Spain: Updated guidance on common errors in CRS reports received via Form 289

The Spanish Tax Administration Agency (AEAT) in late November 2025 issued updated guidance addressing common errors identified during its control activities or reported by partner jurisdictions receiving common reporting standard (CRS) reports via Form 289.

The key updates to the guidance include:

• The section “Information That Should Not Be Reported in Form 289” has been updated to state that, when deciding whether to report an account holder or controlling person in Form 289 based on their tax residence in a CRS jurisdiction, reporting financial institutions must verify that there are no inconsistencies with other filings where these individuals may have been reported as Spanish tax residents
• The “Tax Identification Numbers (TIN) Field” and “Date of Birth (DOB) Field” sections now provide additional guidance stating that the TINs and DOBs of relevant account holders and controlling persons must be obtained by the end of the second calendar year following the year in which the account was classified as pre-existing.
• The updated section on “Consistency with Other Information Statements” specifies that when an account is reported in Form 291 (or Form 196 starting January 1, 2026, for non-resident information) or in Form 296, and the account is linked to a jurisdiction covered by Royal Decree 1021/2015, the reporting financial institution must determine whether the account should also be reported in Form 289, provided all other applicable requirements are met.

Additionally, the AEAT states that a support service for IT-related issues is available to reporting financial institutions through the “Assistance and Appointment” section of the AEAT website or via the AEAT app.

Read a December 2025 report prepared by the KPMG member firm in Spain