Model 720 and crowdlending: who has to file it and what to declare

As of December 31, 2025, I had about €51,000 in foreign crowdlending platforms. A thousand euros above the limit, so I had to file a report. Model 720. And this is exactly the statement that generates the most doubts in the community: do I have to present it? What do I declare? Loans too?

The good news is that the 720 model and crowdlending are very well understood with a single idea: Hacienda doesn't care about what you earn, but What you have outside Spain on December 31st. I will explain it step by step and without technical jargon.

What is the 720 model?

It is a Informational statementYou tell the tax authorities what assets you have abroad, but You don't pay anything for filing it. The gains from your investments are declared later, in the income tax return, which is a separate matter.

Think of the 720 as a Photo of your inventory as of December 31st. It doesn't matter what you've won or lost during the year, and it doesn't matter what you have on the day you present it: what matters is what you had on that last day of the year.

The 3 blocks and the rule of the 50,000 €

The 720 model divides your foreign assets into three blocks. You are only required to file it if any of the blocks exceeds €50,000:

Watch out for the account block: in addition to the balance as of December 31, look at the Average balance from October to December. If you had a lot of money sitting in an account during those months, you can exceed the limit even if you had already invested it by December 31st.

And my crowdlending? What qualifies and what doesn't

Here lies the doubt of almost everyone. In crowdlending, the question that resolves it is very simple: Does what you have have an ISIN? The ISIN is like the ID number of a financial instrument.

• Notes with ISIN → yes, in the securities block. These are the investments of the 6 first-class platforms that have a license to be an investment broker: Mintos, Twino, Debitum, Indemo, Nectaro And ViaInvest. That license allows them to convert the loans into financial instruments with ISIN (Here I explain what each license means).
• Loans without ISIN → no. On the other platforms, you invest directly in loans, and the Treasury has already clarified in a binding consultation (V1342-18) that these loans are not declared in the 720.
• Money without investment → depends. It goes to the account block on any foreign platform, regardless of the license you have, and only requires you to do so if that block exceeds €50,000.

Important: that you invest in a first-class platform It doesn't force you to do it alone to present the 720. Yours notes add up the value in the block of securities along with your stocks, ETFs or funds in foreign brokers, and what counts is the total of that block.

Do you have to submit it every year?

You have to submit the first year if you exceed €50,000 in any block. After that, you only have to submit it again if:

• One block rises more than €20,000 Regarding what you declared last time, or
• You sell or cancel something that you had already declared.

And here crowdlending has a particularity: the notes They expire every few months, and each expiration is a cancellation. Therefore, if you invest in first-class platforms and you have already submitted the 720, The most common situation is that you have to submit it every year..

What doesn't fit in the 720 model

• Physical gold, jewelry, cars or boats You have it. Gold through an ETF, on the other hand, counts as value.
• Cryptocurrencies. They have their own model, the 721, Following the same logic: if you have them stored on a foreign platform and they exceed €50,000. The ones you keep in your own wallet are not declared.
• Your profits. Whatever you have won or lost goes to income tax return, No to 720. The fact that you have won more than 50,000 € has nothing to do with this model.

What happens if I don't present it?

For years, the 720 model has had exorbitant fines. In 2022, the Court of Justice of the European Union declared them disproportionate and Spain had to eliminate them. Today, if you do not file them or file them late, the general penalties for any informative declaration apply, which are much lower than before.

How it is presented in practice

The process has three steps:

1. Download the extracts of each platform with your wallet as of December 31st.
2. Transferring that data to the Treasury format. Here's the problem: the 720 model requests each value one by one, with its ISIN, and in crowdlending it's easy to have hundreds of them. notes. I had about 600. Making it by hand is crazy.
3. Importing the file in the Electronic headquarters of the Tax Agency, review it and submit it.

For step 2 I use AutoDeclaroI send you the extracts without any personal data and return you the file ready to be imported into Hacienda. Transparency: I have a collaboration agreement with AutoDeclaro and I receive a commission if you use it with the community coupon.

If you want to see it from start to finish, in this video I present it step by step using my own platforms: Model 720 for crowdlending from 0 to present.

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