Spain’s tax agency is stepping up its scrutiny of freelancers and small businesses using digital banks such as Revolut, Wise and N26.

New reporting rules will aim to identify undeclared income and suspicious financial activity.

Under the Tax Agency’s 2026 Tax Control Plan, authorities will introduce a new reporting system known as Modelo 174, designed to collect information on the use of virtual cards, electronic money and digital banking accounts – particularly those held with providers based outside Spain.

The move reflects the growing popularity of so-called ‘neobanks’. Revolut alone ended 2025 with more than 6.3million customers in Spain, with the company aiming to surpass eight million this year.

Many freelancers have switched to these platforms to avoid traditional banking fees, benefit from cheaper currency exchange rates and receive payments from overseas clients through services such as Stripe or YouTube.

What will Hacienda be checking?

According to financial publication Diario A y E, The Spanish Tax Agency (AEAT) says it will increasingly cross-reference information received from digital banks with taxpayers’ quarterly and annual tax returns.

The aim is to detect inconsistencies between the money flowing through accounts and what has been declared for income tax (IRPF) and VAT.

Authorities say they will pay particular attention to taxpayers who rely mainly on payment providers based abroad or whose spending appears inconsistent with their declared income.

Does this affect Revolut and N26 users?

Revolut, N26 and Trade Republic now all offer Spanish IBAN account numbers, making them subject to similar oversight as traditional Spanish banks.

However, the new measures are particularly focused on people who continue using foreign IBAN accounts, which historically have been harder for the Spanish authorities to monitor.

Not an immediate reporting requirement

Modelo 174 will not require immediate reporting.

The first declaration will be submitted in January 2027, covering transactions made during 2026.

In addition, cards with less than €25,000 in total annual transactions will be exempt from the reporting requirement.

Part of a wider crackdown

The new model is the latest step in Spain’s broader campaign to improve oversight of the digital economy.

It follows previous reporting requirements covering overseas assets (Model 720), cryptocurrency holdings (Models 172 and 173), digital platforms under the EU’s DAC7 directive, and card and mobile payment reporting introduced through Model 170 earlier this year.

What should freelancers do?

Tax experts recommend that anyone using digital banks for business should ensure:

• Every payment received is backed by an invoice.
• Income is declared in quarterly and annual tax returns.
• Business and personal spending are kept separate.
• Records are retained for all payments and expenses.
• Tax declarations match the actual movement of funds through digital accounts.

The Tax Agency stresses there is no tax advantage to using a foreign IBAN. Spanish tax obligations depend on where the taxpayer is resident, not where their bank account is located.

Freelancers who deliberately fail to declare income could face penalties of up to 150% of the unpaid tax, depending on the circumstances.