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Modelo 210 deemed income: the window now opens on 1 April

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Non-resident owners who have filed their modelo 210 every January are about to find the door shut. Orden HAC/623/2026 rewrote the filing calendar of Orden EHA/3316/2010 for income accrued from 2026: deemed income accrued on 31 December 2026 can only be filed between 1 April and 31 December 2027, and rental income with tax to pay moves to the first twenty days of April. Income accrued in 2025 keeps the old calendar.

The short version

From the 2026 accruals onwards, deemed income on modelo 210 can no longer be filed in January: Orden HAC/623/2026 opens the period on 1 April 2027 and closes it on 31 December 2027.

Valery Grinkevich

Written by

Valery Grinkevich

Licensed economist · tax adviser · 20+ years of experience · Torrevieja, Costa Blanca

January 2027 stops being a filing month

Deemed income on a home kept for your own use accrues on 31 December of each year, under article 27.1.c) of the consolidated non-resident income tax act. What has changed is not the accrual but the period that follows it: article 5.b) of Orden EHA/3316/2010, in the wording given by Orden HAC/623/2026, now says the return is filed and paid from 1 April to 31 December of the calendar year after the accrual date. For the income accrued on 31 December 2026 that means a window of 1 April to 31 December 2027, and nothing before it.

The order is dated 12 June 2026, was published in the BOE of 23 June and has been in force since 24 June. Its single final provision fixes the first application: the new deadlines govern deemed income accrued in 2026, so the change lands on the return most owners would have filed in the first days of January 2027. Anyone who logs in then will find the period has not started.

Your 2025 return is untouched, and it is due this year

The old rule survives for income accrued in 2025: that return can be filed at any moment between 1 January and 31 December 2026, exactly as before. The AEAT note on the reform says so expressly. The last day is a real deadline, not a formality; 31 December 2026 falls on a Thursday, so no working-day extension applies.

The date that bites earlier is the direct debit. Under article 13.6 of the same order, the payment of a deemed-income return (income type 02) can be domiciled only until 23 December, a Wednesday in 2026. After that the return can still be filed, but the tax has to be paid by NRC through a Spanish collaborating bank or by transfer from abroad. The plan of doing it quietly over Christmas has already stopped working.

Why April and not December

Nine months of window invite postponement, and postponement is where the surcharges come from. Filing in April leaves time for the things that go wrong on a modelo 210: a cadastral value revised by the town hall, ownership shares that do not match the deed, a return that has to be split between two owners, a certificate of tax residence that has expired. In December none of that can be fixed before the deadline.

The direct debit closes early in the new calendar too: for deemed income accrued in 2026 it runs from 1 April to 23 December 2027, a Thursday, while filing itself remains open until Friday 31 December 2027. If you pay by direct debit, your real deadline is 23 December, not 31 December, and the eight days between them are not a grace period.

Rental income moves to April as well, in stages

Article 5.c).1.º now puts rental income with tax to pay in the first twenty calendar days of April of the year after accrual, and it says expressly that this applies both to returns filed separately and to returns grouping the whole year. For rent accrued in 2026 that is 1 to 20 April 2027, closing on a Tuesday, with direct debit available only from 1 to 15 April.

The transition is staggered rather than clean. The final provision of the order applies the new rental deadline to accruals in 2026 when the year is grouped, and, for owners who file each quarter separately, only to accruals in the last quarter of 2026. If you file quarterly, check which of your 2026 quarters is still on the old rule before assuming April; the calendar guide sets out every quarter by accrual year.

Nobody is going to remind you

Modelo 210 is a self-assessment. The AEAT issues no bill, no receipt and no reminder for it, which is why fifteen years of filing in January feels safe until the year the rule changes. A calendar that lives in your head is exactly the kind that does not get updated when the BOE moves a date, and there is no letter coming to tell you.

Missing the window is not a formal slip either. A return filed late on your own initiative, before any demand from the AEAT, carries a surcharge under article 27 of the General Tax Act that grows with each full month of delay, and deemed income is one return per owner and per property, so a couple who forget lose twice. Put the date in a calendar that is not your memory.

What to do

Diarise 1 April 2027 for the 2026 deemed income and 1 to 20 April 2027 for 2026 rental income with tax to pay; and if you want the 2025 deemed income paid by direct debit, file it before 23 December 2026.

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