Spanish Form 190 (Modelo 190) 2026: Annual Withholdings Summary | BMC

Q: What is Spanish Form 190 (Modelo 190)?

Form 190 is the annual information return for IRPF withholdings and payments on account. It is filed by all payers that have practised withholdings on employment income, professional services income, prizes, or other taxable income during the preceding fiscal year. It details each recipient individually (tax ID, gross amounts, withholdings, codes, and subcodes for the income type). Its legal basis is Article 105.1 of the General Tax Law (LGT), Article 108 of the IRPF Regulation (Royal Decree 439/2007), and Order HFP/1335/2021.

Q: When is Form 190 filed?

Form 190 is filed between 1 and 31 January of the year following the fiscal year being declared. For fiscal year 2026, the deadline runs from 1 to 31 January 2027. Filing is mandatorily electronic through the AEAT Electronic Headquarters, using electronic certificate, electronic national ID (DNIe), or Cl@ve PIN.

Q: Who is required to file Form 190 in Spain?

All Spanish withholders who have practised IRPF withholdings during the preceding fiscal year — declared quarterly in Form 111 — are required to file: employers with employees, self-employed with staff, self-employed who have received invoices from professionals with withholding, owners' associations with employees, non-profits with personnel, and prize payers. If at least one Form 111 with withholdings has been filed during the fiscal year, there is an obligation to file the annual Form 190.

Q: What is the relationship between Form 190 and Form 111?

Form 111 is the quarterly self-assessment through which the aggregate withholdings of the quarter are paid. Form 190 is the annual information summary that details, recipient by recipient, what income was paid, what withholdings were practised, and under what code and subcode. The sum of withholdings declared in the four quarterly Forms 111 of the fiscal year (or twelve monthly for large enterprises) must reconcile exactly with the total of the annual Form 190. Any difference triggers AEAT verification proceedings.

Q: What are the codes and subcodes of Form 190?

Codes and subcodes are codings that identify the type of income withheld. Main codes are: A (active personal employment income), B (pensions), C (unemployment benefits), D (arrears attributable to prior fiscal years), E (administrators and board members), F (courses, conferences, seminars), G (professional services income — self-employed), H (agricultural, livestock, and forestry activities), I (literary, artistic, or scientific non-exempt prizes), J (other taxable capital gains), K (forestry exploitation in communal mountains), L (consideration for the assignment of image rights). Each code may have subcodes detailing the applicable regime.

Q: What information must each recipient record in Form 190 contain?

Each declared recipient must appear with: tax ID, first and last name or corporate name, postcode, code (type of income), subcode (specific regime), province, gross amount received during the fiscal year, withholdings and payments on account practised, deductible expenses (where applicable, for employment income), reductions applied (irregular income), and, for professional services, the applied withholding rate (15% general, 7% reduced, etc.). For administrators and board members, allowances and maintenance expenses are also included.

Q: What happens if Form 190 does not reconcile with the quarterly Forms 111?

Mismatches between Form 190 and the sum of the quarterly Forms 111 trigger AEAT verification proceedings. Frequent causes of mismatch: withholdings included in Form 111 but forgotten in Form 190 (or vice versa), errors in code or subcode that reassign amounts to different categories, duplicate recipients or with incorrect tax IDs, complementary amounts not included. The AEAT sends a clarification requirement; if differences are not justified, it may issue a complementary assessment with a penalty of 1% per month of delay (surcharge for inaccurate return) or a proportional sanction depending on severity.

Q: What are the penalties for late or incorrect Form 190 filing?

For late filing without prior requirement: fixed penalty of €20 per data item or set of data items referring to the same person, with a minimum of €300 and maximum of €20,000 (Article 198 LGT). If the AEAT previously required filing, penalties are double (minimum €600, maximum €40,000). For errors or omissions in declared data: €150 per omitted, inaccurate, or false data item, without prejudice to the IRPF regularisation of the affected recipient. Correct and timely filing is the only way to avoid penalties.

Spanish Form 190 (Modelo 190) is the annual information summary of IRPF withholdings and payments on account that Spanish companies, self-employed individuals, and other withholders must file. While the quarterly Forms 111 serve to pay the aggregate amount of withholdings, Form 190 details, recipient by recipient, what income has been paid, what withholdings have been practised, and under what code and subcode of income type.

Form 190 is one of the most complex information returns in the Spanish tax system: it combines a prior quarterly obligation (Form 111), volume of data per recipient, coding by codes/subcodes, and a mandatory exact reconciliation. This guide explains in detail what it is, who must file it, when, and how to complete it correctly.

What is Form 190?

Form 190 is the annual information return for IRPF withholdings and payments on account. Its purpose is twofold:

Allow the AEAT to cross-reference data between what is declared by withholders and what is declared by recipients in their annual IRPF (Form 100). If an employee declares employment income without the corresponding withholdings, the AEAT detects it by cross-referencing with their employer’s Form 190.
Generate the recipient’s tax data: information from Form 190 feeds the IRPF draft (Renta Web) and the withholdings certificate that the payer issues to the recipient. Form 190 data is the basis on which the taxpayer prepares their annual IRPF.

The legal basis of Form 190 is found in:

Article 105.1 of the General Tax Law (Law 58/2003), establishing the general obligation to provide information to third parties.
Article 108 of the IRPF Regulation (Royal Decree 439/2007), specifically regulating the duty to inform about withholdings.
Order HFP/1335/2021, approving the official form and the electronic format (with annual updates).

Who must file Form 190

All withholders who have practised at least one withholding declared quarterly in Forms 111 during the preceding fiscal year are required to file Form 190:

Companies with employees (SL, SA, cooperatives, etc.).
Self-employed with employees as employed staff.
Self-employed and companies that have received invoices from Spanish professionals with withholding (advisors, lawyers, architects, consultants, etc.).
Owners’ associations with contracted personnel (porters, concierges, administrators with employment relationships).
Non-profit entities with employees (associations, foundations, NGOs).
Payers of prizes subject to withholding.
Entities that have paid allowances and expenses subject to withholding to their directors or administrators.

If no Form 111 with withholdings has been filed during the fiscal year (because no withholdings were practised), filing Form 190 is not mandatory.

2026 filing deadline

Form 190 is filed between 1 and 31 January of the year following the declared fiscal year:

Declared fiscal year	Filing deadline
2025	1 to 31 January 2026
2026	1 to 31 January 2027
2027	1 to 31 January 2028

If the last day of the deadline (31 January) falls on a Saturday, Sunday, or national holiday, the due date moves to the following working day.

Filing is mandatorily electronic for all filers, through the AEAT Electronic Headquarters. The following are accepted:

TXT file upload with the structure provided in the ministerial Order (for withholders with many recipients).
Completion through web form (for withholders with few recipients).
Import from payroll management applications that generate the compatible file.

Form 190 codes and subcodes

Codes and subcodes are the coding that typifies each recipient by the type of income received. Knowing them is essential to avoid classification errors that generate AEAT requirements.

Main codes

Code	Type of income
A	Active personal employment income (salaries and wages)
B	Pensions and passive income
C	Unemployment benefits or subsidies
D	Arrears attributable to prior fiscal years
E	Remuneration to administrators and board members
F	Courses, conferences, seminars, colloquia
G	Professional services income (self-employed)
H	Agricultural, livestock, and forestry activities income
I	Non-exempt literary, artistic, or scientific prizes
J	Other taxable capital gains
K	Forestry exploitation in communal mountains
L	Consideration for the assignment of image rights

Frequent subcodes

Each code may have subcodes detailing the specific regime. Some examples:

Code A subcode 01: Active employee, general situation.
Code A subcode 03: Employee/pensioner of social welfare mutualities.
Code G subcode 01: Professional with general rate (15%).
Code G subcode 02: Professional with reduced rate (7%) — new self-employed in their first 3 years.
Code G subcode 03: Municipal collectors (1%).
Code E subcode 01: Company administrator — general regime (35%).
Code E subcode 02: Company administrator with reduced turnover (19%).

Order HFP/1335/2021 and its annual updates contain the complete table of codes and subcodes. The AEAT typically publishes the updated catalogue on its Electronic Headquarters at the end of the fiscal year.

How to complete Form 190 step by step

The form consists of a summary return and a detail per recipient.

Summary return

Filer’s tax ID and corporate name.
Declared fiscal year.
Type of return (ordinary, complementary, substitutive).
Total number of included recipients.
Total amount of declared gross income (sum of all recipients).
Total amount of withholdings and payments on account (must reconcile with the sum of quarterly Forms 111 of the fiscal year).

Recipient record

For each recipient, the following is included:

Tax ID / Foreign tax ID / Passport of the recipient.
First and last name or corporate name.
Province code and postcode of the recipient’s address.
Code (A, B, C, …, L) identifying the type of income.
Subcode detailing the specific regime.
Gross amount of income during the fiscal year.
Withholdings and payments on account practised.
Gross amount of income in kind (where applicable).
Payments on account for income in kind (where applicable).
Deductible expenses (in employment income: Social Security contributions, mandatory mutualities, union fees, etc.).
Applied reductions (Article 18 LIRPF for irregular income and income generated over more than 2 years).

For administrators and board members (code E), the following are added:

Allowances and travel expenses subject to withholding.
Employment income in kind (company vehicle, housing, etc.).

For professional services (code G), it is essential to correctly declare the applied withholding rate:

15%: general rate.
7%: reduced rate for new self-employed during 3 years.

Reconciliation with quarterly Forms 111

The exact reconciliation between the four quarterly Forms 111 of the fiscal year (or twelve monthly for large enterprises) and the annual Form 190 is mandatory. The basic formula:

Sum of withholdings (box 28) of the 4 Forms 111  =  Total withholdings of Form 190

Differences trigger AEAT verification proceedings. Frequent causes of mismatch:

Withholdings declared in Form 111 but not included in Form 190: typically when a recipient is included in the quarterly aggregate but not linked to a specific tax ID at year-end.
Complementary amounts or arrears: payments made at year-end or arrears attributable to prior fiscal years that have been included in one quarter but do not appear in Form 190 of the correct fiscal year.
Errors in code or subcode: the amount is in both forms but classified differently.
Incorrect tax ID or duplicate recipient: two records for the same individual with different tax IDs (national ID vs foreign ID), or a tax ID that does not exist in the AEAT census.
Reductions applied at year-end: regularisations of the withholding rate of active personnel applied in the last quarter that have not been propagated to Form 190.

Common mistakes in Form 190

These are the most frequent failures detected by the AEAT:

Classifying a director/administrator in code A: remuneration to administrators and board members goes in code E with a specific rate (35% general, 19% for companies with turnover below €100,000). Including them in code A distorts the withheld rate.
Not updating the 7% reduced rate to 15% at the end of 3 years: professionals who have been self-employed for more than 3 years no longer have the right to the reduced rate. Continuing to apply it is an infraction by the withholder.
Omitting deductible expenses in code A: the worker’s Social Security contributions must be declared in the deductible expenses field so that the recipient’s tax data is correct in their IRPF draft.
Incorrect subcode: the AEAT compares the subcode with the recipient’s activity code. Incorrect subcodes trigger requirements.
Foreign tax ID poorly formatted: foreign ID with final letter omitted, passport without country code, expired temporary tax ID.

Penalties for non-compliance

The sanctions applicable to Form 190 are regulated primarily in Article 198 LGT (information returns):

Late filing without prior requirement

€20 per data item or set of data items referring to the same person or entity.
Minimum: €300.
Maximum: €20,000.

If the late filing is less than 6 months, the above amounts are reduced to 50% (minimum €150, maximum €10,000).

Filing after AEAT requirement

Penalties are raised to double: €40 per data item, minimum €600, maximum €40,000.

Inaccuracies or omissions of data

€150 per omitted, inaccurate, or false data item, without prejudice to the IRPF regularisations that may arise for affected recipients.

Reductions

Penalties allow the general reductions of Article 188 LGT:

30% for conformity with the regularisation proposal.
40% additional cumulative for prompt payment within the penalty proposal deadline.

How BMC helps with Form 190

At BMC Consulting we manage annual Form 190 compliance for foreign-owned companies operating in Spain, Spanish subsidiaries of multinational groups, self-employed individuals, SMEs, and non-profit entities. Our service includes:

Automatic generation of the TXT file from payroll data and records of invoices with professional withholding of the fiscal year.
Verification of codes and subcodes for each recipient: correct identification of professionals at the reduced 7% rate, administrators in code E, courses and conferences in code F, etc.
Reconciliation of Form 190 with quarterly Forms 111 of the fiscal year before filing, to avoid AEAT requirements.
Electronic filing and issuance of withholdings certificates to recipients (mandatory before the start of the recipient’s annual IRPF return period for the following year).
Defence in AEAT verifications and inspections, filing allegations when detected mismatches are due to justifiable discrepancies (arrears, year-end regularisations, etc.).

If your company needs to outsource the preparation of annual Form 190 or has doubts about the correct classification of codes and subcodes, contact our tax team at BMC Consulting.

form 190 modelo 190 Spanish IRPF withholdings annual summary SMEs

← Back to Insights