Validation report and error detection

The validation report indicates whether the annual accounts contain errors and/or give rise to warnings.

There are three possible options:

  • Green: no errors or warnings; everything is in order.
  • Orange: warnings are made; accounts that give rise to warnings can still be filed.
  • Red: errors have been detected; a form with errors cannot be filed.

 MORE INFO This document provides an overview of all possible errors: available in Dutch and French

Rejection of annual accounts

If a filing is rejected, the reason for the rejection will be mentioned in the validation report which can be found in the filer’s personal space. In this case, the status will be indicated as “rejected after examination”. The comments of the Central Balance Sheet Office and the reason for rejection will be mentioned in each case.

Annual accounts may also be rejected if the filing fee is not paid correctly or on time. The status will then be indicated as “rejected for non-payment”.  

In brief

  • How to consult the validation report: available in Dutch and French
  • How to log in to the Filing application: available in Dutch and French

Frequent grounds for rejection

1. The file does not meet the technical and/or formal requirements

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.

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:

  • 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 annual 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.

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….: 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).

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 format”: Figures are expressed with decimals whereas they should be expressed without decimals or an obsolete social balance sheet model was used.
  • “Absence of or inconsistency in dates (opening/closing date of the financial year/date of the AGM)”: The most common omissions and inconsistencies concern failure to enter the date of the annual general meeting correctly 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 non-compliant”: Entities obliged to file a specific model must use a specific cover sheet for the full model and (in some cases) for the abridged model of accounts, with the appropriate code for the 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 non-standard model must be mentioned. Associations and foundations filing under a derogation should also use a specific cover sheet (Dutch and French).
  • “The 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 (or income) 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 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.

2. The filing fee was not paid, only partially paid or paid late

If the file passes the automatic validation stage and a visual check, it is granted “ready for payment” status. The filing fee can then be paid by debit card, credit card or bank transfer. In the Filing application, it is possible to opt for payment by a third party. In this case, it is necessary to specify the payer’s e-mail address; a payment link will be sent by e-mail.

Accounts filed online will be automatically rejected if the filing fee is not received within six business days from the grant of “ready for payment” status. Common causes of rejection on this basis are:

  • the filing fee is paid on the sixth business day after the file is marked as “ready for payment” but the payment service provider, CCV, does not receive the payment until the seventh business day or later, whereas the payment service provider must receive the filing fee no later than the sixth business day; it is therefore advisable to pay the filing free immediately;
  • the payment service provider receives an incorrect amount: this happens quite often with batch filings when the filing fee is paid from more than one bank account with the same structured communication.

Finally, the filer will be informed by e-mail of the rejection of the accounts due to non-payment or partial payment of the filing fee and of the procedure to be followed to refile them. The filer must therefore provide a correct e-mail address in the “My profile” section of the Filing application.

3. An incorrect structured communication was used to pay the filing fee

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.

4. The filer withdraws the accounts

As long as the filing fee has not been processed, the filer can withdraw accounts submitted online. In this case, the filer must restart the filing procedure from the beginning, meaning the filing date will change (with possible implications for the filing free).