Form 390 for Self-Employed in 2026: What It Is, How to Fill It In and When to Submit It
By Velnor Capital Team • • 8 min read
Every January, thousands of Spanish self-employed professionals face the same challenge: completing Form 390, the annual VAT summary, without making costly mistakes. According to data from the Agencia Tributaria (AEAT), VAT-related errors and omissions are among the top five reasons for tax inspections targeting autónomos, with penalties starting at €150 for minor infractions and reaching 50–150% of the unpaid amount for serious ones. With over 3.3 million self-employed workers registered in Spain as of early 2026, the stakes have never been higher — and yet many still confuse this form with a payment form, or miss the filing deadline entirely.
From a legal and fiscal standpoint, Form 390 (Modelo 390) is governed by Order EHA/3111/2009 and subsequent updates from the AEAT. It is a purely informational declaration — meaning no payment is made through it — that consolidates all quarterly VAT data submitted throughout the year via Form 303. It must be filed by all VAT-registered taxpayers, including autónomos under the general VAT regime, with some exceptions for those on simplified schemes. Understanding the distinction between this annual summary and the quarterly liquidations is essential to staying compliant in 2026.
In this guide, you will learn exactly what Form 390 is, who must file it, how to fill it in step by step with real numerical examples, what the most common mistakes are and how to avoid them, which documentation you need to gather, and what tools can simplify the entire process. Whether you are a freelancer filing for the first time or a seasoned self-employed professional looking to streamline your annual obligations, this article covers everything you need to know — for informational purposes only.
What Is Form 390 and How Does It Work?
Form 390 (Modelo 390) is the annual VAT summary declaration (declaración anual de IVA) that self-employed professionals and companies registered for VAT in Spain must submit once a year. It does not generate a payment or a refund on its own — it simply aggregates all the VAT data already declared across the four quarterly Form 303 submissions made during the fiscal year.
Think of it as an annual reconciliation: the AEAT uses it to cross-check that the quarterly figures you reported throughout the year add up correctly, and to verify consistency with other tax obligations such as Form 347 (operations with third parties over €3,005.06).
Real numerical example: Imagine an autónomo who invoiced the following VAT in 2025:
Annual totals for Form 390: VAT accrued = €8,200 / VAT deductible = €3,000 / Total net paid = €5,200
Form 390 must reflect exactly these cumulative figures. Any discrepancy between the 390 and the four 303s will trigger an automatic alert from the AEAT system.
Who Must File Form 390 in 2026?
Autónomos Under the General VAT Regime
All self-employed professionals registered under the general VAT regime (régimen general del IVA) must file Form 390 annually. This is the most common scenario for freelancers providing professional services, consultants, designers, architects, and most tradespeople.
Companies and SMEs
Legal entities (S.L., S.A.) that submit quarterly VAT liquidations via Form 303 must also file Form 390, regardless of turnover size.
Autónomos Under the Simplified VAT Regime (Régimen Simplificado)
Self-employed workers who apply the simplified VAT regime (módulos) also have an obligation to file Form 390, consolidating the annual VAT settlement specific to their activity modules.
Who Is EXEMPT from Form 390?
Since 2014, certain taxpayers are exempt from filing Form 390 if they meet both of the following conditions:
▸They file Form 303 monthly (monthly VAT filers — typically large businesses or those registered in the Registro de Devolución Mensual, REDEME).
▸They submit their Form 303 electronically.
These taxpayers instead complete specific additional fields in their last monthly Form 303 (December) that serve as the annual summary.
Autónomos in Special VAT Regimes
Self-employed professionals operating under the special VAT regime for travel agencies, second-hand goods, art, or agricultural activities have specific rules — always verify with a qualified tax advisor whether Form 390 applies to your specific scheme.
Want to optimize your taxes automatically?
Velnor Capital's AI CFO analyzes your finances in real time, identifies missing deductions, and alerts you before each tax deadline.
Enter your NIF (tax identification number), name or business name, fiscal year (2025 for the 2026 filing), and the main economic activity with its IAE epigraph code. Tick the appropriate boxes for your VAT regime and whether you carry out operations exclusively in Spanish territory or also in the Canary Islands, Ceuta, or Melilla.
For each rate, enter the taxable base and the corresponding VAT amount. These figures must match the sum of all four quarterly Form 303 submissions.
Section 3: Deductible VAT — Current Operations (Boxes 190–280)
Here you declare all VAT paid on purchases, expenses, and investments that are deductible for your business activity. Key categories include:
▸Current goods and services
▸Real estate investments
▸Movable capital goods (vehicles, machinery, equipment)
▸Imports
Ensure the deductible expenses underlying these VAT amounts are properly documented and business-related.
Section 4: Annual Settlement Result (Boxes 640–660)
This section calculates the net VAT position for the year — the difference between accrued VAT and deductible VAT. It must reconcile with the sum of all quarterly results from Form 303. If you are owed a refund, it will appear here — but remember, the actual refund was requested (or not) through your quarterly 303 filings.
Section 5: Pro-Rata and Partial Deduction Information (if applicable)
If you carry out both VAT-exempt and VAT-taxable activities (for example, a consultant who also teaches accredited courses), you must apply the pro-rata rule and declare the applicable percentage here.
Common Mistakes When Filing Form 390
Concept
Why it does NOT apply / Common error
"Form 390 generates a VAT payment"
False — it is purely informational; payments are made via Form 303
Copying Q4 data only instead of annual totals
Form 390 requires the SUM of all four quarters, not just Q4
Forgetting intra-EU acquisitions
These must appear in Form 390 even if declared in Form 349
Applying 100% VAT deduction on mixed-use assets
Partial deduction or pro-rata rules must apply (e.g., car used 50% privately)
Omitting investment VAT adjustments
Capital goods regularisation must be reflected if assets were sold or use changed
Submitting after January 31
The deadline is January 31 — late filing triggers automatic penalties from €150
Mismatching figures with Form 303 quarterly data
AEAT systems cross-check automatically; discrepancies trigger inspection alerts
Documentation You Need to File Form 390
Before sitting down to complete Form 390, gather the following documents:
▸All four quarterly Form 303 submissions for fiscal year 2025 — these are your primary data source.
▸Sales invoices issued during the year, classified by VAT rate applied.
▸Purchase and expense invoices supporting your deductible VAT claims, including supplier NIF and correct VAT breakdown.
▸Customs documents for any imports (DUA — Documento Único Aduanero).
▸Intra-EU acquisition records and any Form 349 (Recapitulative Statement) submitted during the year.
▸Fixed asset register if you purchased capital goods (machinery, vehicles, computers) to correctly apply investment VAT and regularisation rules.
▸Pro-rata calculation if you have mixed-activity VAT status.
Keeping these records organised throughout the year — not just in January — is the single most effective way to reduce errors and filing time. Good digital accounting software can automate much of this reconciliation automatically.
Practical Example: Annual VAT Summary Table
The following example illustrates a typical autónomo providing IT consulting services at 21% VAT, with quarterly data consolidated into Form 390:
Period
Taxable Base (Sales)
VAT Accrued (21%)
Taxable Base (Purchases)
VAT Deductible (21%)
Net VAT Paid
Q1 — Form 303
€10,000
€2,100
€3,810
€800
€1,300
Q2 — Form 303
€8,571
€1,800
€2,857
€600
€1,200
Q3 — Form 303
€11,429
€2,400
€4,286
€900
€1,500
Q4 — Form 303
€9,048
€1,900
€3,333
€700
€1,200
TOTAL — Form 390
€39,048
€8,200
€14,286
€3,000
€5,200
In this example, Form 390 Box entries would show: accrued VAT at 21% = €8,200, deductible VAT on current operations = €3,000, annual net result = €5,200 (already paid across four quarterly Form 303 submissions). The form confirms no additional payment or refund is pending.
This autónomo also has a quarterly IRPF obligation — if you want to understand how your income tax interacts with VAT declarations, the guide on quarterly IRPF declarations for autónomos in 2026 covers the complete picture.
When to Submit Form 390: Deadlines in 2026
The filing deadline for Form 390 corresponding to fiscal year 2025 is January 31, 2026 — the same deadline as the last quarterly Form 303 for Q4 2025.
Key deadline summary:
▸Period covered: Full fiscal year 2025 (January 1 – December 31, 2025)
▸Filing deadline: January 31, 2026
▸Filing method: Exclusively electronic via the AEAT online portal (Sede Electrónica), using a digital certificate, Cl@ve PIN, or through an authorised tax representative
▸Paper filing: Not permitted for Form 390
Missing this deadline results in automatic penalties: €100 for late filing without prior AEAT request, and up to €200 if the AEAT must formally request the declaration first. In cases where the late filing reveals unpaid tax (though Form 390 itself generates no payment), broader surcharges and interest apply.
Tools and Automation: File Form 390 Without Stress
Managing VAT reconciliation manually — cross-checking four quarterly Form 303 submissions, categorising invoices by VAT rate, calculating pro-rata percentages — is time-consuming and error-prone. For self-employed professionals managing their own finances, digital accounting tools that automatically aggregate quarterly data into annual summaries can save hours every January and dramatically reduce the risk of mismatches that trigger AEAT alerts.
Velnor Capital (from €19.99/month) is designed specifically for Spanish autónomos and SMEs, helping you track VAT automatically across the year so that completing Form 390 becomes a matter of reviewing pre-populated data rather than manually reconciling spreadsheets. The platform keeps your quarterly figures aligned and ready for your annual summary — giving you and your tax advisor a clean, verified data set every January.
Official source: Agencia Tributaria — AEAT (Spanish Tax Agency). The information in this article is for informational purposes only. Always consult a tax advisor for your specific situation.
Manage your finances with AI from €19.99/month
Invoicing, expense tracking, AI tax advisor and AI CFO in one place. No hidden fees. Cancel anytime.
Compare direct estimation vs modules (estimación directa vs módulos) for Spanish self-employed in 2026. Real examples, AEAT rules, limits, and how to choose the right IRPF regime.
Complete guide to Form 111 (modelo 111) for self-employed professionals and SMEs in Spain in 2026. Learn who must file it, how to fill it in step by step, real IRPF withholding examples, deadlines and common mistakes to avoid.