Do I need a PKIoverheid certificate to file the annual accounts?
Not for every route. It depends on your size class and on who sends the Dutch annual accounts: you via the KVK portal, or software or your accountant via SBR.
The short answer
Micro and small entities file themselves via the KVK portal Zelf Deponeren, with eHerkenning (at least level 2) or e-mail and password plus authorisation; the KVK does not mention a PKIoverheid certificate there. For medium-sized and large entities using SBR software, the KVK does mention that certificate. If your accountant does it, the certificate is the firm's.
Updated 30 October 2026
Key facts
| Legal basis | art. 2:394 DCC (filing), digitally under the Besluit elektronische deponering handelsregister (Decree on electronic filing with the Business Register) |
| Portal, micro and small | Zelf Deponeren: eHerkenning (at least level 2) or e-mail and password with authorisation; no certificate mentioned |
| SBR, medium-sized and large | Financial software plus a PKIoverheid certificate to send (KVK) |
| Cost of filing itself | None; you pay for software and certificate (KVK) |
Which routes actually exist?
For every legal entity that must file, digital filing is the intention; the KVK names SBR as the standard route. For financial years beginning on or after 1 January 2025 the temporary exemption for some legal entities has lapsed, according to the SBR domain Handelsregister. There are three real routes and one exception.
| Route | For whom | What you need | Certificate? |
|---|---|---|---|
| KVK's Zelf Deponeren portal | Micro and small enter the annual accounts in the portal. Medium-sized and large upload an already adopted set of annual accounts; for large, an XBRL file is not accepted there, an iXBRL package is | Log in with eHerkenning (at least level 2) or with e-mail and password plus authorisation, and an access code for the legal entity | Not mentioned on the KVK page |
| SBR with financial software via Digipoort | Every class; for medium-sized and large the standard route | Software that can create an SBR message, and for medium-sized and large a PKIoverheid certificate to send | Yes for medium-sized and large, according to the KVK page on SBR |
| Your accountant or bookkeeper | Every class | An authorisation; the firm usually sends with SBR software | That is then the firm's certificate |
| PDF by e-mail to sbr.ontheffing@kvk.nl | Only if digital filing really is not possible; contact the KVK first | Your reasons and the annual accounts as PDF | No, but it is an exception, not a route |
The Besluit elektronische deponering handelsregister requires legal entities that did not fall under the earlier groups, such as large ones, to use SBR from financial years beginning on or after 1 January 2025. According to the KVK, the PDF exception for large legal entities applies only to financial years up to and including 2024.
What a certificate is and what eHerkenning is
They are two different things. eHerkenning is a login means: you prove that you may act on behalf of the legal entity. A PKIoverheid certificate is a digital certificate with which messages are sent; the KVK writes on the SBR page that for medium-sized and large you need, besides the software, a certificate "to be able to send the annual accounts". The KVK also says that filing itself is free and that you pay for the software package and the certificate.
For the portal route the KVK asks for one of two things. With eHerkenning, at least reliability level 2 is needed. With e-mail and password you need an authorisation, and that authorisation is free. With an authorisation via eHerkenning you often pay the supplier of the eHerkenning means, but the page mentions no amounts. Costs are on what do eHerkenning, PKIoverheid and SBR software cost.
Can a micro or small BV still use the portal for financial year 2025?
On the KVK page about micro and small (published 4 December 2025) the Zelf Deponeren portal is the first of two routes, alongside the bookkeeper or accountant with software. The page mentions no end date for micro and small and does not exclude financial year 2025. The Ondernemersplein page says that legal entities file "according to SBR" from financial year 2025; that is not a contradiction, because the portal does the SBR filing for you. Search results sometimes say that micro and small could not use the portal. We did not find that sentence on 27 October 2026 on the KVK pages we read. You see the real answer when logging in: if the legal entity can choose the financial year and enter the annual accounts, the portal works.
Case: two BVs, two routes
Two fictional BVs file the 2025 annual accounts on 27 October 2026. The outer limit of twelve months is 31 December 2026 for both, but the eight days after adoption determine the real deadline. Each BV must meet two of the three limits over two consecutive financial years to fall in a class; here it concerns both years.
| Jansen Verhuur BV | Van Dam Techniek BV | |
|---|---|---|
| Figures 2025 | Balance sheet total € 310.000, turnover € 120.000, one employee: micro (limits: balance sheet total ≤ € 450.000, net turnover ≤ € 900.000, < 10 employees) | Balance sheet total € 9,4 million, turnover € 18 million, 62 employees: medium-sized |
| Adopted | Meeting of the DGA on 4 November 2026; file no later than 12 November 2026 | Adopted by the shareholders on 20 October 2026; file no later than 28 October 2026 |
| Route | Zelf Deponeren, logging in with eHerkenning level 2+ | The accounting firm sends with SBR software |
| Certificate needed? | No, according to the KVK page on the portal | Yes, at the firm; the BV does not have to obtain one itself |
| What the BV does itself | Check the preview, submit and keep the confirmation of receipt | Give authorisation and supply the annual accounts plus auditor's report |
The pattern: a certificate only becomes a question if you want to send yourself with SBR software, and then mainly for medium-sized and large. Anyone who uses the portal needs a login means, not a certificate.
Misunderstandings
- "Without PKIoverheid nobody can file." For the portal the KVK does not mention it.
- "eHerkenning is the same as a certificate." One logs in, the other sends.
- "With the right software I don't have to arrange anything." Software creates the message; whoever sends has the certificate or the authorisation.
- "I pay the KVK for filing." The KVK charges nothing for it.
How it works at Jaarrekening.io
Jaarrekening.io sends nothing to the KVK, so you need no certificate for our app. The app creates the publication version and, for supported financial years, an XBRL file. For micro and small you copy the figures into the portal; for medium-sized you upload in the portal or give the file to your accountant; for large the accountant files with SBR software. The first set of annual accounts in your account is free, for every size class.
Sources
- KVK: filing your annual accounts yourself
- KVK: filing with SBR (PKIoverheid for medium-sized and large)
- KVK: filing annual accounts, business class micro and small
- KVK: filing annual accounts, business class large
- KVK: preparing and filing an XBRL annual account (medium-sized)
- Besluit elektronische deponering handelsregister, art. 2 (wetten.overheid.nl)
Frequently asked questions
Do I need a PKIoverheid certificate to file my annual accounts?
Not always. The KVK mentions the certificate on the SBR page for medium-sized and large, alongside the software. For the Zelf Deponeren portal (micro and small) you log in with eHerkenning, at least level 2, or with e-mail and password plus authorisation, and the KVK mentions no certificate there.
Does filing with the KVK cost anything?
No. The KVK writes that filing itself is free, also via SBR. You do pay for the means with which you log in or send: an eHerkenning means, SBR software and, for medium-sized and large, the PKIoverheid certificate.
Can I file without eHerkenning?
Yes, via the portal with e-mail and password, but then you need an authorisation. An authorisation on e-mail and password is free. According to the KVK, medium-sized and large legal entities can use the portal only this way (with authorisation).
Can my bookkeeper or accountant file for me?
Yes. You grant an authorisation, in writing or with your own eHerkenning means. The statutory duty to file on time and correctly remains with the board of the legal entity.
May I send the annual accounts to the KVK by e-mail or post?
Only if digital filing is not possible, and then you first contact the KVK. The PDF goes to sbr.ontheffing@kvk.nl with your reasons. For large legal entities the PDF exception applies to financial years up to and including 2024.
Read more
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.
Get started