Must a large Dutch entity file electronically in 2026?
Yes. Financial year 2025 is the first SBR year for the large size class. Here is what is expected of you, legally and technically.
Short answer
Large Dutch entities file electronically with the Chamber of Commerce from financial year 2025. The 2016 electronic-filing decree phased it in by size: micro and small from financial year 2016, medium from 2017, and large only from 2025. Adopted accounts must reach the register within eight days of adoption, and at the latest twelve months after year end.
The phasing, and why large comes last
Electronic filing is not a new idea. The 2016 decree on electronic filing with the trade register started the switch and spread it across the size classes: micro and small first, medium a year later, large as the closing step. Financial year 2025 is therefore the first SBR year for the largest entities, and 2026 the year those filings arrive.
An estimated 8,000 large entities do this for the first time in 2026, most of them in spring and early summer. For most of them this is not one new button, but a different way of delivering the accounts they already prepare.
The deadline sits in article 2:394
Adopted accounts must reach the trade register within eight days of adoption, and in any case within twelve months of the end of the financial year. Those eight days are the reason to schedule the conversion before adoption: afterwards there is no room left to reconsider a mapping.
Two neighbouring articles frame the duty. Article 2:391 requires the management report and article 2:393 the auditor's report for the medium and large size classes. For large entities those documents become public too.
What the technical rulebook requires
The technical implementation is the Regulatory Technical Standard for the SBR trade-register domain, finalised on 31 October 2025 for financial years from 1 January 2025. It deliberately mirrors the European ESEF model: a report-packages chapter for Inline XBRL that allows a filer-authored extension taxonomy with anchoring, alongside the fixed-framework XBRL filings it gradually replaces.
- Annex II sets the detailed-tagging duty and the mandatory KVK metadata that travels as tagged facts.
- Annex III pins the specification set, including Calculations 1.1, so calculation relationships are tested from the taxonomy itself.
- Annex IV is the markup rulebook and bans voluntary block tagging for financial years beginning before 1 January 2026, pending the revised method.
Large entities publish everything
Micro and small entities keep the profit and loss account private, and medium-sized entities may abbreviate. For large entities that relief does not exist: the full accounts, the management report, the other information and the auditor's report all become public.
That changes what the conversion has to handle. There is more to tag, and at this size the notes are the largest part of it.
When you do not file your own accounts
Article 2:403 lets a group company skip filing its own accounts once its parent consolidates it and files a liability statement; articles 2:391 to 2:394 then stop applying to the subsidiary. Article 2:408 offers a narrower relief for an intermediate holding whose figures already sit inside a higher consolidation.
Mind the form. Annex II of the filing rulebook defines conditional metadata for the case of filing a foreign group head's annual report in connection with these exemptions. Where that applies, the reliance is a tagged fact, not a footnote.
Electronic filing by size class
The phasing from the 2016 electronic-filing decree, and the calendar year the first filing falls in when the financial year matches the calendar year.
| Size class | First electronic financial year | First filing falls in |
|---|---|---|
| Micro | 2016 | 2017 |
| Small | 2016 | 2017 |
| Medium | 2017 | 2018 |
| Large | 2025 | 2026 |
The size class follows from articles 2:395a to 2:397 of the Civil Code, with thresholds raised from financial year 2024. The class also depends on two consecutive balance sheet dates and on aggregation within the group; this page is not legal advice.
Questions that come with this
Does this apply if our financial year is not the calendar year?
Yes. The phasing attaches to the financial year, not the calendar year. For large entities the first electronic financial year is 2025, whether that year begins or ends during 2025.
We report under IFRS. Does that change the route?
Not the route, but the entry point. Article 2:362 permits the IFRS option, and the KVK tree imports IFRS-NL entry points for it. Pick the entry point that matches your basis and size class; a wrong one fails validation straight away.
Do we have to tag the whole notes section?
The detailed-tagging duty is set in Annex II of the filing rulebook. Voluntary block tagging is in fact not permitted for financial years beginning before 1 January 2026, so tagging more than is asked is not the safe option here.
Who submits, we or our accountant?
That stays your arrangement. We deliver the validated package and keep validation separate from submission, so filing remains a deliberate act by whoever signs for it.
Can we see in advance whether the package passes?
Yes. The validator runs the XBRL specifications, the calculation relationships from the taxonomy and the SBR Filing Rules, and returns what each finding needs. Only errors block; warnings inform.
When should we start?
Before adoption. The conversion fixes choices, such as concept mapping and the structure of the notes, that you would rather make while the accounts are still being drafted than in the eight days after.
Preparing your first electronic filing?
Walk the route once with your own accounts, well before adoption.