Annual accounts 2025: the late-filing surcharge starts on 1 September

The 31 December 2025 cohort has been in default since 1 August. On 1 September the National Bank starts charging for it, and the price is set by the model deposited — not by the size class of the client.

Two dates govern the annual accounts of a company that closed on 31 December 2025, and only one of them gets quoted.

The general meeting had to approve the accounts within six months of the close — 30 June 2026. The deposit with the Central Balance Sheet Office had to follow within thirty days of that approval, and in any case no later than seven months after the close: 31 July 2026. A file that is still unfiled today is not about to be late. It has been late for three weeks.

What changes on 1 September is not the deadline. It is the invoice.

The surcharge ladder

Art. 3:13 WVV provides for a tarieftoeslag on annual accounts filed on or after the first day of the ninth month following the close of the financial year. For a 31 December 2025 year-end that is 1 September 2026. The National Bank collects it together with the filing fee, for the account of FPS Finance.

The ladder steps; it does not accrue. A file that slips from 30 September to 1 October costs €76 more on the abridged model and €251 more on the full model, for a single day of delay. That shape matters for triage: between the steps, one more week costs nothing, and the day before a step costs everything.

The band follows the model filed

This is where secondary summaries go wrong, and it is the error a client will catch. The two columns are the model actually deposited — abridged or micro on one side, full on the other. A small company that is entitled to the abridged schema but files a full one, because the group reports that way or because a bank asked for it, pays €504 in September, not €151.

The size class determines what a company may file. The surcharge reads what it did file. On any file where the full model was chosen voluntarily, check the schema before you check the calendar — the difference is €353 in September and €1,057 from January.

The date that counts is the date of submission

The surcharge attaches to the deposit, not to the payment. Accounts submitted on 31 August 2026 fall outside the surcharge even where the National Bank debits the fee in September, and even where the deposit is processed afterwards. Accounts submitted at five past midnight on 1 September are inside it.

For a practice holding a stack of unfiled files, that single sentence is the plan for the week: everything that can be approved and deposited before midnight on 31 August saves between €151 and €504 per file. On the abridged and micro models, the saving exceeds the entire filing fee.

The fee itself: structured against PDF

Filing fees for 2026, VAT included:

Roughly €70 per file, per year, for choosing a format. Across a portfolio of eighty client files that is roughly €5,600 annually, and it is the same money whether the file goes out in March or in November. Where any part of the portfolio still leaves as PDF, that is the cheapest correction available in this profession — and unlike the ladder, it applies to files that are perfectly on time.

What sits on top of the National Bank's bill

The surcharge is an administrative tariff. It is not the sanction, and a client who has paid it is not settled up.

Three exposures run alongside it:

• A tax fine of €25 to €250 per elapsed month, imposed separately for the late filing.
• Directors' liability. Damage suffered by a third party is presumed to result from the missing filing, and it is the director who must prove otherwise. A late deposit is therefore not a private matter between the company and the NBB.
• Art. 2:74 WVV. After three consecutive financial years of unfiled annual accounts, the enterprise court may pronounce the dissolution of the company on the application of any interested party — a creditor, a competitor, the public prosecutor. Regularisation of every outstanding filing before judgment is a complete defence.

That last rule sets a priority most file plans get backwards: on a multi-year arrears file, the year to close first is the oldest unfiled one, because the trigger counts consecutive years rather than totals.

Force majeure

A refund of the surcharge can be requested on force-majeure grounds. It is a request, judged on facts — illness, fire, an event that made deposit genuinely impossible — and not a remedy for a compressed season. Document the ground while it is happening. A justification reconstructed six months later rarely persuades.

The work order for this week

1. Sort the unfiled files by band, not by client size. Everything that can reach the National Bank before midnight on 31 August pays nothing extra. That is the only cohort with a deadline this week.
2. For each remaining file, price the next step. A file that cannot be ready in August has until 31 December before it moves from €227 / €755 to €453 / €1,510. The date to protect is 31 December — not "as soon as possible", which is not a date and does not survive October.
3. Confirm the schema on every full-model deposit. Where the full model was voluntary and the abridged one is available, the surcharge falls from €504 to €151 and the fee from €379.50 to €89.40, before counting the work saved.
4. Check that the general meeting was actually held and minuted. Depositing without a valid approval solves the tariff problem and leaves the governance one intact. Two obligations, one receipt.
5. Pull the oldest unfiled year forward on any file carrying more than one year of arrears.

Nothing in the ladder is discretionary and nothing in it is negotiable at the counter. The only variable a practice controls is the day the file leaves it — which is why the triage question this week is not "who is late" but "who can still be deposited before Monday".