SBR intermediary
An SBR intermediary is a party that can submit digital reports on behalf of a company via a permitted route.
What does SBR intermediary mean?
An SBR intermediary is a party that can submit digital reports on behalf of a company via a permitted route.
The entrepreneur remains responsible for the content of the annual accounts. Agree who validates, sends and keeps confirmations of receipt; the technical route differs per type of report.
How does it work?
SBR Nederland describes the intermediary as the service-providing go-between (accountant, bookkeeper, administration office, tax adviser or tax specialist) who prepares and compiles financial reports for reporting entrepreneurs. In the message flow he is the submitter: his software converts the annual accounts into an XBRL message and sends it via Digipoort to the KVK or the Dutch Tax Administration (Belastingdienst).
Two things make that possible. The message is sent with a PKIoverheid certificate, which establishes who the sender is. And where an intermediary submits on behalf of a client, it must be clear that he is authorised; SBR records that relationship in an authorisation register (SBR glossary). The statutory obligation does not shift: the legal entity itself is obliged to make the accounts public (art. 2:394(1) DCC).
Example
A small BV has its administration office file. The board prepares the annual accounts on 15 April; the DGA adopts them on 2 June and gives the instruction to file the same day. The office sends on 4 June, but the message is rejected because the holding’s KVK number was filled in. After correction the confirmation of receipt follows on 6 June. The eight-day period ran until 10 June, so the filing is on time. Had the office noticed the rejection only after two weeks, the BV would have been late, not the office.
In the annual accounts
Submission process outside the balance sheet and P&L.
Difference from Digipoort
The intermediary is a party, Digipoort is a channel. Digipoort is the government’s secure line that receives, processes and delivers messages; the intermediary prepares the message and connects to it. An entrepreneur therefore does not choose between the two, but between filing themselves via a portal and filing via an intermediary with software.
Common mistakes
- Seeing an export as a successful submission
- Not keeping a confirmation of receipt
What to watch for
- Agree in writing who passes on the adoption date, who sends and within how many days; the eight days start on the day of adoption.
- Request the confirmation of receipt and then check in the Business Register that the documents are under the correct KVK number.
- Micro and small entities can also authorise an accountant or bookkeeper for the KVK portal Zelf deponeren (file it yourself); larger classes submit in XBRL or iXBRL.
Legal basis and sources
art. 2:394 DCC; SBR information
Frequently asked questions
Is an SBR intermediary mandatory?
No. A legal entity may file itself, for example via the KVK portal Zelf deponeren (file it yourself). An intermediary is practical if a firm already prepares the annual accounts.
Who is liable if the intermediary files late?
Towards third parties the legal entity and its board, because the filing obligation rests on them. Whether the firm compensates the damage depends on the engagement you concluded with the firm.
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Preparing Dutch annual accounts?
Your first set of annual accounts is free, for every size class. Create an account and prepare the annual accounts of your Dutch company under Title 9 of Book 2 of the Dutch Civil Code.
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