Companies (Moniteur belge/Belgisch Staatsblad)

22 March 2021 - Errata - page 30698 

27 December 2019 - Ed. 2 - pages 118531 to 118538

15 May 2019 - Errata - page 46951

24 October 2016 - pages 71588 to 71594

Associations and foundations (Moniteur belge/Belgisch Staatsblad)

4 December 2020 - Errata - page 84910

7 September 2020 - pages 65102 to 65108

Social balance sheets are subjected to a series of specific checks.

The list is appended as Annex 1.3 to the Protocol on the filing by electronic means of annual accounts in the form of a structured data file.

The file containing the annual accounts must meet certain technical and formal requirements in order to be accepted. In most cases, these checks are done automatically. In a few cases, however a Central Balance Sheet Office employee is involved.

1. Automatic validation

All files are subjected to automatic validation. The method used to check a file which has been submitted online depends on the type of file and whether a standard model was used to compile the accounts:

• for XBRL files, checks are always performed at this stage to determine whether the uploaded file:
  • meets the applicable structural and technical requirements,
  • fulfils all arithmetic and logical conditions in terms of content,
  • contains the correct identifying details (e.g. legal status) for the legal entity whose accounts are being filed,
  • contains correct information for the financial year to which the accounts relate;
• for PDF files, checks are always performed at this stage to determine whether the uploaded file
  • meets the applicable technical requirements,
  • mentions the correct company number,
  • for standard models of accounts, fulfils all arithmetic and logical conditions in terms of content,
  • contains the correct identifying details (e.g. legal status) for the legal entity whose accounts are being filed,
  • contains correct information for the financial year to which the accounts relate.

During automatic validation, a message will be sent almost immediately by the Filing application if an issue is detected during any of the abovementioned checks. The most common problems are:

• Unable to locate the following schema reference: http ://www .nbb.be/be/fr/pfs/ci/xxx-2020-02-01.xsd….: This means that obsolete software was used to prepare the file. It will be necessary to create a new file using either a more recent version of the accounting software (please contact the supplier) or the Filing application itself.
• The PDF file contains layers or comments. These are prohibited (see the “Protocol on the filing by electronic means of annual accounts and consolidated annual accounts in the form of a PDF file”, available in French and Dutch).

  This issue can be resolved by reprinting the document in PDF (or printing and scanning, if required).

2. Visual check

A file will only be subjected to a visual check if:

• during automatic validation of an XBRL file, the Filing application identifies certain issues requiring a decision by the filer or the Central Balance Sheet Office;
• a PDF file or an XBRL file containing certain information in the form of a PDF file is uploaded; in this case, an additional check must be performed by the Central Balance Sheet Office.

For a visual check, the most common grounds for rejection are:

• “Poor contrast, small type or readability issues”: The accounts were prepared using a very small typeface or printed (and then scanned) using a printer with insufficient toner.
• “Annual accounts do not comply with the applicable standard form”: Figures are expressed with decimal places whereas they should be expressed without decimal places or an obsolete social balance sheet model was used.
• “Absence or inconsistency of dates (opening/closing date of the financial year/date of the AGM)”: The most common omissions or inconsistencies concern failure to enter the date of the annual general meeting as required or cases where the general meeting has yet to take place but the date has already been entered or the general meeting was held before the close of the financial year.
• “The cover sheet is missing or noncompliant”: Filers that are required to use a specific model must attach a specific cover sheet for the full model and (in some cases) for the abridged model of annual accounts, with the appropriate code per type of undertaking, such as credit institutions, investment firms and management companies of collective investment undertakings (Dutch: VOL-inst and VKT-inst; French: C-ét and A-ét), insurance companies (Dutch: VOL-ver and VKT-ver; French: C-ass and A-ass), copyright collecting societies (Dutch: VOL-AUT and VKT-AUT; French: C-AUT and A-AUT) and others (exceptional cases) (Dutch: VOL-A and VKT-A; French: C-A and A-A). The statutory or regulatory basis justifying the use of a different model must be mentioned. Associations and foundations filing under a derogation should also use a specific cover sheet (Dutch and French).
• “The annual accounts were not drawn up in a single language”: This ground for rejection is often seen when the balance sheet and the profit and loss statement are not in the same language as the documents to be filed along with the accounts, such as the auditor’s report or the management report; that being said, established foreign language terms such as “cash flow”, “human resources” and “public relations manager” may be used.
• “The information entered does not match the PDF”: This error usually concerns the starting and/or closing date of the financial year, i.e. the dates on the cover sheet of the file differ from those entered in the Filing application or an identical file is awaiting payment.
• “These annual accounts have already been filed”: A file is often based on that of the preceding financial year; occasionally, the previous year’s file is submitted accidentally instead of the updated one.

For payment by bank transfer, only the structured communication assigned to the filing upon the initiation of payment will be accepted. When initiating payment, the payment method to be indicated is “bank transfer”. A structured communication is composed as follows +++ 012/3456/78910 +++.

Therefore, the reference beginning with “L” of the payment request or order (e.g. L221222120931602CB8D6B58.1) and the CCV reference (e.g. d018ac14-7612-11ed-a7f8-c14b249a6cff) should NEVER be used as a structured communication.