Every Belgian company must file its annual accounts each year with the National Bank of Belgium. Miss that deadline and you pay more than a higher fee: you also put your liability as a director, your creditworthiness and, in the worst case, the survival of the company at stake. Whether you run a Belgian company, manage a Belgian subsidiary from abroad or want to check a Belgian business partner, this is what you need to know about the deadline, the cost and the consequences of late filing.
Who has to file annual accounts in Belgium?
The filing obligation is tied to the legal form. In short: anyone who enjoys limited liability has to make their figures public in return.
- Must file: the BV/SRL (private limited company), the NV/SA (public limited company), the CV/SC (cooperative) and the European company. Large and very large non-profit associations (VZW/ASBL), international non-profits and foundations also file with the National Bank (small associations file with the registry of the enterprise court, the court that handles company matters).
- Do not file: sole traders. A self-employed person trading in their own name keeps accounts but publishes nothing.
- Usually not: partnerships without limited liability (maatschap, VOF/SNC, CommV/SComm). They are exempt unless they are large according to the size criteria or one of their unlimited partners is itself a company.
Which format you have to file (micro, abbreviated or full) depends on the size of the company. A company is small when it does not exceed more than one of these thresholds: 50 employees, 11.25 million euro turnover, 6 million euro balance sheet total (10 employees, 900,000 euro and 450,000 euro for a micro company). Small and micro companies file an abbreviated format without turnover; large companies file the full format with turnover, a management report and a statutory auditor.
The deadline: timeline for a 31 December year end
The Belgian Companies and Associations Code (WVV/CSA) imposes two consecutive time limits. First, the general meeting must approve the annual accounts within 6 months after the end of the financial year. The board then has 30 days to file them with the Central Balance Sheet Office of the National Bank of Belgium (the central registry for all Belgian financial statements), and in any case no later than 7 months after the balance sheet date.
| Step | Deadline | Legal basis |
|---|---|---|
| End of financial year | 31 December | Balance sheet date set in the articles of association |
| Approval by the general meeting | 30 June | Within 6 months after year end |
| Filing with the National Bank | 31 July | Within 30 days after the general meeting, at the latest 7 months after year end |
| Late filing surcharge starts | 1 September | From the ninth month after year end |
If your financial year ends on another date, everything shifts accordingly: 30 June becomes "balance sheet date plus 6 months" and 31 July becomes "balance sheet date plus 7 months". Note that holding the general meeting earlier also means filing earlier. If the meeting approves the accounts on 15 May, the 30-day period already expires in mid-June.
What does filing with the National Bank cost?
The National Bank charges a publication fee for every filing. It depends on two things: the format (micro, abbreviated or full) and the way you file. A structured XBRL file is cheaper than a PDF, because the National Bank does not have to process the figures manually.
Expect roughly 60 to 300 euro, depending on the format and the filing method. A micro format in XBRL sits at the bottom of that range, a full format as a PDF at the top. The amounts are indexed every year; the current rates are published on the website of the Central Balance Sheet Office. A corrected filing (to fix an error) is charged separately.
Late: the late filing surcharge
If you file after the seventh month, the filing is registered as "late". In the eighth month you still pay the normal fee, but from the ninth month after the balance sheet date the National Bank adds a surcharge on top of the normal cost. This is the late filing penalty in practice. It grows the longer you wait, and is considerably higher for the full format than for the micro or abbreviated format.
| Moment of filing (31 December year end) | Micro or abbreviated format | Full format |
|---|---|---|
| Ninth month (September) | about 150 euro | about 500 euro |
| Tenth to twelfth month (October to December) | about 225 euro | about 750 euro |
| From the thirteenth month (January of the following year) | about 450 euro | about 1,500 euro |
These are indicative 2025 amounts, rounded and on top of the normal filing fee. The exact amounts are indexed every year by the National Bank. The surcharge applies per set of accounts filed: a company catching up on two financial years at once pays it twice.
Other consequences of late filing
The surcharge is the most visible consequence, but certainly not the most expensive one.
Presumption of director liability
Article 3:10 of the Companies and Associations Code states that damage suffered by third parties is presumed to result from the failure to file the annual accounts within the legal period. A supplier that extended credit to your company without being able to consult the figures and is then left unpaid can hold the directors personally liable. The board then has to prove that the damage had nothing to do with the missing accounts. That reversed burden of proof is far more dangerous for a director than a few hundred euro extra to the National Bank.
Judicial dissolution
A company that fails to file its annual accounts for three consecutive financial years can be dissolved by the enterprise court. But it does not have to get that far: from the seventh month after the balance sheet date, any interested party (a creditor, a shareholder) or the public prosecutor can already apply for dissolution. The court may grant a period to regularise the situation, but do not count on it.
Banks and credit
Banks, leasing companies and credit insurers pull their figures directly from the Central Balance Sheet Office. If the latest financial year is missing, your company falls back on an outdated or incomplete profile, which often means a lower credit line or a refused financing. A late filing also remains visible: the filing date stays attached to the accounts forever.
What it signals to customers and suppliers
Credit controllers and buyers read late accounts as a flashing light. In practice, delay often points to a dispute with the accountant, figures that had to be "tidied up", or simply no money to pay the bookkeeper. It is no coincidence that it is one of the 5 warning signs of an approaching bankruptcy. A company that files late gives its business partners a reason to insist on prepayment or shorter payment terms.
Checking whether a company filed on time
You can retrieve annual accounts from the Central Balance Sheet Office, but it is faster through the search function of Jaarrekening.be. Search by name or enterprise number and open the "Financial statements" tab. There you see, for each financial year, the filing date, the format used and the figures themselves. The full walkthrough is in Belgian annual accounts: how to find a company's figures.
What to look for:
- Filing date after 31 July (for a 31 December year end): late. A few weeks is a point of attention, a few months is a red flag.
- Later every year: a pattern says more than a single outlier.
- Latest financial year missing: already past September of the following year and still nothing? Then combine this with the other signals on the "Publications" tab.
Already late? Do this now
Missed the deadline yourself? Then file as soon as possible anyway. Every month you wait makes the surcharge more expensive and keeps the presumption of liability alive. Concretely:
- Have the annual accounts approved by the general meeting, even outside the legal period. A late approval is better than no approval.
- File through the Filing application of the Central Balance Sheet Office, preferably in XBRL. The surcharge is calculated automatically and invoiced together with the normal fee.
- Several financial years outstanding? File them in chronological order and catch up in one go. That immediately closes the door on a claim for judicial dissolution.
In summary
For a financial year ending on 31 December, the general meeting approves the annual accounts by 30 June and the company files by 31 July. Filing on time costs a few dozen to a few hundred euro; from September a late filing surcharge is added that rises to well over a thousand euro for the full format. More importantly: as long as you do not file, you as a director are presumed liable for damage suffered by third parties, and judicial dissolution looms. Filing, even late, is therefore always the cheapest option.
