Belgian annual accounts: filing deadline, late-filing fines and what a late filer tells you
Tips
The short answer
A Belgian company must file its annual accounts with the National Bank's Central Balance Sheet Office within 30 days of approval by the general meeting, and no later than seven months after the end of the financial year. For a year ending 31 December, that means 31 July. File more than a month after that deadline and a surcharge is added to the filing fee. In 2026 it is 151 euros for small companies using the abbreviated or micro model and 504 euros for the others in the ninth month after year end, 227 or 755 euros in months ten to twelve, and 453 or 1,510 euros from the thirteenth month. A company that does not file also risks damages claims, being struck off the KBO and judicial dissolution. For a seller, a missing filing is a free warning sign.
Deadlines and amounts come from the National Bank's Central Balance Sheet Office pages and the Code of Companies and Associations on Justel, read on 30 September 2026. This is general information, not legal advice.
The filing deadline
Two deadlines stack. The board must put the accounts to the general meeting for approval within six months of the financial year end (article 3:1 of the Code of Companies and Associations). The accounts must then be filed with the National Bank within thirty days of approval, and at the latest seven months after year end (articles 3:10 and 3:12).
Financial year ends | General meeting at the latest | Filing at the latest | Surcharge from |
|---|---|---|---|
31 December 2025 | 30 June 2026 | 31 July 2026 | 1 September 2026 |
31 March 2026 | 30 September 2026 | 31 October 2026 | 1 December 2026 |
A company in liquidation cannot have its accounts approved, but must still submit them to the general meeting and file within a month of that, still within seven months of year end, according to the National Bank. How to find a filing once it is in is covered in how to look up Belgian annual accounts.
Who must file with the National Bank
Companies: public limited companies (NV/SA), private limited companies (BV/SRL), cooperative companies (CV/SC), European companies and EEIGs.
Partnerships (VOF/SNC, CommV/SCS) only in specific cases: large ones with at least one legal entity among their partners. Small partnerships, and large ones whose partners are all natural persons, do not file.
Associations and foundations that exceed more than one of these: 5 employees on average, 391,000 euros in recurring revenue, 1,562,000 euros in total assets, 1,562,000 euros in total debts. Smaller ones file at the registry of the enterprise court instead.
Foreign companies with a Belgian branch, health insurance funds and certain investment funds.
Sole traders working in their own name do not file annual accounts, so a missing filing means nothing for them.
The late-filing surcharge in 2026
The surcharge applies when the accounts are filed more than one month after the seven-month deadline (article 3:13). The law calls it a contribution to the costs the federal authorities incur in detecting and monitoring companies in difficulty. It comes on top of the normal filing fee.
Filed in | Small company, abbreviated or micro model | Other companies |
|---|---|---|
Month 8 after year end | No surcharge | No surcharge |
Month 9 | 151 euros | 504 euros |
Months 10 to 12 | 227 euros | 755 euros |
Month 13 onwards | 453 euros | 1,510 euros |
Source: National Bank of Belgium, amounts valid from 1 January 2026. They are indexed every 1 January (in 2025 they were 148, 222 and 443 euros, and 492, 737 and 1,474 euros). The column depends on the model filed: a small company that files the full model pays the higher amounts. The National Bank says it cannot grant exceptions. The only way back is a refund request for force majeure, filed no later than eighteen months after the end of the financial year concerned.
What else happens when a company does not file
Presumed damage. If the accounts are not filed on time, damage suffered by third parties is presumed, unless proven otherwise, to result from that failure (articles 3:1 and 3:10).
Struck off the KBO. A company that has not filed for at least three consecutive financial years can be struck off ex officio by the Crossroads Bank for Enterprises. The striking off is withdrawn once the missing accounts are filed (article III.42 of the Code of Economic Law). It shows in the company's KBO record; the Belgian company register guide explains where.
Judicial dissolution. The enterprise court can dissolve a company that has not met its filing obligation, at the request of any interested party or the public prosecutor, or after a referral by the chamber for enterprises in difficulty. The claim can only be brought once seven months have passed since year end, and the court can grant a period to regularise instead of dissolving (article 2:74). What follows is covered in what it means when a company is in liquidation.
Director liability in a bankruptcy. If debts exceed assets, current and former directors can be held personally liable for the shortfall when a manifestly grave fault on their part contributed to the bankruptcy (article XX.225 of the Code of Economic Law). The article names serious tax fraud as always being such a fault; it does not name non-filing, so the court judges each case. It does not apply to companies with average turnover below 620,000 euros excluding VAT over the last three years and a balance sheet total of no more than 370,000 euros.
How common late filing is
The National Bank counted 566,637 filings for 2024. 61% arrived on time, 24% less than a month late, about 12% one to three months late and 2.5% more than three months late.
What a late filer tells you
For sales and credit teams, the date matters as much as the figures. A company that has filed on time for years and suddenly files months late has not become disorganised overnight. Often there is a dispute with an accountant, a delayed audit, or numbers nobody wants to publish. How to spot a customer heading for trouble puts this signal in order with the others: equity thinning, directors leaving, the registered office moving.
Year ending 31 December 2025, no accounts filed by | What it means |
|---|---|
31 July 2026 | Still within the legal deadline. Nothing to read into it. |
31 August 2026 | Late, no surcharge yet. Worth noting if the company usually files on time. |
From 1 September 2026 | Surcharge territory. Ask why, and check the other signals before you extend credit. |
From 1 January 2027 | A full year of figures missing. Treat it as a red flag. |
Three consecutive years | The KBO can strike the company off ex officio. |
Late accounts are also old accounts. When they do arrive, read them with that in mind: how to read Belgian annual accounts shows which three figures to look at, and is this company financially healthy? works through solvency, liquidity and profitability.
How to check filing dates
Open the company in Consult, the National Bank's free application, by enterprise number.
List the financial years that have been filed. A gap between years, or a last filed year that ended more than eight months ago, is what you are looking for.
Check the KBO record for an ex officio striking off for non-filing.
Check the status. A company already in bankruptcy or liquidation will not file normally; how to check whether a Belgian company is bankrupt covers that.
For a whole customer base, opening Consult account by account breaks down. Bizzy shows four years of filed accounts from the National Bank of Belgium on each Belgian company, with the filed PDF for every year, so a missing year is visible next to the figures without a separate lookup.
Frequently asked questions
When must a Belgian company file its annual accounts? Within 30 days of approval by the general meeting, and no later than seven months after the end of the financial year. For a year ending 31 December, that is 31 July.
How much is the fine for filing annual accounts late? In 2026, from the ninth month after year end: 151 euros for small companies on the abbreviated or micro model and 504 euros for others; 227 or 755 euros in months ten to twelve; 453 or 1,510 euros from the thirteenth month. It comes on top of the filing fee.
Can the late-filing surcharge be waived? The National Bank says it cannot grant exceptions. A company can ask for a refund in case of force majeure, at the latest eighteen months after the end of the financial year.
Can a company be dissolved for not filing its accounts? Yes. The enterprise court can dissolve a company that has not filed, at the request of an interested party or the public prosecutor, or after a referral by the chamber for enterprises in difficulty. Separately, the KBO can strike off a company that has not filed for three consecutive years.
Photo: the Grote Markt of Sint-Niklaas with the town hall, Sneeuwvlakte, CC BY-SA 4.0, via Wikimedia Commons