Spain Updates VAT Return Forms Effective 1 February 2026

Updated VAT Forms in Spain Effective February 2026

From 1 February 2026, the Spanish Tax Agency has introduced technical amendments to several VAT return forms and the SII (Immediate Supply of Information) system. These changes follow the approval of a new payment-on-account mechanism for VAT applicable to certain fuel supplies released from a non-customs warehousing regime.

While the update is sector-specific and mainly relevant to operators in the fuel supply chain, it is important for businesses to understand how the revised forms operate and whether any compliance adjustments are required.

By means of Order HAC/1495/2025 of 17 December, the Spanish authorities approved Model 319, establishing a mandatory VAT payment on account mechanism applicable to certain fuel deliveries made after goods leave the non-customs warehousing regime. The conditions and procedure for filing and paying this advance VAT amount.

The objective of the measure is to strengthen VAT control within the fuel sector by requiring an advance payment that can subsequently be deducted in the corresponding VAT return.

Learn more about new guarantee regime for fuel VAT warehousing.

Amendments to VAT Return Forms

To allow deduction of the new payment on account introduced via Model 319, the Spanish Tax Agency has amended the following VAT return forms:

• Form 303, periodic VAT return
• Form 322, individual VAT return for entities under the VAT group regime
• Form 353, aggregated VAT return for VAT groups
• Form 390, annual VAT return

New specific fields have been introduced to reflect VAT payments made on account under the fuel guarantee regime, and to allow taxable persons to deduct those advance payments in the VAT period in which the subsequent taxable and non-exempt supply is declared.

These changes are technical and ensure coherence between the payment-on-account system and the regular VAT self-assessment process.

For businesses outside the fuel distribution and warehousing chain, these amendments are unlikely to affect periodic VAT reporting.

New Field in the SII

In addition to the VAT return amendments, a new field has been added to the SII records (Suministro Inmediato de Información, in the local language) layout within the Book of Issued Invoices.

This new data field is designed to identify invoices documenting supplies of fuel extracted from a fiscal warehouse following the provision of the relevant guarantee/payment mechanism.

This adjustment strengthens traceability and reporting transparency in the fuel sector under the SII system. Businesses required to submit invoice data through SII and operating in the fuel supply chain should ensure that their ERP and reporting systems are updated accordingly.

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As a conclusion, the Spanish VAT return updates effective 1 February 2026 align the VAT reporting framework with the newly introduced payment-on-account mechanism for certain fuel supplies. Take a look at the official Order introducing the updated VAT forms.

Although the amendments modify several core VAT forms and introduce an additional SII reporting field, the practical impact remains limited to operators within the fuel and VAT warehousing sector. Businesses active in this area should review their compliance processes and ensure their VAT reporting systems are aligned with the new requirements.