According to CoinMeta, the Spanish Tax Authority has confirmed that cryptocurrencies held in self-owned wallets do not need to be reported on Form 721, provided that the asset holders control the private keys and the assets are not held by foreign third parties. The Spanish Tax General Administration clarified this approach in a consultation issued on April 21, 2026. The reporting requirements of Form 721 depend on who controls and protects the private keys. According to the regulations, Form 721 applies to virtual currencies whose private keys are held by third parties and is applicable to Spanish residents and certain other entities. The Spanish Tax Authority distinguishes between managed and unmanaged wallets, emphasizing that no reporting is required when control lies with the user. This policy means that hardware wallets are not subject to the restrictions of Form 721 as long as the holder controls the private keys. Spain introduced a framework for reporting overseas cryptocurrencies in 2023, and the first reporting period will begin in 2024.