Modelo 210 Guide
Received a Requerimiento or Propuesta from the AEAT? How to Respond Correctly (2026 Deadlines)
Requerimiento, Propuesta de liquidación, or Providencia de apremio from the AEAT? Deadlines, penalties, and the right next steps for non-residents.
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Received a Letter from the AEAT — The Short Answer
A letter from the AEAT (Agencia Tributaria, the Spanish tax authority) is not, in itself, cause for panic — but it's also not something you should ignore. Spanish administrative letters carry varying degrees of legal weight: some are purely informational with no action required, while others demand a response within a matter of working days. What matters is correctly identifying the type of letter, since this determines both the applicable deadline and the consequences of not responding.
What Does Requerimiento Mean?
A requerimiento is a formal request from the Spanish tax authority (AEAT) asking you to provide additional information or documents relating to an existing tax return.
The Main Types of Letters at a Glance
| Letter type | What it means | Response required? | Typical deadline |
|---|---|---|---|
| Comunicación | Purely informational letter | No | — |
| Requerimiento | Request for documents or clarification on a specific point | Yes, always | 10–15 working days |
| Propuesta de liquidación | A proposed, different tax calculation that the AEAT considers correct | Yes — otherwise it moves to a Liquidación provisional | 15 working days to object (Alegaciones) |
| Liquidación provisional | A provisional administrative assessment issued after the objection period expires or after reviewing submitted objections | Yes — appeal possible | 1 month for Recurso de reposición or a TEAR appeal |
| Providencia de apremio | Payment demand for an already-due, unpaid debt | Yes, payment required | As stated in the letter |
| Notificación de expediente sancionador | Notice of a penalty procedure | Yes, objection possible | 10 working days |
Important: all deadlines are calculated in working days (días hábiles) — Saturdays, Sundays, and Spanish public holidays don't count.
Requerimiento: The Most Common Type of Letter
A requerimiento is usually the mildest type of letter — the AEAT is asking for additional information or documents because data available to them doesn't match your tax return. Typical reasons for non-residents:
- A missing or incomplete Modelo 210 return for a particular year
- Discrepancies between reported rental income (e.g. via Modelo 238 from platforms like Airbnb) and your own return
- Missing evidence for deducted expenses
Important: a requerimiento must always be answered — even if you don't have the requested documents, you must inform the AEAT of this rather than not responding at all.
Propuesta de Liquidación: When the AEAT Proposes a Different Calculation
With a propuesta de liquidación provisional, the AEAT has already carried out its own calculation of your tax liability — usually because data from other sources (banks, platforms, the land registry) doesn't match your return.
Two options:
- Agree (Conformidad): you accept the AEAT's proposal
- Object (Alegaciones): within 15 working days, you can respond with evidence and arguments
Important: if you don't respond within the deadline, the process generally moves into a Liquidación provisional — the AEAT formally confirms its original proposal as a (provisional) decision. Only against this Liquidación provisional can you still lodge an appeal — a Recurso de reposición or a complaint to the TEAR, each within one month of the Liquidación provisional being served. However, without a timely response to the original propuesta, you lose the ability to dispute the underlying facts through Alegaciones.
For a propuesta de liquidación relating to rental income, it's worth checking our guide to declaring rental income to review the underlying calculation.
What Happens If You Don't Respond at All?
The consequences differ significantly depending on whether a tax liability ultimately arises or not:
- Late, voluntary filing (no tax due): if you file before the AEAT prompts you to, and no tax is owed, there are generally no penalties (Art. 198.2 LGT).
- Non-filing only discovered after a prompt (no tax due): anyone who only responds to a requerimiento, or ignores it, risks penalties for formal breaches under Art. 198 LGT — the exact amount depends on the specific case.
- An existing tax liability: here, the consequences are considerably higher — the full tax debt plus late-payment interest, as well as a penalty under Art. 191 LGT, which varies depending on the severity of the breach (minor, serious, very serious) — in particularly serious cases, up to 100–150% of the tax debt.
Important: the exact penalty always depends on the individual case — in particular, whether a tax liability exists, whether you responded voluntarily or only after being prompted, and whether mitigating circumstances apply. A blanket estimate in advance is not possible.
Important regarding limitation periods: any action by the AEAT — including a requerimiento or a propuesta de liquidación — interrupts the four-year limitation period, which then starts running afresh from the date of service.
For more on the consequences of missing a regular filing deadline, see our guide on Modelo 210: Missed the Deadline — What to Do?.
What This Means in Practice for Non-Residents
- Open and read the letter immediately — the deadline starts from the date of service, not the date you actually read it
- Identify the exact type of letter — this determines both the deadline and the type of response required
- Respond within the deadline — even an incomplete but timely response is usually better than none at all
- For a propuesta de liquidación: carefully check whether the AEAT's calculation is correct before agreeing to it
- Keep proof of service — it's essential for calculating the deadline
What We See in Practice
At Fiscaro, we regularly observe two patterns on this topic:
Letters ignored out of uncertainty: many non-residents don't even open a Spanish administrative letter, or fail to respond out of uncertainty — yet not responding is usually the most expensive option, since deadlines pass and proposals become final automatically.
Requerimiento and propuesta confused: a requerimiento (a request for information) is mistakenly treated as an already-fixed tax liability — or, conversely, a propuesta de liquidación is misunderstood as a mere request for information and not answered within the deadline.
Calculate Your Regular Modelo 210 Tax Now
To avoid future letters in the first place, it's worth ensuring a correct and timely annual filing.
→ Calculate your Modelo 210 tax now
Common Mistakes
- Not opening or reading the letter promptly — the deadline keeps running regardless
- Ignoring a requerimiento because the requested documents are missing — even the absence of documents must be communicated to the AEAT
- Letting a propuesta de liquidación pass without comment — the process then moves into a Liquidación provisional
- Not keeping proof of service — makes it harder to correctly calculate deadlines in a dispute
- Agreeing too hastily without checking — particularly for imputed income or deducted expenses, it's worth reviewing the underlying calculation
FAQ
Do I have to respond to every letter from the AEAT? No — a pure comunicación (informational letter) requires no response. A requerimiento, propuesta de liquidación, or penalty procedure, however, must always be answered.
What's the difference between a requerimiento and a propuesta de liquidación? A requerimiento requests additional information or documents. A propuesta de liquidación already contains a specific tax calculation proposed by the AEAT, which you can agree to or dispute.
What happens if I miss the deadline? For a requerimiento, penalties may apply, with the amount depending on the individual case. For a propuesta de liquidación, the process moves into a Liquidación provisional — you can still appeal against this, but the ability to dispute the underlying facts through Alegaciones is lost.
Can I request an extension? For some procedures, an extension is possible if requested in good time before the original deadline expires — the details depend on the specific procedure.
Is a letter from the AEAT automatically a penalty? No. Many letters are routine requests to clarify discrepancies, not threats of sanctions. What matters is correctly identifying the type of letter.
What do I do if I disagree with the propuesta de liquidación? Within the deadline (15 working days from service of the propuesta), you can object with evidence and arguments (Alegaciones). If the assessment has already become final, you still have the option of a Recurso de reposición or an appeal to the TEAR — each within one month of the assessment being served.
Sources
- Ley 58/2003 (General Tax Act), Art. 93, 94 (Requerimientos)
- Ley 58/2003, Art. 156.3 (deadline for Alegaciones on a Propuesta de liquidación: 15 working days)
- Ley 58/2003, Art. 191 (penalties where a tax liability exists)
- Ley 58/2003, Art. 198 (penalties for non-filing without a tax liability)
- Ley 58/2003, Art. 66-70 (limitation periods and their interruption)
- AEAT: Manual práctico de notificaciones y requerimientos
Conclusion
A letter from the AEAT is rarely cause for panic, but always cause for a close look. The consequences of not responding are almost always more costly than a timely, even incomplete, response. Anyone who correctly identifies the type of letter and meets the relevant deadline stays in control of what happens next.
Fiscaro ensures correct, timely Modelo 210 filings so that letters like these don't become necessary in the first place.

Hanns-Christopher Deppe
Founder of Fiscaro · Real Estate Economist & Dipl. Industrial Engineer · Agent in Mallorca
Hanns-Christopher has lived in Mallorca for over 15 years and has guided hundreds of non-residents through their Spanish tax obligations. He founded Fiscaro to make the Modelo 210 process as simple as possible.
This article is for general information purposes only and does not constitute individual tax advice. For an assessment tailored to your specific circumstances, we recommend consulting a qualified tax adviser or Spanish gestoría.
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