Form 721 for crypto: do I have to file it?

Form 721 (modelo 721) is the Spanish information return on crypto-assets held abroad: you report, you do not pay anything. It binds only those holding cryptocurrency custodied by non-Spanish entities above €50,000 on 31 December. Answer three questions and we will tell you.

1. Are you tax resident in Spain?
2. Where is your cryptocurrency?

Tick everything that applies.

3. Value on 31 December of what non-Spanish entities hold for you

What to understand before you trust the answer

Your own wallet does not count. Really.

Form 721 reports what a third party custodies. If you hold the private keys, there is no third party: there is nothing to report on this form, whatever it is worth. A Ledger with a million in bitcoin stays out. What decides is not how much you hold, but who keeps it.

It is a snapshot of 31 December

Not the high of the year, nor the average, nor what it is worth when you file. It is what it was worth on that day. If on 12 November you held €90,000 and on 31 December €40,000, you are not over the threshold.

Reporting is not paying, and not reporting does cost

Filing form 721 generates no tax bill. It is an information return and that is all. What has consequences is not filing it when you should. That is why it is one of the few formalities where there is no rational reason to take the risk.

And it is independent of income tax

Whether or not you file form 721 does not change what you pay when you sell. They are two different things: form 721 reports what you hold abroad; Spanish income tax (IRPF) taxes what you gain when you sell or swap. You may have to file both, one, or neither. For the second there is the crypto tax calculator for Spain.

What to know about form 721

Who has to file

Individuals and companies tax resident in Spain that on 31 December hold cryptocurrency custodied by entities not resident in Spain —exchanges and custodians based outside— with a combined value above €50,000. The holder counts, and so does anyone who is a beneficiary of the account or authorised on it. The threshold is per person and every foreign platform adds up: two accounts of €30,000 on two foreign exchanges bind you just as much as one of €60,000.

What is reported and how it is valued

For each entity that custodies: its name, address and country. And for each cryptocurrency you hold with it: the units on 31 December and their value in euros that day. The rules say which rate: the 31 December price quoted by the main trading platforms or by the price-tracking sites; failing that, a reasonable estimate of market value. Keep a record of where each figure came from: if the Agencia Tributaria, the Spanish tax authority, asks, that is the first thing it will want.

When it is filed

From 1 January to 31 March of the year after the one being reported, online, through the electronic office of the Agencia Tributaria. The first campaign was the 2024 one, for balances on 31 December 2023; it is a new form, and that is why plenty of people who have held cryptocurrency abroad for years do not know it exists.

When you have to file again

Not every year. Once filed, it only comes round again if the combined value on 31 December has risen by more than €20,000 over the last return, and also when you stop holding a balance on a platform you reported: that closure is reported too. If your balance falls or barely moves, there is nothing to file.

What happens if you do not file

Form 721 was born in 2023, after the Court of Justice of the European Union struck down in 2022 the penalty regime of form 720, so it is penalised under the general regime of the General Tax Act (articles 198 and 199): for not filing, €20 per item or set of items, with a minimum of €300 and a maximum of €20,000; if you file late without the tax authority having asked you for it, half of that. Filing it incomplete or with incorrect data has its own penalty. It is money paid for not filling in a form that costs nothing.

Three cases

  • €60,000 on a foreign exchange and €10,000 on a Ledger. You do file: the exchange custodies €60,000, above the threshold. The Ledger does not go into the count, and it did not need to.
  • €30,000 on one foreign exchange and €30,000 on another. You do file: the threshold is per person, not per platform, and they add up to €60,000.
  • €200,000 in a wallet of your own and €5,000 on a foreign exchange. You do not: the only thing custodied by a foreign third party is €5,000. The rest is yours and nobody else's, and form 721 does not ask about it.

If the platform is Spanish —Bit2Me, say, or any of those the ESMA register places in Spain— it stays out of form 721 as well: it already reports to the Agencia Tributaria through forms 172 and 173. The list of authorised providers tells you, for each one, which authority supervises it and where it is based.

What this page does NOT resolve

  • It does not say whether, having filed in earlier years, you have to file again this year: that rule depends on how much has changed since the last return.
  • It does not cover wealth tax (Impuesto sobre el Patrimonio), which is a different tax, with rules of its own in each autonomous region.
  • It is no good for the Basque Country or Navarre: they have their own foral regimes.
  • It does not add up for you: the value you type has to be the total across every foreign platform of yours, not one of them.

For the rest of the tax picture —FIFO, swaps, savings bands, staking— and for where to start, the guides hub. And if you are looking for somewhere to trade with an authorised platform, the list of providers with a MiCA licence — which also tells you which ones are Spanish and which are not, and that is exactly what decides whether this form applies to you.

Sources: the form 721 page in the Agencia Tributaria's electronic office and its frequently asked questions; Order HFP/886/2023, which approves the form, and articles 198 and 199 of the General Tax Act for the penalties. All of them are published in Spanish only. Text reviewed on 3 September 2026.

This content is for information and is not tax advice. If your case involves several platforms, earlier years already reported or doubts about valuation, check it with an adviser.

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