Who has to file annual accounts with the KVK?
Whether you have to file depends on the legal form and not on your profit; only for a foundation or association does turnover play a part. Below is a short rule per legal form, with what often goes wrong.
The short answer
The BV (private limited company), the NV (public limited company) and the cooperative must file annual accounts every financial year, even without turnover. A foundation or association only has to if it runs an enterprise with a large net turnover. A sole proprietorship, partnership (maatschap), ordinary general partnership (vof) or ordinary limited partnership (cv) does not have to file; they are not legal entities under Title 9 Book 2 of the Dutch Civil Code.
Updated 30 October 2026
Key facts
| Legal basis | art. 2:360 DCC (who falls under Title 9) and art. 2:394 DCC (publication) |
| Time limit | Within eight days after adoption, no later than twelve months after the end of the financial year |
| What you file | Depends on the size class: micro the balance sheet, small the balance sheet with notes, medium-sized and large more |
By legal form: do you have to file?
The law ties the obligation to the legal form. Article 2:360 DCC determines to whom Title 9 applies; for those legal entities the publication of article 2:394 DCC applies. The KVK uses the same classification on its page on whether or not to file.
| Legal form | File? | Reason |
|---|---|---|
| BV | Yes, every financial year | Title 9 applies to the BV (art. 2:360(1) DCC), also for a dormant BV or a BV without turnover |
| NV | Yes, every financial year | Same ground as the BV |
| Cooperative and mutual insurance association | Yes | Named in art. 2:360(1) DCC |
| Foundation or association | Only with a large enterprise | Title 9 applies if it maintains an enterprise that must be registered and whose net turnover for two financial years in a row is at least half the amount in art. 2:396(1)(b) DCC, so € 7,5 million out of € 15 million (art. 2:360(3) DCC). A foundation with an equivalent public accountability falls outside |
| Limited partnership (cv) or general partnership (vof) | Only if all fully liable partners are foreign capital companies | art. 2:360(2) DCC. An ordinary vof or cv, with natural persons or BVs as managing partners, does not file |
| Sole proprietorship | No | Not a legal entity; the KVK expressly names the sole proprietorship as exempt |
| Partnership (maatschap) | No | Not a legal entity under Title 9; the KVK does not name the maatschap separately, so this follows from the statutory text |
| Foreign company with a branch | Sometimes | If it must publish in its country of origin, it files in the Netherlands in the same form; for a formally foreign company more applies. Ask the KVK or your accountant |
For the legal forms to which the obligation does apply, the content is fixed per size class. A micro BV files the balance sheet; a small entity the balance sheet with notes and without profit and loss account (art. 2:395a(8) and 2:396(8) DCC). Medium-sized and large file more. See who has to publish the profit and loss account and the size classes. What that means for a micro BV, a small holding and a foundation with an enterprise is worked out in three examples: who files what.
Who does not have to file, but must still do something
- A subsidiary with a 403 declaration. A legal entity that belongs to a group does not have to file its own annual accounts if the head of the group assumes joint and several liability and the other conditions of art. 2:403 DCC are met. You do file the declarations; read article 2:403 DCC and the 403 declaration.
- A sole proprietorship or partnership (maatschap). No filing, but accounting records and an income tax return. Those are different obligations from filing.
Case: four entrepreneurs, one question
Four fictitious entrepreneurs ask in the same week whether they have to file. Only the BV has to.
| Who | Facts | Has to file? |
|---|---|---|
| Mirjam Dekker, sole proprietorship | Web shop, turnover € 310.000 for 2025 | No. Turnover does not matter; a sole proprietorship is not a legal entity under Title 9 |
| Dekker Holding BV | Holds the shares in an operating company, no turnover, one employee (the director-major shareholder); micro, provided the operating company also stays within the micro limits | Yes, within twelve months after 31 December 2025, so no later than 31 December 2026. Filing without turnover is possible; see filing without turnover |
| Stichting Dorpshuis De Linde | Operates a hall with catering, net turnover € 420.000 | No. € 420.000 is far below € 7,5 million; Title 9 does not apply (art. 2:360(3) DCC). Do check whether the articles or grant conditions require their own accountability |
| Maatschap Bos en Visser, two GPs | One practice, no BV | No. But an income tax return per partner |
The pattern: for a BV the legal form determines the obligation, and only the size determines what you file. For a foundation, the size of the enterprise determines whether the obligation exists. More about the foundation is at does a foundation have to publish. A BV that has been dissolved or is being wound up keeps the obligation as long as it is in the register; see what if my BV has been dissolved.
When and how do you file?
You file within eight days after adoption by the general meeting, and always no later than twelve months after the end of the financial year (art. 2:394(1) and (3) DCC). If the annual accounts have not been adopted two months after the end of the preparation period, the board files the prepared annual accounts stating that they have not been adopted (paragraph 2). The details are at the final date and annual accounts not adopted. Filing late has consequences: what happens if I file late.
Common misunderstandings
- "My BV is small, so I don't have to file." A small or micro BV files limited annual accounts, but every year.
- "My BV has done nothing." The obligation does not depend on activity; see the holding case above.
- "A vof doesn't have to, so my vof's BV doesn't either." The BV that is managing partner files itself.
- "A foundation never has to." That is only true below the turnover limit of article 2:360(3) DCC.
How it works at Jaarrekening.io
Jaarrekening.io follows the legal forms of Title 9: the BV, the NV and the cooperative directly, a foundation or association only if it falls under article 2:360(3) DCC. The app creates a publication version according to your size class and monitors the time limits; it does not submit anything to the KVK itself, you or your accountant do that. The first annual accounts in your account are free, for every size class; see free annual accounts.
Sources
Frequently asked questions
Does a BV without turnover have to file annual accounts?
Yes. The obligation of article 2:394 DCC depends on the legal form, not on turnover or activity. A dormant BV or holding without turnover files every financial year, usually micro annual accounts with only the balance sheet.
Does a sole proprietorship have to file annual accounts?
No. A sole proprietorship is not a legal entity and does not fall under Title 9 Book 2 DCC. The KVK expressly names the sole proprietorship as not obliged. A sole proprietorship does keep accounting records and files an income tax return.
Does a foundation or association have to file?
Only if it has a business activity that must be in the Business Register and the net turnover of it is at least € 7,5 million for two financial years in a row, half the limit in article 2:396(1)(b) DCC. Then it falls under Title 9 (art. 2:360(3) DCC). Below that it does not file.
Does a general partnership (vof) or limited partnership (cv) have to file annual accounts?
As a rule not. Only if all partners who are fully liable for the debts are capital companies under foreign law does the vof or cv fall under Title 9 (art. 2:360(2) DCC). A BV that is managing partner does file its own annual accounts.
Does a subsidiary BV have to file if the parent has issued a 403 declaration?
No, if all conditions of article 2:403 DCC are met, including the written consent of the shareholders, consolidated annual accounts in which the subsidiary is included and which fall under European reporting law, and the joint and several liability assumed by the consolidating parent. The declarations themselves must be filed.
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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.
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