Must my DGA-BV file for 2025 as early as November?
Often yes. If signing is also adoption, the extra adoption months fall away. With maximum extension, the KVK names 8 November as the limit.
The short answer
Often yes. If signing is also adoption, the extra adoption months fall away. With maximum extension, the KVK names 8 November as the limit.
Basis: art. 2:210(1) and (5) and art. 2:394 DCC
Period for preparation
For a BV with calendar financial year 2025, 31 December 2026 is not always the right planning date. If all shareholders are also directors, signing can immediately mean adoption. The eight days for filing then start at once. The simplified adoption has conditions and may be excluded in the articles of association.
The board normally prepares the annual accounts within five months after the financial year under art. 2:210(1) DCC. The general meeting can, because of special circumstances, extend by at most five months. For calendar year 2025 that leads, without extension, to the end of May 2026 and, with maximum extension, to the end of October 2026. An extension is therefore a separate resolution, not a default setting. Record the reason and the resolution. A late arrangement with the bookkeeper does not change the preparation period by itself. First check whether your file really contains a valid extension resolution before you count on the longest period.
When is signing also adoption?
Art. 2:210(5) DCC links signing to adoption under conditions when all shareholders are also directors. All directors and supervisory directors must sign for this. Other persons entitled to attend meetings must be able to inspect the annual accounts and agree to this manner of adoption. The articles of association can exclude this route. For this situation the KVK names ten months and eight days after the end of the financial year as the standard limit at maximum extension. For a calendar year that is 8 November. For execution in 2026, preferably plan for Friday 6 November at the latest, so that you do not have to rely on a weekend or any interpretation of the period.
An earlier signing can also produce an earlier filing date. If the annual accounts were already adopted in the described way in September 2026, you cannot simply wait until November. Art. 2:394(1) DCC requires publication within eight days after adoption. So look at the real signing and adoption date and let a calendar reminder start from it. That prevents a general schedule with only 'November deadline' from exceeding a concretely earlier moment. When the simplified adoption does not apply, you must assess the ordinary decision-making route and deadlines separately.
When must you file?
For a holding with an operating company, check both companies separately. The DGA is not necessarily the direct shareholder of the operating company; that may be the holding. Look at who is legally shareholder and director, not just who is ultimately the owner. Keep the extension resolution, the signed version and the proof of submission per BV. For the actual submission, consult the current KVK information and ask for help in good time with deviating articles of association or depositary receipt holders. The usable planning for financial year 2025 starts from your formal structure and actual resolutions, not from a single final date that would apply to all BVs.
Sources
Frequently asked questions
Does 8 November apply to every BV?
No. This limit at maximum extension fits the simplified adoption described; an earlier adoption can bring the deadline forward.
What if the articles of association exclude the DGA route?
Then you must assess the ordinary adoption route and the related deadlines.
Does the holding structure apply equally to both BVs?
No. Check for each BV who is the direct shareholder and director.
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