FAQ - Associations and foundations (A&F)

1. Where should a small association that voluntarily opts to keep its accounts in accordance with the rules applicable to large associations file its annual accounts?

Small associations that voluntarily keep their accounts in accordance with the rules applicable to large associations must prepare their accounts using the models provided for large associations. However, they should file their accounts with the appropriate business court, not with the National Bank. If they wish to do so, they can file their accounts with the National Bank, subject to payment of the applicable filing fee.

2. Are there consequences for meeting (or no longer meeting) the thresholds set out in the size criteria (principle of consistency)?

Meeting or no longer meeting the criteria will only have consequences if this occurs for two consecutive financial years. This is known as the consistency principle (Art 1:28 CCA).

3. One size criterion is the level of revenue, other than exceptional revenue, excluding VAT. What does this cover?

This refers to revenue generated by the association or foundation in the ordinary course of business.  

For a small association or foundation, this concept refers to the total revenue included in the statement of revenue and expenditure based on the minimum schedule for “small” associations or foundations, less exceptional revenue.

For large or very large associations or foundations, this is the total revenue booked to accounts 70 through 74 in the system of accounts.

For a newly formed association, the board of directors must determine, based on the budget, which accounting system should be followed

More information: CBN/CNC Opinion 2022/03

4. Are the size criteria assessed on a consolidated basis, as is the case for companies?

The size criteria are assessed separately for each association or foundation.
There is an exception for foreign non-profit associations with a centre of operations in Belgium. For purposes of the size criteria, all centres of operations in Belgium of a foreign non-profit are taken into consideration.

5. When assessing the size criteria, should the number of full-time equivalents (FTEs) include persons who are paid by another entity (such as a federal public service) but who effectively work for the association or foundation?

Such persons should be included when calculating the number of full-time equivalents if the employment contract was concluded between the individual and the association or foundation.

Such persons should be disregarded for the purpose of calculating the number of full-time equivalents if the employment contract was concluded between the individual and another entity (for example a federal public service).

6. What are the obligations of large and very large associations and foundations that are subject to special legislation or rules?

Associations and foundations that are subject to other accounting obligations pursuant to specific rules or legislation do not have to comply with the accounting provisions of the CCA insofar as the accounting rules or laws to which they are subject are at least equivalent.

If the board of directors considers the annual accounts drawn up pursuant to the applicable legislation to be at least equivalent, the accounts must be filed with the National Bank. They must be accompanied by a special cover sheet for the annual accounts of associations or foundations compiled based on a non-standard model. The association or foundation must state on the cover sheet the statutory or regulatory basis justifying the use of a different model.

For more information, see the CBN/CNC Recommendations on the equivalence of accounting and financial statement rules laid down by sector-level regulations with the ordinarily applicable accounting and financial statement rules for non-profits, international non-profits and foundations.

7. Which associations and foundations must draw up a social balance sheet?

A social balance sheet must be prepared by each association or foundation with on average at least 20 employees, on an annual basis, expressed in full-time equivalents (FTEs). In the case of large and very large associations and foundations, the social balance sheet forms part of the annual accounts to be filed with the National Bank.

Large or very large associations and foundations which use a model other than the abridged or full standard model for their annual accounts must include a social balance sheet if the model they use does not include one.

Associations and foundations employing fewer than 20 FTEs but that are required to file their annual accounts with the National Bank may complete the social balance sheet section of the filing, for the purpose of transparency.

A small association or foundation which does not have to file annual accounts with the National Bank but employs 20 FTEs or more must prepare a social balance sheet and submit it to the Central Balance Sheet Office. This information is incorporated into the statistics published by the CBSO but is not made publicly available.