you need to file again next year
The obligation re-triggers only when (a) new venues are added/removed, (b) a platform's value rises by more than €20,000 vs the last filed return, or (c) you transfer all balances from a platform. Without material changes, you don't re-file.
Included calculator
Spanish crypto capital-gains simulator
IRPF 2025-2026 savings-base brackets. Enter your buy price, sell price and quantity.
Total sale
€90.000
Capital gain
€60.000
Estimated tax
€12.680
Bracket breakdown:
| Bracket (EUR) | Taxed | Rate | Tax |
|---|---|---|---|
| 0-6000 | €6000 | 19% | €1140 |
| 6000-50.000 | €44.000 | 21% | €9240 |
| 50.000-200.000 | €10.000 | 23% | €2300 |
Effective rate: 21.13% · Net after tax: €77.320
Estimate only — not tax advice. Assumes FIFO cost basis and full IRPF savings base. Regional variations may apply for Basque Country and Navarra.
Key takeaways
- Threshold: €50,000 combined on non-resident exchanges on 31/12.
- Self-custody (Ledger, Trezor, MetaMask) is NOT included.
- Informational only — no payment, only reporting.
- Late-filing penalty: €300 minimum, scaling with balance.
- Deadline: January 1 to March 31 of the following year.
- Renewed only for material changes (>€20,000 or new venues).
Frequently asked questions
Does Binance Spain count for Modelo 721?
No. Binance Spain, Bit2Me and other platforms with a Spanish tax ID are Spanish tax residents and their balances are not part of the 721. They do share your operations directly with Hacienda (for IRPF), but they don't appear on this informational return.
Do I have to declare my Ledger in Modelo 721?
No. Self-custody wallets (Ledger, Trezor, non-custodial MetaMask, cold wallets) are explicitly excluded. Only balances where a third party custodies on your behalf are reportable.
What happens if I file the 721 late?
€300 minimum fine for spontaneous late filing without a prior request. If Hacienda requests it before you file, the penalty goes up. Voluntary regularisation is always cheaper than waiting for a formal request.
Does Modelo 721 replace Modelo 720?
No. Modelo 720 still applies for foreign bank accounts, securities and other non-crypto assets. Modelo 721 is specifically for crypto. If you also have fiat accounts abroad over €50,000, you may need to file both.
Are NFTs included in Modelo 721?
The law refers to "virtual currencies" and there is technical debate about whether NFTs (non-fungibles) qualify. The majority tax opinion says no, but an NFT with clear financial function (fractionalised, yield-bearing) could be in a grey area. Consult a specialist if you have material exposure.
Modelo 721 is informational, but skipping it has real cost. If in doubt about whether you're required, sum your total 31/12 balances and consult the full crypto tax return guide for which model and which box each event belongs to.
View full crypto tax return guide