Modelo 190

The Modelo 190, formally known as the Declaración Informativa: Resumen Anual de Retenciones e Ingresos a Cuenta del IRPF, is Spain’s annual withholding summary for personal income tax. It is filed with the Agencia Tributaria, also known as the AEAT or Hacienda, and reports the IRPF withholdings and payments on account made during the previous calendar year.

In Spain, employers and other withholding agents do not only calculate tax at year end. They withhold IRPF during payroll or payment cycles, report those amounts through Modelo 111, and then summarize the full year through Modelo 190. This annual filing helps the tax authority reconcile withholding data and populate the employee’s or recipient’s pre-filled Spanish income tax return, known as the borrador de la Renta.

For companies operating in Spain, Modelo 190 is an important payroll and tax compliance obligation. It connects payroll processing, quarterly IRPF filings, employee tax data, social security reporting, and year-end reconciliation. International employers can simplify this process with Mercans’ Spain Employer of Record services and global payroll solutions, which help manage local payroll, statutory reporting, and tax compliance across multiple jurisdictions.

What Is Modelo 190?

Modelo 190 is an annual informative tax return used to report the total IRPF withholdings and payments on account applied by a withholding agent during the year. It is submitted electronically to the AEAT.

The form includes recipient-level details, which means each employee, freelancer, professional, or other income recipient is reported separately. This allows the Spanish tax authority to compare the annual declaration with quarterly Modelo 111 filings and use the information in the recipient’s personal income tax return.

Modelo 190 is used to report:

• Employment income subject to IRPF withholding
• Professional fees paid to freelancers and consultants
• Income from certain economic activities
• Prizes and specific gains subject to withholding
• Exempt income that still needs to be declared
• Payments on account for benefits in kind
• Recipient identification and tax information
• Annual reconciliation with Modelo 111 filings

In practice, Modelo 190 acts as the annual closing statement for IRPF withholding compliance.

Why Modelo 190 Matters

Modelo 190 is important because the data submitted by employers and withholding agents directly affects the Spanish tax system.

For the AEAT, it provides a detailed annual record of tax withheld from individuals and other recipients. For employees and taxpayers, it helps populate their Renta Web pre-filled income tax return. For employers, it proves that the IRPF amounts withheld during the year match the payments declared through Modelo 111.

Incorrect Modelo 190 data can create problems for both the employer and the recipient. It may cause mismatches in the Renta Web draft, trigger AEAT inquiries, or lead to penalties for late, incomplete, or inaccurate reporting.

For multinational employers, this makes accurate Spanish payroll management essential. Mercans’ payroll services help companies manage payroll calculations, IRPF deductions, statutory filings, and annual tax reporting with local compliance support.

Who Must File Modelo 190?

Modelo 190 must be filed by any business, organization, or individual classified as a retenedor, meaning a withholding agent, if they have applied IRPF withholdings or payments on account during the year.

Entities that may need to file Modelo 190 include:

• Spanish companies paying salaries to employees
• Self-employed individuals who pay workers, freelancers, or contractors
• Public administrations and public-sector entities
• Non-profit organizations and foundations
• Foreign companies with a permanent establishment in Spain
• Professional firms paying fees subject to withholding
• Property administrators paying withholding-subject service providers
• Any entity that filed Modelo 111 during the year

A withholding agent may not need to file Modelo 190 if no IRPF withholding or payment on account was made during the full calendar year. However, some exempt income must still be reported, so employers should review their reporting position carefully before assuming no filing is required.

Companies expanding into Spain can use Mercans’ Employer of Record services to hire employees without setting up a local entity, while still meeting payroll, employment, and statutory reporting obligations.

Modelo 190 and Modelo 111

Modelo 190 is closely connected to Modelo 111.

Modelo 111 is the periodic declaration used to report and pay IRPF withholdings to the Spanish Treasury. Most employers file it quarterly, although large companies may need to file monthly.

Modelo 190 is the annual summary that consolidates the amounts reported during the year. It should match the totals declared through Modelo 111.

The relationship works as follows:

• Payroll is processed and IRPF is withheld
• Social security data is reported through the relevant Spanish systems
• Modelo 111 is filed quarterly or monthly
• Modelo 190 is filed after year end
• AEAT checks Modelo 190 against Modelo 111 totals
• Modelo 190 data feeds the taxpayer’s Renta Web draft

Because of this connection, companies should reconcile Modelo 111 and Modelo 190 before submitting the annual declaration.

Key System in Modelo 190

A central feature of Modelo 190 is the Clave and Subclave classification system. These codes identify the type of income being reported.

Correct classification is essential because each income type must be reported under the right key. Errors in key selection can affect the recipient’s tax return and may lead to AEAT mismatches.

Common Modelo 190 keys include:

Key A: Employment Income

This key is used for salaries, wages, bonuses, and other income paid to active employees under an employment contract.

Key B: Pensions and Passive Income

This key covers pensions, unemployment benefits, and other passive employment-related income.

Key C: Lump-Sum Unemployment Benefits

This applies to unemployment benefits paid in a single amount by the Spanish public employment service.

Key D: Severance and Termination Compensation

This key is used for dismissal or termination compensation, including amounts that may be exempt within statutory limits.

Key E: Directors and Board Members

This key reports remuneration paid to company directors, administrators, board members, and similar governing body members.

Key F: Professional Athletes

This key applies to compensation paid to professional sportspeople.

Key G: Professional and Self-Employment Income

This key is used for payments to lawyers, consultants, doctors, advisors, and other professionals carrying out economic activity.

Key H: Agricultural and Livestock Activities

This applies to income from farming, livestock, and related activities subject to withholding.

Key I: Forestry Activities

This key is used for income connected to forestry activity.

Key J: Other Economic Activities

This key applies to certain industrial, commercial, and service activities.

Key K: Prizes

This key is used for cash or non-cash prizes from contests, raffles, competitions, and similar events.

Key L: Exempt Income

This key reports income that is exempt from IRPF but must still be included in the annual declaration.

Key M: International Workers

This key may apply to specific income paid to certain internationally mobile workers or workers subject to special reporting treatment.

Each key may include multiple subkeys. Subkeys provide a more specific description of the payment. Choosing the correct key and subkey is one of the most important parts of Modelo 190 preparation.

Information Reported in Modelo 190

Modelo 190 contains detailed information about the withholding agent and each income recipient. The filing is structured to allow the AEAT to identify who paid the income, who received it, how much was paid, and how much tax was withheld.

Withholding Agent Information

The declaration includes details about the company or person filing the form, such as:

• Tax identification number
• Legal name or business name
• Fiscal year reported
• Contact and filing information
• Total number of recipient records
• Total amounts paid and withheld

Recipient Identification Data

Each recipient record may include:

• NIF, NIE, or DNI
• Full legal name
• Province of residence
• Tax residence status
• Income classification key and subkey
• Fiscal year and reporting period

Income and Withholding Data

Modelo 190 reports the financial details for each recipient, including:

• Gross income paid
• IRPF withheld
• Payments on account
• Benefits in kind
• Applicable reductions
• Deductible expenses
• Social security amounts where relevant
• Compensation and support payment information where applicable

Family and Personal Circumstances

The filing may also reflect personal circumstances relevant to withholding calculations, such as:

• Number of descendants
• Number of ascendants
• Disability status
• Family situation
• Dependants affecting tax reductions

These details help determine whether the withholding rate applied during the year was correct.

Regional and Foral Treasury Data

Spain has special regional tax systems in the Basque Country and Navarra. Companies operating across common territory and foral territories may need to allocate withholding data correctly between the State Treasury and relevant foral treasuries.

This makes payroll accuracy especially important for businesses with employees in multiple Spanish regions.

How to File Modelo 190

Modelo 190 must be filed electronically through the AEAT Sede Electrónica. Paper filing is not accepted.

Common authentication options include:

• Digital certificate
• DNI Electrónico
• Cl@ve PIN
• Cl@ve Permanente

Submission methods may include:

• Online form submission
• File upload using AEAT technical specifications
• Large-volume information transmission systems for high-record filings

After submission, the AEAT issues a confirmation receipt. This receipt includes a secure verification code and serves as proof of filing.

Businesses using Mercans’ HR and payroll technology can centralize payroll information, improve visibility over annual reporting data, and support smoother compliance workflows across countries.

Modelo 190 and the Spanish Renta Web

Modelo 190 is one of the key sources used by the AEAT to prepare the Renta Web pre-filled income tax return.

After employers and other withholding agents submit Modelo 190, AEAT uses the reported data to generate each taxpayer’s draft return. This may include employment income, withholdings, exempt income, and other reportable amounts.

If the Modelo 190 contains incorrect data, the taxpayer’s draft return may also be incorrect. This can require manual correction and may create delays or tax discrepancies.

This is why employers should verify:

• Employee identification details
• Income classification keys
• Annual gross pay
• IRPF withholding totals
• Exempt income reporting
• Benefits in kind
• Severance treatment
• Modelo 111 reconciliation

Accurate filing helps protect both the employer and the employee.

Recent Modelo 190 Updates

Modelo 190 is updated periodically through official Spanish tax regulations and AEAT technical specifications. Employers should review the latest instructions every year before filing.

Recent areas of update and attention include:

• Changes to technical filing specifications
• Updated reporting fields for IRPF changes
• Individual reporting of State and foral treasury allocations
• Treatment of maternity and paternity benefits
• Exempt income reporting under Key L
• Director remuneration reporting
• Public employment and apprenticeship income categories
• Updated thresholds affecting exempt and taxable amounts

Because these updates may affect payroll setup and reporting logic, companies should not treat Modelo 190 as a static annual task. It requires yearly review.

Mercans supports employers with Spanish payroll compliance updates, statutory reporting support, and year-end payroll reconciliation through Mercans’ global payroll solutions.

Penalties for Modelo 190 Non-Compliance

The AEAT can apply penalties when Modelo 190 is not filed correctly, filed late, or filed with missing information.

Common penalty triggers include:

• Late filing
• Failure to file
• Missing recipient records
• Incorrect NIF or NIE data
• Inaccurate income or withholding amounts
• Incorrect key or subkey classification
• Filing by an invalid method
• Discrepancies between Modelo 190 and Modelo 111
• Failure to pay withheld IRPF

Penalties may be calculated per record, by percentage of omitted or incorrect amounts, or by fixed penalty ranges depending on the type of breach. Voluntary correction before an AEAT request may reduce the financial impact.

Common Modelo 190 Mistakes

Even experienced payroll teams can make errors when preparing Modelo 190. The most common mistakes include:

• Using the wrong income key
• Selecting an incorrect subkey
• Missing exempt income under Key L
• Reporting incorrect NIF or NIE details
• Failing to include all recipients
• Creating duplicate recipient records
• Misreporting severance payments
• Failing to split taxable and exempt compensation
• Incorrectly allocating amounts between State and foral treasuries
• Not reconciling Modelo 190 with Modelo 111
• Missing the 31 January deadline
• Submitting an incompatible electronic file
• Incorrect family or disability data affecting withholding calculations

A structured payroll close process can reduce these risks. Employers should review payroll records, quarterly filings, employee master data, and income classifications before submission.

Modelo 190 and Spanish Payroll Compliance

Modelo 190 is part of Spain’s broader payroll compliance environment. Employers must manage not only annual tax reporting but also monthly payroll calculations, IRPF withholding rates, social security contributions, employment law requirements, collective agreements, and regional tax differences.

Spanish payroll compliance may involve:

• Monthly payroll processing
• IRPF withholding calculations
• Employee social security contributions
• Employer social security contributions
• Sistema RED reporting
• SILTRA submissions
• CRA reporting
• Modelo 111 filings
• Modelo 190 annual filing
• Employment contract compliance
• Convenios Colectivos obligations
• Severance and termination rules
• Regional IRPF variations

For international businesses, these obligations can be difficult to manage without in-country expertise. Mercans’ Spain payroll and EOR solutions help companies hire, pay, and manage workers in Spain while reducing compliance risk.

How Mercans Supports Modelo 190 Compliance

Mercans helps companies manage Spanish payroll and year-end reporting with local compliance expertise and global payroll technology.

For businesses hiring in Spain without a local entity, Mercans’ Employer of Record services provide a compliant way to onboard employees, run payroll, manage employment obligations, and support statutory reporting.

For companies with an existing Spanish entity, Mercans’ global payroll services help centralize payroll operations, calculate accurate gross-to-net pay, manage IRPF deductions, and support Spanish filing requirements such as Modelo 111 and Modelo 190.

Through HR Blizz, Mercans enables employers to manage payroll data, employee records, HR workflows, and reporting across multiple countries from one platform.

Mercans’ Spain payroll support can include:

• Spanish payroll processing
• IRPF withholding calculation
• Modelo 111 filing support
• Modelo 190 annual reconciliation support
• Recipient record preparation
• Key and subkey classification support
• Social security reporting support
• Sistema RED and SILTRA process support
• Foral treasury reporting support
• Convenios Colectivos compliance support
• Severance and termination payroll treatment
• Benefits in kind reporting
• Year-end payroll review
• Multi-country payroll reporting
• Employer of Record support in Spain

With payroll coverage across more than 160 countries, Mercans supports global companies that need accurate, compliant, and scalable payroll operations in Spain and worldwide. Explore Mercans’ payroll and EOR solutions to simplify Modelo 190 compliance and manage Spanish payroll with confidence.

Modelo 190 FAQs

What is Modelo 190 in Spain?

Modelo 190 is the annual informative declaration used to report IRPF withholdings and payments on account made during the previous calendar year.

Who must file Modelo 190?

Any withholding agent that has applied IRPF withholdings or payments on account during the year may need to file Modelo 190. This includes employers, companies, self-employed professionals, public bodies, and certain organizations.

What is the difference between Modelo 111 and Modelo 190?

Modelo 111 is filed periodically to declare and pay IRPF withholdings. Modelo 190 is the annual summary that consolidates those withholdings by recipient.

When is Modelo 190 due?

Modelo 190 is generally due between 1 January and 31 January of the year following the fiscal year reported.

Can Modelo 190 be filed on paper?

No. Modelo 190 must be filed electronically through the AEAT Sede Electrónica.

What are Claves in Modelo 190?

Claves are income classification keys used to identify the type of payment being reported, such as employment income, professional fees, severance compensation, pensions, or exempt income.

What happens if Modelo 190 does not match Modelo 111?

Discrepancies between Modelo 190 and Modelo 111 may trigger AEAT checks, requests for clarification, corrections, or penalties.

Are exempt payments reported in Modelo 190?

Yes. Some exempt income must still be reported, usually under Key L.

Do foreign workers need to be included in Modelo 190?

Foreign workers subject to Spanish IRPF withholding should generally be included in Modelo 190. Non-residents subject to IRNR may fall under other reporting models.

How can Mercans help with Modelo 190?

Mercans supports Spanish payroll processing, IRPF withholding, Modelo 111 reconciliation, Modelo 190 preparation, and broader payroll compliance through its global payroll and Employer of Record services.