Filing

Filing the annual accounts digitally via iXBRL: what changes and when

From financial year 2025 Dutch legal entities file annual accounts digitally via SBR. How to choose XBRL or iXBRL, and when iXBRL is mandatory.

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Cover art for Filing annual accounts (jaarrekening) digitally via iXBRL: what changes and when

From financial year 2025, virtually every Dutch legal entity must file its annual accounts (jaarrekening) digitally via SBR with the Dutch Chamber of Commerce (KVK). The Decree on electronic filing with the trade register (Besluit elektronische deponering handelsregister) was amended on 18 December 2024, bringing the last remaining group, large legal entities, into the digital chain. At the same time, a format choice has existed since financial year 2024: the familiar XBRL format (an SBR instance) or the European iXBRL format (XHTML with embedded XBRL tags). This article explains per size class what applies, how to choose between the two formats, and in which situations iXBRL is mandatory.

Key facts

  • Who: all legal entities required under Article 2:394 of the Dutch Civil Code (BW) to file their annual accounts with the KVK trade register.

  • Legal basis: Article 2:394 BW (filing obligation) and the Decree on electronic filing with the trade register, amended by the Decree of 18 December 2024 (Staatsblad 2024, 428).

  • Digital filing mandatory: micro and small entities from financial year 2016, medium-sized entities from financial year 2017, large entities for financial years starting on or after 1 January 2025.

  • Format: XBRL (SBR instance) or the European iXBRL format (XHTML), at the entity's choice, unless iXBRL is mandatory.

  • Deadline: file within 8 days after adoption and no later than 12 months after the end of the financial year.

  • Exception: listed companies (issuers within the meaning of Article 5:25o of the Dutch Financial Supervision Act, Wft) file their annual reporting in ESEF format with the AFM, not via SBR with KVK.

From phased introduction to a full digital obligation

Digital filing was introduced in phases and runs through Standard Business Reporting (SBR), the Dutch national standard for structured digital data exchange with the government. Micro and small legal entities have been required to file digitally since financial year 2016, medium-sized legal entities since financial year 2017. Large legal entities, and for example medium-sized subsidiaries of large legal entities, were until now exempt, pending the European single electronic reporting format (ESEF) developed for listed companies.

That exemption has been removed. The Decree of 18 December 2024 (Staatsblad 2024, 428) provides that large legal entities must also file their annual reporting, meaning the annual accounts, the management report and the other required information, electronically via SBR, starting with financial years beginning on or after 1 January 2025. Legal entities filing annual accounts on a foreign accounting basis now also fall within scope. Only issuers with their registered office in the Netherlands remain exempt: they submit their annual reporting to the AFM.

At the same time, the SBR channel has been extended with the European format. From financial year 2024, filers can choose between the XBRL format and the iXBRL format; since February 2025, Digipoort and the KVK upload portal actually accept iXBRL Report Packages. The requirements are set out in the Regulatory Technical Standard (RTS) and the Reporting Manual of the SBR trade-register domain, which follow the European ESEF rules for listed companies as closely as possible.

Overview per size class

The size class (micro, small, medium-sized or large) follows from balance-sheet total, net turnover and the average number of employees over two consecutive financial years. Note that the thresholds were raised as of financial year 2024, moving many companies into a lighter class; see the size criteria for the annual accounts. The table below shows per size class when digital filing became mandatory, which format applies and whether an auditor's report is required.

Size class

Digital filing mandatory

Format

Auditor's report

Micro (art. 2:395a BW)

From financial year 2016

XBRL or iXBRL (choice)

Not required

Small (art. 2:396 BW)

From financial year 2016

XBRL or iXBRL (choice)

Not required

Medium-sized (art. 2:397 BW)

From financial year 2017

XBRL or iXBRL (choice)

Required (art. 2:393 BW)

Large (above the criteria of art. 2:397 BW)

From financial year 2025

XBRL or iXBRL (choice); iXBRL only for IFRS or custom presentation

Required (art. 2:393 BW)

The obligation follows the type of annual accounts you file, not just the entity's actual size. A small legal entity that voluntarily files as medium-sized (including a statutory audit) has been subject to the digital obligation since financial year 2017; an entity that files as large, or applies IFRS, is subject to it from financial year 2025.

XBRL or iXBRL: two formats, one channel

With the XBRL format you submit an XBRL instance document: structured, machine-readable data without any layout of your own, prepared within the fixed framework of the Dutch Taxonomy. With the iXBRL format, the annual accounts are a single XHTML document with the XBRL tags embedded in it: the same file is readable by people and processable by machines, and you keep your own layout and house style. For the technical background, also read our article on the difference between XBRL and iXBRL.

Characteristic

XBRL (SBR instance)

iXBRL (Report Package)

File form

XBRL instance document (data only)

XHTML document with embedded XBRL tags

Readability

Machine-readable only; software needed for display

Human- and machine-readable in any browser

Layout

Fixed framework of the Dutch Taxonomy

Own layout and house style possible

Taxonomy

Predefined entry point per size class

Own extension taxonomy required

Reporting standard

NL GAAP only

NL GAAP or IFRS

Maximum size

15 MB

100 MB

Filing route

Digipoort or the KVK portal

Digipoort or the KVK upload portal

An iXBRL filing is submitted as a Report Package: one package file containing the iXBRL documents and the entity's own extension taxonomy. Only one adopted annual reporting can be filed per financial year, and the legal entity must itself verify that the filing has been successfully processed in the trade register.

When is iXBRL mandatory rather than a choice?

The RTS of the SBR trade-register domain restricts the freedom of choice in four situations:

  • IFRS annual accounts. The XBRL route is only available for annual accounts prepared under NL GAAP. Entities reporting under IFRS file in iXBRL. Moreover, a legal entity applying IFRS is classified as a large legal entity, regardless of its actual size.

  • Custom presentation. Legal entities that include entity-specific line items or adapt the structure and presentation of the annual accounts must always use the iXBRL format.

  • ESRS sustainability information. Entities reporting in the management report on the basis of the European Sustainability Reporting Standards must use the iXBRL format. European sustainability legislation (CSRD) is still in flux due to the Omnibus simplification package; check the current state before building your reporting process on it.

  • No suitable entry point. If no predefined XBRL entry point exists that fits your situation, iXBRL is the only route.

Not sure which format fits your organisation? Our decision guide electronic filing: SBR or iXBRL lists the trade-offs.

Deadlines: when must the annual accounts be filed?

Article 2:394 BW contains three deadlines. Paragraph 1: the legal entity publishes the annual accounts within eight days after adoption. Paragraph 2: if the annual accounts have not been adopted within two months after the end of the preparation period, the board must without delay file the prepared (not yet adopted) annual accounts, stating that they have not yet been adopted. Paragraph 3: no later than twelve months after the end of the financial year, the annual accounts must in any case have been published.

Worked example. If the financial year equals calendar year 2025 and the general meeting adopts the annual accounts on 15 May 2026, the filing must be completed by 23 May 2026 at the latest. If adoption does not take place, the long-stop of paragraph 3 applies: the filing must be made by 31 December 2026.

The auditor and NBA Alert 50

Medium-sized and large legal entities are subject to a statutory audit (Article 2:393 BW); the auditor's report is part of the filing. Micro and small legal entities are exempt from the statutory audit.

For the iXBRL Report Package, the NBA (the Dutch professional body of accountants) published Alert 50 on 26 June 2025 on the role of the external auditor. In essence: if the text of the auditor's report is included in an SBR Report Package, this counts as a new publication of that report, for which the auditor must give prior written consent. The technical conversion of the adopted annual accounts to iXBRL falls outside the scope of the statutory audit; the alert describes five scenarios and the corresponding wording in the auditor's report. The practical lesson: involve the auditor early in the filing process, especially in the first iXBRL year.

Self-filing or filing via software?

Through KVK's self-filing portal (Zelf Deponeren), micro and small legal entities prepare their annual accounts online and file them directly. Medium-sized and large legal entities can use the portal to upload the already adopted annual accounts; a medium-sized legal entity uploads three files: the annual accounts, the auditor's report and the auditor's electronic signature. Logging in is possible with eHerkenning, among other methods, and anyone filing on behalf of another party always needs an authorisation.

For automated submission, the standard route for accounting firms and administration offices filing many sets of annual accounts, filing runs through SBR software and Digipoort.

Frequently asked questions

Is it mandatory to file the annual accounts digitally? Yes. Micro and small legal entities have been required to do so since financial year 2016, medium-sized entities since financial year 2017, and large legal entities for financial years starting on or after 1 January 2025. Only listed companies (issuers, art. 5:25o Wft) are exempt; they file their annual reporting with the AFM.

Can I still file on paper or as a PDF? Not for financial years starting on or after 1 January 2025, regardless of size class. A PDF is not a valid filing format: the annual accounts must be submitted as an XBRL instance or as an iXBRL Report Package via Digipoort or the KVK portal.

What is the difference between XBRL and iXBRL? XBRL is a separate, purely machine-readable instance document containing structured financial data. iXBRL (Inline XBRL) embeds those same tags in an XHTML document, so that a single file can be read by both people and machines. For KVK filings both formats are permitted, unless iXBRL is mandatory.

When is iXBRL mandatory for KVK filings? For annual accounts prepared under IFRS, for entity-specific line items or an adapted structure and presentation, for ESRS sustainability reporting in the management report, and when no suitable predefined XBRL entry point exists.

Do medium-sized and large companies have to include an auditor's report? Yes, the auditor's report is part of the filing. If the report is included in an iXBRL Report Package, NBA Alert 50 (26 June 2025) requires the auditor's prior written consent, because this constitutes a new publication of the report.

Does the digital obligation also apply when voluntarily filing under a heavier regime? Yes. The obligation follows the type of annual accounts being filed. A small legal entity that voluntarily files under the requirements for medium-sized entities has been subject to the digital obligation since financial year 2017; an entity filing under the requirements for large entities, from financial year 2025.

Doc2iXBRL for digital filing

Switching from a classic SBR chain to iXBRL requires different software and a different way of working. Doc2iXBRL is a platform for accountants and finance teams that converts approved PDF or Word annual accounts into validated iXBRL or SBR, including AI-supported taxonomy mapping and pre-filing validation via Arelle. The platform supports both the Dutch Taxonomy for KVK filings (Dutch GAAP) and ESEF for IFRS reporting, without guaranteeing a KVK acceptance outcome.

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