Late-adopted annual accounts: almost a quarter after twelve months

The short answer

In one part of the KVK Open Dataset (312.943 filings), 24,3% of the annual accounts were adopted only more than twelve months after the end of the financial year. Those adopted annual accounts were therefore not made public within the deadline of art. 2:394(3) DCC , unless the board had filed the prepared version earlier. The median was 5,4 months.

Updated 30 October 2026

Key facts

The distribution: how long after the financial year

Half are adopted within 5,4 months, shortly after the five months in which the board of a BV must prepare the annual accounts (art. 2:210(1) DCC). If all shareholders are also directors, signing can be adoption at the same time (art. 2:210(5) DCC); preparation and adoption then coincide.

On the other hand, one in ten is adopted only after 16,9 months. For 24,3% adoption falls after the twelve-month limit. Those adopted annual accounts were then not made public within the deadline.

How we measured, and what the assumptions are

• Sample. Part 0 of the seven files of the bulk download: 312.943 filings. How the KVK distributes the filings over the files is not described. We therefore treat the result as an indication, not as a national figure.
• End of financial year. The dataset gives only the financial year, no start and end date. We take 31 December of that year. For a non-calendar financial year the measured period deviates, upward or downward.
• Date. The field is called DocumentAdoptionDate. In the Dutch Taxonomy that is the date of adoption; the KVK developer documentation calls it the filing date. For the conclusion that makes little difference: an adopted annual account can only be filed after adoption. If either date is after twelve months, that annual account was not public within twelve months.
• Adopted annual accounts only. A prepared annual account that was filed on time because adoption did not happen (art. 2:394(2) DCC) is not in the dataset. Whoever acted that way has met the deadline, but counts here as late as soon as the adopted version follows.
• Whoever never files is missing. The share of entities that make public late or not at all can therefore be higher than this figure.
• Repeatability. The figures come from a one-off analysis of 2 November 2026. Unlike the key ratios on the other pages, they are not in our regular processing. At the next processing we will recalculate them over all parts.

Adopting, filing and the deadlines of a BV

For a BV with a financial year equal to calendar year 2025, without extension:

If the general meeting extends the preparation period, which is only possible on the basis of special circumstances and by at most five months, the first two dates shift with it. The twelve-month limit never shifts. For the NV the same deadline is in art. 2:101 DCC; for the cooperative and the foundation or association with an enterprise other deadlines apply. See publication deadline and extension.

One rule the dataset cannot test: the eight days between adoption and filing. That needs two dates, and only one is in it. A BV that adopts on 1 December and files on 20 December is late under paragraph 1, but counts in this measurement as on time.

Worked example: four BVs, financial year 2025

BV D shows where the measurement is too strict. It acted according to the law, but only its adopted annual accounts are in the dataset, with adoption after more than fourteen months. BV A and B show the two usual routes: adopting shortly after the preparation period, or later in the year after an extension.

What making public late costs

Whoever does not make public at the latest twelve months after the financial year violates art. 2:394(3) DCC. That is an economic offence (art. 1 under 4° WED).

It weighs heavier in a bankruptcy. If the board has not complied with the publication obligation, it has performed its task improperly and it is presumed that this is an important cause of the bankruptcy; an unimportant omission does not count (art. 2:248(2) DCC). The trustee can then hold the directors liable for the shortfall. How to clear a backlog is explained in annual accounts filed late; the provision itself in article 2:248 DCC.

How to avoid late adoption

• Count back from the limit: 31 December 2026 for financial year 2025. For a non-calendar financial year the filing deadline calculator works out the dates.
• If all shareholders are directors, check whether the articles of association allow adoption by signing (art. 2:210(5) DCC). That saves a meeting; see adopting the annual accounts.
• If adoption stalls, file the prepared annual accounts with the statement that they have not yet been adopted (art. 2:394(2) DCC). See filing non-adopted annual accounts.
• Do not wait for the corporate income tax return. An extension for the return is not an extension at the KVK; see CIT extension is not an extension at the KVK.

How it works in Jaarrekening.io

On the filing page of a financial year, Jaarrekening.io shows under "Explanation and deadlines" the dates for your legal form and financial year: the end of the preparation period, the date on which you file the prepared annual accounts if adoption does not happen, eight days after adoption and the final deadline. You file yourself; the app sends nothing to the KVK.

Source and licence

Source: KVK Business Register Open Dataset Annual Accounts, adaptation Jaarrekening.io, CC BY 4.0. Data downloaded and processed on 2 November 2026.

Calculation, definitions, limitations and the download of all cells: method and sources.

Sources

• KVK: Business Register Open Dataset Annual Accounts (bulk download, CC BY 4.0)
• Creative Commons Attribution 4.0 International, legal code
• Art. 2:394 DCC: making public the annual accounts (wetten.overheid.nl)
• Art. 2:210 DCC: preparation and adoption for the BV
• Economic Offences Act (Wet op de economische delicten), art. 1 (in force from 22 September 2026)
• KVK Developer Portal: Open Dataset Annual Accounts API

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