Cards, Bizum and merchant collections: Spain's 2026 rules
Spain's monthly Modelo 170 separates merchant collections, personal mobile payments, card spend and settlement accounts. See how a properly operated US LLC fits.
Receiving a card payment, collecting through Bizum and paying with a business card do not create the same record. Spain's redesigned Modelo 170 has made that distinction more important since January 2026: selected providers now report card and mobile-number-linked collections for businesses and professionals established in Spain every month.
The useful question is not which logo appears at checkout. It is who sold the product, which provider acquired the payment, which legal entity owns the merchant profile and where the settlement lands. For a US LLC, that analysis protects a valuable distinction: the company can remain the seller, contracting party and account holder without being collapsed into its owner.
Start with the transaction, not the app
One payment screen can support several legally different flows:
| Flow | What is actually happening |
|---|---|
| Personal mobile payment | One individual sends money to another outside a merchant collection service |
| Bizum for a business | A merchant receives a commercial payment linked to a phone number |
| Card collection | An acquirer processes a sale and settles proceeds to the merchant |
| Business-card spend | The company uses a card issued against its own account to pay an expense |
| Bank transfer | Funds move between accounts through SEPA, ACH, wire or another transfer rail |
Modelo 170 focuses on the second and third rows: collections received through cards or mobile-number-linked payment systems by businesses and professionals established in Spain. It is not a return for every personal Bizum, a live list of private purchases or a substitute for the merchant's own accounts and tax filings.
What changed on 1 January 2026
Spain's Royal Decree 253/2025 redrafted the information obligation. Order HAC/747/2025 then approved the new Modelo 170 and its technical fields.
For 2026 onwards:
- reporting is monthly, in the following calendar month;
- the scope covers every type of physical or virtual card described by the rule;
- commercial payments associated with a mobile phone number are included;
- there is no minimum amount for covered merchant collections;
- merchant identity, terminals, monthly amounts and settlement destinations are identified.
The first monthly return was due in February 2026 for January data. This does not require a merchant to submit a new form after each sale. It means the payment provider records and reports a more precise monthly view of the commercial collections it processes within the Spanish scope.
Who files Modelo 170
The filing duty belongs to the collection service provider, not to the merchant merely because it receives a payment.
The rules cover:
- banks and credit institutions managing card or mobile-linked collections;
- payment institutions and electronic-money institutions;
- providers installing point-of-sale terminals or executing merchant collections;
- their Spanish branches;
- and the same types of provider operating in Spain under the freedom to provide services, for services supplied to businesses and professionals established in Spain.
Calling a provider “foreign” is therefore not a complete analysis. The relevant facts are the contracting entity, its regulatory route into Spain and the merchant relationship it serves. Visa, Mastercard, Bizum, the issuer and the acquirer also play different roles; a consumer-facing brand does not identify the filer by itself.
What information is reported
The Spanish Tax Agency's 2026 guidance identifies five core data groups:
- full identification of the business or professional using the collection system;
- the merchant number under which it operates;
- point-of-sale terminals, whether or not physically located in Spain;
- monthly amounts collected, split between cards and mobile-number-linked payments;
- bank accounts, payment accounts or other destinations receiving the proceeds.
The technical design also captures transaction counts for terminals and mobile collections. This is periodic merchant-level information, not an individual tax report sent in the buyer's name every time a card is tapped.
Person-to-person Bizum stays outside the model
AEAT expressly excludes payments between individuals, or C2C payments, from Modelo 170. The model addresses collections received by businesses and professionals established in Spain.
That distinction prevents a common overstatement: a phone-linked payment is not business turnover merely because it uses Bizum.
- Reimbursing a friend for dinner remains a personal payment.
- Paying an invoice through Bizum for businesses is a merchant collection.
- Moving funds between two accounts owned by the same company is not a sale.
The underlying relationship determines the nature of the money: sale, refund, loan, owner contribution, distribution or own-account transfer. The payment rail helps evidence that relationship; it does not create it.
There is no merchant-collection threshold in 2026
Older commentary often links Modelo 170 to an annual threshold. That is no longer the correct rule for the monthly model. AEAT states that covered card and mobile-linked collections are reportable regardless of amount.
Do not confuse that rule with Modelo 174, the separate annual information return for card operations within its own scope and threshold, or with Modelo 196 for financial accounts.
| Return | Main perspective | Timing |
|---|---|---|
| Modelo 170 | Card and mobile collections received by the merchant | Monthly |
| Modelo 174 | Operations on cards within its specific scope | Annual |
| Modelo 196 | Accounts, holders and financial-account data | Monthly plus annual summary |
Modelo 170 looks at the receiving merchant. Modelo 174 looks at the card and its activity under a different rule. Modelo 196 looks at the account. Treating any one of these forms as a universal answer obscures the transaction rather than explaining it.
What this means for a US LLC
A US LLC is a legal and contractual entity separate from its owner. It can be the merchant of record, the party named on the invoice, the holder of the processor account and the owner of the settlement account. When all four point to the same company, the payment story is substantially stronger.
An owner's Spanish residence does not automatically turn every company collection into a personal receipt. Equally, US formation alone does not decide whether a specific provider relationship falls inside or outside Spanish Modelo 170.
A proper review asks:
- Which entity is named as seller in the contract and invoice?
- Who owns the Stripe, PayPal, Bizum or acquirer profile?
- Which regulated entity provides the collection service?
- Which business does that provider treat as established in Spain?
- Where are proceeds settled, and who owns that account?
- Where is the activity actually conducted and managed?
“US LLC”, “Spanish-resident owner” and “European provider” are relevant facts, but none is a conclusion on its own.
Four examples that lead to different answers
Spanish sole trader using Bizum for businesses
A professional established in Spain receives customer payments through a commercial Bizum service. The provider identifies the professional and reports monthly mobile-linked collections under Modelo 170. The professional continues to issue invoices and meet the tax obligations attached to the activity.
LLC operating through its own merchant identity
The LLC appears on the website, terms of sale, invoices, processor contract and settlement account. The flow belongs to the company. Any Spanish reporting analysis examines the provider entity, acquiring agreement, place of establishment and actual operations; it does not assign receipts to the owner by default.
LLC using a European provider while managed from Spain
Neither inclusion nor exclusion should be assumed. A provider operating through a Spanish branch or under freedom to provide services can fall within the rule when it manages collections for a business established in Spain. Contractual, registration and operational facts should tell the same story.
Personal payment between two people
A genuine C2C Bizum remains outside Modelo 170. If the payment actually compensates a sale or service, calling it personal does not change the commercial facts.
Build a payment setup that explains itself
A sound LLC does not depend on ambiguity. Its providers, documents and accounts should identify one business consistently.
Corporate identity
Keep the full legal name, EIN, registered address, operating address, ownership, managers and authorised signers current. The merchant name shown by a processor should connect naturally to the invoice and payout statement.
Collection agreement
Retain the exact Stripe, PayPal, bank or acquirer entity contracting with the LLC, the approved countries, services and settlement account. A brand name is not a contract.
Sale and invoice
The order, subscription or service agreement should point to an invoice issued by the entity that made the sale. VAT or other indirect-tax treatment depends on product, customer and place-of-supply rules, not on the visual design of the payment button.
Settlement trail
A EUR 100 sale may produce a EUR 96 payout after fees or be bundled with other charges. Processor statements should preserve gross sales, refunds, fees and net settlement without changing the identity of the underlying revenue.
Company account
Wherever possible, settlement should reach an account held by the LLC. Sending company sales to a personal account weakens separation, complicates onboarding and creates explanations that a direct structure would avoid.
Use each payment rail for a defined purpose
Bizum can suit local commercial collections. Card acquiring can reach global customers. ACH and wire support USD activity; SEPA supports EUR flows; a Merchant of Record assumes a different commercial role.
A well-designed stack can combine:
- a US operating account for the LLC;
- EUR capability where the customer base needs it;
- card processing for checkout;
- ACH for US clients and suppliers;
- SEPA for European counterparties;
- a clear policy for currencies, refunds and reserves.
An LLC is much more than a bank account. It is the entity that contracts, invoices, holds treasury, accesses financial providers and carries the business forward. Payment tools should reinforce that structure rather than replace it.
Exentax connects the full payment architecture
Exentax designs the relationship between the LLC, its business activity, tax position, banking and collection channels. Before selecting a gateway, we establish who will sell, where the activity is carried out, which markets and currencies matter and which regulated entity sits behind each provider.
We then coordinate LLC records, USD and EUR banking, processors, invoicing and the applicable tax analysis. The aim is not fewer options. It is a company that can use more options with one coherent identity: ready to collect, pay, reinvest and grow without rebuilding its story for every new provider.
Questions businesses ask about cards, Bizum and AEAT
Does AEAT receive every Bizum from 2026?
No. Modelo 170 expressly excludes person-to-person payments. It covers qualifying collections received by businesses and professionals established in Spain through card or mobile-number-linked systems.
Does the merchant file Modelo 170?
Not merely because it receives payments. Covered banks, payment institutions, e-money institutions and collection providers file it. The merchant retains its own accounting and tax responsibilities.
Does the old EUR 3,000 threshold still apply?
No. For the redesigned Modelo 170 applying from 2026, AEAT confirms that covered merchant collections are reported regardless of amount.
Are card spend and card collections the same report?
No. One is an expense seen from the cardholder's side; the other is revenue processed for a merchant. Modelos 170 and 174 observe different sides of the payment.
Does a US LLC automatically avoid Modelo 170?
No automatic rule says so. The merchant, establishment, provider and service must be reviewed. The LLC does, however, provide a strong legal framework for keeping the seller, contract, invoice and account properly separated.
Does Spanish residence make my LLC's collections personal?
Not by itself. The LLC can remain the seller and payment-account holder. The owner's residence and applicable taxation are separate analyses based on the real activity.
Do Stripe, PayPal or a foreign acquirer always file Modelo 170?
The brand alone cannot answer that. Identify the contracting entity and whether it operates inside the Spanish scope, including through a branch or freedom to provide services, for a merchant established in Spain.
Does Modelo 170 calculate tax due?
No. It is an information return filed by the provider. The business's tax position depends on its entity, classification, residence, activity and income-source rules.
Collect through a company built for growth
Spain's 2026 changes reinforce a basic operating principle: the payment method should connect to the entity making the sale. For a US LLC, that means a dedicated merchant profile, coherent invoices, company accounts and providers chosen for their actual function.
When designed properly, that infrastructure expands rather than restricts the company. It can combine markets, currencies and payment rails while preserving the LLC's legal, banking and operating value. Reporting becomes one understood layer of the structure, not the strategy itself.