Must I file annual accounts if my BV had no turnover?

The short answer

Yes. The filing duty of art. 2:394 DCC attaches to the legal form, not to activity. A dormant BV without turnover also files annual accounts.

Basis: art. 2:394 DCC

Why an empty BV still has to file

A BV without activities still has a balance sheet: there is issued capital, often a current account with the director-major shareholder (DGA) and usually a small bank balance. That balance sheet is prepared, adopted and filed, even if the profit and loss account is almost empty.

The duty starts with the BV as a legal entity and does not end because sales stop. First check whether the company still exists on the balance sheet date; a registered BV without customers is legally not yet a terminated BV. Even at zero turnover, distinguish between no transactions and no assets: bank charges, interest, a shareholder loan and outstanding tax amounts can change the result and equity. Use the closing position of the ledger, not the assumption that all amounts are zero.

Which figures appear in a year without turnover?

A dormant BV almost always falls in the micro class (art. 2:395a DCC). The filing then consists of a heavily abridged balance sheet with a few disclosures below it — a limited document, but still mandatory.

Suppose a BV has € 1,000 in the bank on 1 January and pays € 120 in bank charges during the year. Without turnover, the bank balance ends at € 880 and the result is € 120 negative. The balance sheet must explain that difference; an empty form with zeros everywhere would miss reality. Also check the opening balance sheet, any receivables from the director and costs still owed. The micro exemption limits the data made public, but does not replace the internal annual accounts.

What happens if you skip the empty BV?

Not filing is an economic offence. In bankruptcy, art. 2:248(2) DCC applies: save for an insignificant omission, improper performance of duties is presumed and presumed to have been an important cause. The presumption of causation is rebuttable.

Note the statutory deadline from the actual end date of the financial year and record who handles the adoption. For calendar financial year 2025, the absolute limit is 31 December 2026, but after earlier adoption the shorter period of eight days applies. A dormant BV has no general pause button for the publication duty. If you want to terminate it, first complete outstanding years and the records, then follow the dissolution route. Keep the confirmation of receipt of every filing with the file.

How do you make a year without activity verifiable?

Keep a short note with the final trial balance stating which activities have stopped and which accounts still exist. A BV may, for instance, have sent no new invoices but still get a rental deposit of € 2,000 back. That receivable still belongs in the closing balance sheet. Compare the bank balances with the statements at the balance sheet date and check whether an outstanding CIT or VAT position has been settled. If a participation or loan is present, assess whether the value is still right; no turnover says nothing about that. That way someone else can understand the difference between a truly empty BV and a BV with silent assets.

For the shareholders, prepare the internal annual accounts with result and notes, and then decide which limited data are published with the KVK. The size class follows the statutory limits and group rules; a dormant holding with a large subsidiary is not micro by default. Therefore note the assets, turnover and employees of the relevant group before you choose the micro version. After sending, check the financial year in the Business Register and keep the proof in the same folder as the adoption. That prevents a second year with an unnoticed missing publication.

Sources

• KVK: whether or not to file annual accounts
• KVK: final deadline

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