Cash accounting and other special VAT regimes (criterio de caja)

Terms used

• Criterio de caja — The criterio de caja is cash accounting for IVA: you account for IVA when money is actually paid or received.
• IVA — IVA is Spain's value added tax, charged on most sales of goods and services.
• Recargo de equivalencia — The recargo de equivalencia is a surcharge regime where retailers pay extra tax to suppliers and file no IVA returns on those sales.
• Módulos — Módulos is the simplified regime, where tax is calculated from fixed indicators of your activity instead of actual figures.
• Modelo 036 — Modelo 036 is the standard form for registering, changing or ending a business activity with the tax office.
• IRPF — IRPF is Spain's personal income tax.

Key rules

• Cash accounting limit: You can use cash accounting if your turnover last year was no more than EUR 2,000,000.
• Latest IVA date: Even if an invoice is never paid, IVA is due at the latest on 31 December of the year after the service.
• Cash payments: You cannot use cash accounting if one customer paid you more than EUR 100,000 in cash in the year.
• Services: The recargo de equivalencia is for retail traders selling goods, not for freelancers providing services.
• Simplified regime: Módulos is mostly closed to professional freelancers, and its limits are reset by a yearly order.

Which regime might suit you

Most freelancers use the normal IVA system, where IVA is due when you issue an invoice. Three special regimes change that timing. Cash accounting is the one most freelancers can realistically choose. The recargo de equivalencia is for shop-type traders. The simplified regime is mostly closed to professionals. Each has its own eligibility limits.

Cash accounting (criterio de caja)

Bottom line: you pay IVA on sales when your client pays you, and you deduct IVA on purchases when you pay your supplier. It helps if clients pay late, because you do not advance IVA you have not collected.

How it works:

• On sales, IVA is due when you collect the invoice, in whole or in part.
• On purchases, you deduct IVA when you pay the invoice, in whole or in part.
• If an invoice stays unpaid, the limit is the same on both sides: the IVA still counts at the latest on 31 December of the year after the service.
• Every invoice you issue must say "régimen especial del criterio de caja".

Who can use it: the limit is EUR 2,000,000 of turnover last year. You cannot use it if a single customer paid you more than EUR 100,000 in cash during the year. It is for taxpayers in the normal IVA system, not those in the recargo, simplified or exempt regimes.

How to opt in: use modelo 036 or 037. Do it when you register your activity, or in December for the following year. The choice renews automatically. It lasts at least to the end of the year you choose it, and runs for three years unless you renounce it. You can renounce the same way. If you go over the turnover limit, you leave the regime.

Watch for: your own suppliers may also be under cash accounting, and your clients will deduct IVA only when they pay you. Agree payment terms with that in mind.

Recargo de equivalencia

This regime is for retail traders who resell goods to final consumers without transforming them. It does not apply to freelancers who provide services.

Under it, your supplier adds a surcharge on top of IVA on what you buy, and you file no IVA returns on those retail sales. The 2025 surcharge rates were 5.2% on 21% IVA, 1.4% on 10% IVA, 0.5% on 4% IVA and 0.75% on tobacco. If you plan to sell goods in a shop, ask your gestor whether you fall under it.

Simplified regime (módulos)

This regime is for small businesses in activities listed in a yearly government order. It is linked to the IRPF method of estimating profit by modules. It is mostly not available to professional freelancers.

The turnover limits are EUR 250,000 for business activities, EUR 125,000 for invoices to other businesses, and EUR 250,000 for agriculture. In some cases a purchases limit of EUR 300,000 also applies. Limits and availability are set each year, so check the 2026 order with your gestor or tax office before relying on it.

Where to go next

The timeline and FAQ below cover the steps for cash accounting and common questions.

Timeline and deadlines

• Choose cash accounting with modelo 036 or 037: when you register, or in December for the next year

• Charge IVA on your sales when the client pays you, in whole or part, and write "régimen especial del criterio de caja" on your invoices: each time a payment arrives

• Deduct IVA on your purchases when you pay the supplier, in whole or part: each time you pay

• Account for any IVA still unpaid on your sales and purchases: at the latest on 31 December of the year after the operation

Frequently asked questions

Does the recargo de equivalencia apply to freelancers who provide services?

No, the recargo de equivalencia does not apply to freelancers who provide services. It is for retail traders who resell goods to final consumers without transforming them. Their supplier adds the surcharge on top of IVA, and the retailer files no IVA returns on those sales.

Can I use cash accounting if one customer pays me a lot in cash?

No, you cannot use cash accounting if one customer paid you more than EUR 100,000 in cash during the year. Other payment methods do not count towards that limit. Check your customers' payments before you choose the regime.

How do I opt in to cash accounting and how long does it last?

You opt in with modelo 036 or 037, either when you register or in December for the following year. The choice renews automatically each year and lasts at least until the end of the year you choose it, and for three years unless you renounce. You can revoke it the same way, and it ends if you exceed the limit.

Is the simplified regime (módulos) available to professional freelancers?

No, the simplified regime (régimen simplificado, known as módulos) is mostly not for professional freelancers. It covers small businesses in activities listed in a ministerial order, with turnover limits of EUR 250,000 for business activities and EUR 125,000 for invoices to businesses.