Must an association or foundation file its annual accounts? The € 7,5 million threshold

The short answer

A Dutch association (vereniging) or foundation (stichting) falls under Title 9 Book 2 of the Dutch Civil Code and must file if its registered enterprises have net turnover of at least € 7,5 million per year in two consecutive financial years (art. 2:360(3) DCC): half of € 15 million. Below that you do not have to file.

Updated 30 October 2026

The rule, from the statutory text

The main rule of Title 9 applies to BVs, NVs and cooperatives. For foundations and associations there is an exception in paragraph 3 of article 360:

This title also applies to the foundation and the association that maintain one or more enterprises which by law must be entered in the commercial register, if the net turnover of these enterprises during two consecutive financial years […] amounts to half or more of the amount referred to in article 396(1)(b) […].

The amount in article 396(1)(b) is the net turnover limit for the small legal entity: € 15 million per financial year. Half of it is € 7,5 million. (The law calls the amount "as amended pursuant to article 398(4)"; the limit can therefore move along if the amounts are adjusted by order in council.) That is also what the KVK writes: an association or foundation with an enterprise that has turnover of at least € 7,5 million per year in two consecutive financial years must file.

Why one source says € 6 million and another € 7,5 million

Both figures were once correct. Until the financial years of 2024, the net turnover limit for small legal entities was € 12 million, so half was € 6 million. With the decision to raise the amounts (Staatsblad 2024, 52) that limit became € 15 million for financial years beginning on or after 1 January 2024; financial year 2023 could already apply it. In paragraph 3 the law refers to the amount in article 396 and so follows along. For financial year 2025, and for every financial year you prepare now, € 7,5 million therefore applies. A page that still mentions € 6 million is outdated.

What counts as net turnover, and what does not

The test looks at the net turnover of the enterprises that the foundation or association maintains and that must be in the Business Register. That is different from total income. In the usual reading, subsidies, gifts, bequests and membership fees do not count as an enterprise's turnover; income from supplying goods or services at a price, such as ticket sales, catering, course fees or letting a commercially operated building, does. If a borderline case is not in the law, have it checked by an accountant or ask the KVK; this page gives no advice on your specific income.

The limit looks exclusively at turnover. Balance sheet total and number of employees play no role in whether Title 9 applies; they only determine afterwards which size class you have.

Two years in, two years out

The statutory text requires the turnover "during two consecutive financial years", and then speaks of "without interruption thereafter": as with the size criteria in article 396, the situation only changes after two years in a row. One peak year above € 7,5 million therefore does not bring a foundation under Title 9, and one dip does not take it out again. The usual reading is that you fall in after two years above and go out after two years below. About the precise starting date, the first financial year for which you must prepare Title 9 annual accounts, there is nuance in the literature; in a borderline case consult your accountant or the KVK.

There is one exception in the same provision: if the foundation or association is required by or pursuant to law to draw up a financial statement equivalent to annual accounts, and it is made public, Title 9 does not apply. Think of sectors with their own statutory accountability regime, such as healthcare or housing corporations.

Case: Stichting Theaterhuis De Kade

De Kade (fictional) operates a theatre with a restaurant, registered in the Business Register. In addition it receives € 2,1 million in structural subsidy. Its net turnover runs as follows:

The subsidy of € 2,1 million does not count. After 2023 (below the limit), 2024 and 2025 both qualify, so the two consecutive financial years are complete: Title 9 applies. The board prepares the annual accounts under the rules for its size class (by balance sheet total, turnover and employees), has them adopted by the body named in the articles of association (who adopts) and files them within eight days of adoption and no later than twelve months after the financial year (art. 2:394 DCC). In 2026 and 2027 turnover falls to € 7,4 and € 7,3 million. Only after two years below does the duty lapse.

A small foundation without a profit motive under Title 9

If the foundation or association does fall under Title 9 but is small and does not pursue profit, it need not apply article 2:394, provided it does two things: on request immediately send or make available for inspection, free of charge, the limited documents to creditors and other interested parties, and file with the Business Register a statement from an accountant that the legal entity carried out no activities outside its stated purpose during the financial year (art. 2:396(9) DCC). So this is an exemption from filing under two conditions, not an exemption from preparing. The accountant's statement must also state that this article applies to the legal entity.

How it works at Jaarrekening.io

For a foundation or association, Jaarrekening.io records whether Title 9 applies on the basis of article 2:360(3) DCC. If so, you go through the annual accounts route for your size class. The app files nothing: you do that yourself at the KVK. The first set of annual accounts in your account is free, for every size class.

Sources

• Art. 2:360 DCC: scope of Title 9, text applicable from 1 July 2026 (wetten.overheid.nl)
• Art. 2:396 DCC: small legal entities, text applicable from 1 July 2026 (wetten.overheid.nl)
• Art. 2:394 DCC: making public, text applicable from 1 July 2026 (wetten.overheid.nl)
• Staatsblad 2024, 52: increase of amounts in art. 2:395a, 396 and 397 DCC as of 1 January 2024
• KVK: Am I required to file my annual accounts?
• KVK: deadline for filing annual accounts

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