Does your company carry out a significant volume of transactions with foreign companies or hold assets and liabilities abroad?
The third quarter of 2026 ends on 30 September. For certain companies, this means an additional reporting obligation before the Bank of Spain: filing the quarterly Form ETE.
Companies subject to quarterly reporting will have until 20 October 2026 to submit the information relating to the quarter.
Beyond the filing deadline itself, this point in the year is also a good opportunity to check whether changes in the company’s international activity during 2026 may have altered its reporting frequency.
Which companies should pay attention to the third-quarter close?
Generally, quarterly Form ETE reporting applies to residents in Spain whose transactions with non-residents during the previous year, or whose year-end balances of foreign assets and liabilities as of 31 December, reached €100 million or more but remained below €300 million.
Therefore, not every company working with international customers or suppliers is required to file a quarterly return.
However, there is another point that should be monitored during the year.
Growth in international activity during 2026 may change the reporting frequency
Bank of Spain Circular 4/2012 also covers situations where a company did not initially reach the relevant thresholds but exceeds them during the year.
If, during 2026, transactions with non-residents or balances of foreign assets and liabilities increase beyond one of the applicable thresholds, the company becomes subject to the corresponding reporting frequency from the moment that threshold is exceeded.
For this reason, the September close is a useful time to review not only the obligations the company has already been meeting, but also whether growth in its international activity has created a new reporting requirement.
What should companies review before 30 September?
Companies with significant international activity should check, among other matters:
- The volume of transactions carried out with non-residents.
- The balances of foreign assets and liabilities.
- Whether any threshold affecting the reporting frequency has been exceeded during 2026.
- Whether the information required to prepare the third-quarter return has been properly collected.
Carrying out this review in advance provides additional time before the filing period begins. It can also help identify changes compared with previous quarters or financial years.
Do you need to understand how Form ETE works?
Form ETE is an information reporting obligation with different filing frequencies and requirements depending on the volume of each company’s international transactions.
If you need to review what Form ETE is, who must file it, which information must be included or how it is submitted, you can consult our website content on the Bank of Spain Form ETE.
At LEIALTA, we support Spanish companies and international groups operating in Spain with the review and fulfilment of obligations linked to their cross-border activity, including the preparation of Form ETE filings before the Bank of Spain.
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