Regulatory4 min
Annual accounts 2025: the late-filing surcharge starts on 1 September
By Artem Kuznetsov, founderLast verified 23 August 2026
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What matters now
- Effective now
- In default since 1 August 2026 — the filing deadline was 31 July
- Next change
- 1 Sep 2026 — surcharge opens at €151 / €504; 1 Oct — €227 / €755
- Main impact
- The band follows the model actually filed, abridged or micro versus full
- Action today
- File before midnight on 31 August — submission date is what counts
Your 2025 annual accounts were due on 31 July. From 1 September, being late acquires a price list — and the price depends on which schema your accounts are filed in.
Start with the correction, because the headline date is not the deadline.
If your company closed its books on 31 December 2025, the accounts had to be approved by the shareholders within six months, and filed with the National Bank within seven — 31 July 2026. That date has passed. If nothing has been filed, the company has been in default for three weeks already.
What arrives on 1 September is the bill for it.
What it costs, by the day you file
The National Bank adds a surcharge on top of the ordinary filing fee for accounts filed from 1 September onwards, and it goes up twice more.
| You file | Abridged or micro accounts | Full accounts |
|---|---|---|
| On or before 31 August 2026 | nothing extra | nothing extra |
| In September 2026 | €151 | €504 |
| October to December 2026 | €227 | €755 |
| In 2027 | €453 | €1,510 |
Two things to read off that table.
It jumps, it does not creep. Filing on 1 October rather than 30 September costs €76 more on the smaller schema and €251 more on the full one, for one day of difference. Between the jumps, a week costs nothing.
Which column you land in depends on the schema, not on how small you are. Small companies usually file abridged or micro accounts. Some file the full version anyway — because a bank asked, or because a parent company reports that way. If yours does, the September price is €504, not €151. This is worth one question to your bookkeeper before anything else.
The date that counts is the day it is submitted
The surcharge attaches to the moment of filing, not to the moment the fee is paid or processed. Accounts submitted on 31 August are outside it, even if the National Bank charges the fee in September. Accounts submitted just after midnight are inside it.
So if your accounts are approved, or can be approved this week, the entire decision is a scheduling one: get the deposit in before the end of the month and the surcharge is simply zero. On abridged and micro accounts, that saves more than the filing itself costs.
Two obligations, and only one of them sends you an invoice
This is the part that gets conflated, and the expensive half is the quiet one.
Holding the general meeting — approving the accounts, minuting the decision, discharging the directors — had to happen within six months of the close. Filing the accounts is a separate act, done afterwards, with the National Bank.
Only the filing produces a receipt and a fee. The meeting produces nothing but a document in your own records, which is exactly why it is the one that gets skipped. Skipping it is not an administrative cost — it is a governance failure that sits with the directors personally, and no surcharge will settle it. If the meeting did not happen, filing the accounts does not repair that; it just makes the omission tidier.
What it turns into if it keeps sliding
The surcharge is the polite consequence. Behind it:
- A separate tax fine, from €25 to €250 for every month of delay that has elapsed. That one is on top of the National Bank's tariff, not instead of it.
- Personal exposure for directors. If a third party — a supplier, a lender, a customer — suffers damage, the damage is presumed to have been caused by the missing filing. It is the director who has to prove it was not. That presumption is the reason "we will do it when things calm down" is a poor plan for anyone who signs.
- Dissolution. After three consecutive years with no accounts filed, any interested party can ask the enterprise court to dissolve the company. A competitor can do this. A creditor can do this. Filing everything outstanding before the court rules is a complete answer to it — which means the fix, even at that stage, is still just filing.
There is a relief valve: the surcharge can be refunded on force-majeure grounds. It is judged on the facts, and "we were busy" is not one of them.
What to ask for this week
- "Can we still deposit before 31 August?" If yes, that is the whole conversation — everything else is scheduling.
- "Which schema are we filing, and does it have to be that one?" The answer is worth €353 in September and more than a thousand euros from January.
- "Was the general meeting held and minuted?" If the answer is vague, fix that separately from the filing.
- "Are we filing structured or as a PDF?" The structured route costs about €70 less, every year, on every schema. It is the one line here that is worth money even when nothing is late.
The part worth changing after this
The annual accounts are late for a boring reason almost every time: the underlying year was not legible until someone sat down in June and made it legible. Nothing about the filing itself takes seven months.
A year that is current as it happens — documents captured when they arrive, bank statements matched against them along the way — turns the annual filing into a formality that takes an afternoon in February. It does not change any deadline. It changes how much work stands between you and meeting one.
This year, though, there is only one number that matters: 31 August. Everything after it is priced.
Sources
- 01NBB/BNB — Central Balance Sheet Office, 2026 filing fees
- 02Art. 3:13 Code of Companies and Associations (WVV/CSA)
- 03Art. 2:74 CCA — judicial dissolution
- 04FPS Economy — filing the annual accounts
Dokus keeps the year legible while the year is still running.
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