Key data
| Regulation | Resolution of August 26, 2026, of the Under-Secretariat, publishing the Agreement between AEAT and the Commission for the Prevention of Money Laundering and Monetary Infractions for the exchange of information |
|---|---|
| Publication | September 1, 2026 |
| Entry into force | September 1, 2026 |
| Replaces | Previous Agreement of 2006, extinguished by Law 40/2015 |
| Affected parties | Anti-money laundering obligated subjects: financial entities, tax advisors, notaries, real estate agencies and large companies |
| Category | Tax News |
| Year | 2026 |
| Legal framework | Article 95 LGT and article 46 of Law 10/2010 |
Banks, tax advisors, notaries, real estate agencies and large companies have from today a concrete reason to review their compliance procedures. The Resolution of August 26, 2026 publishes the new agreement between the State Tax Administration Agency (AEAT) and the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Infractions (SEPBLAC), which activates a permanent channel for information exchange between tax inspection and financial intelligence.
The previous agreement, signed in 2006, was extinguished by Law 40/2015. This new agreement is not a simple renewal: it establishes an updated framework, with electronic means and reinforced confidentiality guarantees, which enables the direct use of shared information in verification and inspection procedures.
What does this regulation establish?
The agreement creates a bidirectional flow of data between two bodies that until now operated with separate channels:
| Direction of flow | What information is shared | What it is used for |
|---|---|---|
| SEPBLAC → AEAT | Financial information with tax relevance | Tax verification and inspection procedures |
| AEAT → SEPBLAC | Reserved tax data | Anti-money laundering investigations |
Three technical elements define how this exchange works:
- Without additional prior request: authorities can directly use the shared information in their procedures, without the need to request each piece of data individually.
- By electronic means: the exchange will preferably be carried out electronically, which speeds up response times.
- With confidentiality guarantees: the applicable legal framework is article 95 of the General Tax Law (LGT) and article 46 of Law 10/2010 on the prevention of money laundering.
Economic and operational impact
The impact is not measured in a rate or a fixed amount: it is measured in inspection risk and exposure to sanctions. The agreement acts as a multiplier of the State's detection capacity over obligated subjects.
Until now, a company could have a tax irregularity without SEPBLAC knowing about it, or vice versa. With this agreement, information flows automatically between both bodies. The concrete operational consequences are:
- An alert in SEPBLAC for suspicious activity can trigger an AEAT inspection without the company anticipating it.
- A tax fact detected by AEAT can feed a SEPBLAC anti-money laundering investigation.
- Verification procedures can be initiated with already consolidated information, shortening the Administration's response times.
- Companies with deficiencies in their internal money laundering control systems are more exposed than before, because now data crossing is systematic and electronic.
For companies with compliance programs already in place, the operational impact is minor. For those that still do not have procedures updated in accordance with Law 10/2010, the risk is immediate.
Who does it affect?
The agreement directly affects all obligated subjects under Law 10/2010 on the prevention of money laundering and monetary infractions:
- Financial entities (banks, savings banks, credit cooperatives, payment entities)
- Tax and fiscal advisors
- Notaries
- Real estate agencies and developers
- Auditors of accounts
- Lawyers (when acting in financial or corporate operations)
- Administrative managers
- Large companies with complex financial operations
- Casinos and gaming establishments
- Jewelers, art galleries and dealers in high-value goods
Practical example
A tax advisory firm that manages the assets of several high-net-worth clients receives a communication from SEPBLAC regarding an operation that generated an alert in its detection system. Until now, that file would remain within SEPBLAC's scope.
With the new agreement in force from September 1, 2026, SEPBLAC can transfer that information to AEAT electronically and without the need for an additional request. AEAT, in turn, can initiate a verification procedure against the advisory firm or the affected clients using that data directly. The process is faster, more coordinated, and for the advisory firm, harder to anticipate if it does not have its internal procedures in order.
The same mechanism works in reverse: if AEAT detects in a routine inspection financial movements that do not match a client's income tax return, it can transfer that information to SEPBLAC to assess whether there is a money laundering risk.
What should companies do now?
- Review the anti-money laundering compliance program: verify that internal procedures are updated in accordance with Law 10/2010 and that the prevention manual covers current risk scenarios.
- Audit operations with greater exposure: identify transactions or clients that could generate cross-alerts between AEAT and SEPBLAC, especially in the last non-prescribed fiscal years.
- Strengthen compliance team training: personnel responsible for money laundering prevention must know that AEAT now has access to SEPBLAC information and vice versa, and act accordingly.
- Review communication channels with both bodies: ensure that the designated contacts with SEPBLAC and AEAT are correctly identified and up to date.
- Consult with specialized legal advisor: if there are doubts about the current compliance situation, this is the time to conduct a preventive review before an inspection arrives.
Frequently asked questions
What changes compared to the previous 2006 agreement?
The 2006 agreement was extinguished by Law 40/2015 and ceased to be in force. The new agreement, in force from September 1, 2026, is not an extension but a completely new agreement that incorporates electronic data exchange, updates the legal framework to Law 10/2010 and article 95 LGT, and eliminates the need for additional prior request to use shared information in inspection procedures.
Can AEAT initiate an inspection solely with SEPBLAC data?
Yes. The agreement expressly enables authorities to use shared information directly in verification and inspection procedures, without the need for an additional prior request. This means that financial data transferred by SEPBLAC can be sufficient for AEAT to open a verification file.
What confidentiality guarantees exist for shared data?
The agreement establishes strict confidentiality guarantees in accordance with two legal frameworks: article 95 of the General Tax Law (LGT), which regulates the reserved nature of tax data, and article 46 of Law 10/2010, which regulates confidentiality in the anti-money laundering field. Data can only be used for the purposes provided for in the agreement.
Which obligated subjects should pay more attention?
Obligated subjects under Law 10/2010 are the most exposed: financial entities, tax advisors, notaries, real estate agencies, auditors, lawyers acting in financial operations, administrative managers, casinos and dealers in high-value goods. For all of them, the data crossing between AEAT and SEPBLAC directly increases the risk of detecting irregularities.
When does this agreement come into force?
The agreement came into force on the same day as its publication in the BOE: September 1, 2026. There is no transitional period: the exchange of information between AEAT and SEPBLAC is operational from that date.
Official source
Consult complete regulation in official source
Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-18416
