From financial year 2025, large legal entities file their annual reporting package (jaarrapportage) digitally with the KvK (Dutch Chamber of Commerce). Delivery goes via SBR, in iXBRL or XBRL; emailing a PDF or sending paper is a thing of the past for this group. Small and medium-sized entities have filed this way for years; large was the last size class still allowed to choose. The first mandatory filings are happening now, and that makes the questions suddenly concrete: who falls under it, which format is mandatory, what does it mean for the audit, and which deadlines apply?
Who must file digitally
The obligation applies to legal entities in size class large (groot). A legal entity is large when, on two consecutive balance sheet dates, it meets at least two of these three criteria:
- balance sheet total more than € 25 million;
- net turnover more than € 50 million;
- an average of 250 or more employees.
These are the raised size criteria from Delegated Directive (EU) 2023/2775, implemented in the Netherlands by Stb. 2024, 52 and applying from financial year 2024.
Two situations need to be kept precise:
- Subsidiaries under the group exemption of article 2:403 of the Dutch Civil Code (opens in a new tab) (BW) do not file their own financial statements; the group head files the consolidated financial statements. The exemption only works as long as the conditions are met, including the group head’s declaration of liability and the annual consent of the shareholders, filed with the Business Register. Who files what therefore differs per group structure, and the documents must be mutually consistent. The obligation also reaches beyond an entity’s own size class: medium-sized subsidiaries of a large legal entity or of an issuer are covered as well.
- Listed companies (issuers within the meaning of the Dutch Financial Supervision Act) do not make an SBR filing with the KvK themselves. They deliver the annual financial report in ESEF to the AFM, which forwards the report to the Business Register (article 2:394(8) BW). That is a different regime, with its own taxonomy and its own rules.
What exactly changes
The digitalisation obligation is not new; only the last group is now up. Small entities have filed digitally since financial year 2016, medium-sized since financial year 2017, large from financial year 2025.
What gets filed is the whole annual reporting package: the financial statements, the management report and the other information including the audit opinion, all in the same format and in one delivery. The KvK states the last point explicitly: the audit opinion must be filed in the same format as the financial statements (opens in a new tab).
SBR is the delivery method, not a file format. SBR (Standard Business Reporting) is the Dutch standard for digital reporting, built on XBRL and the Dutch Taxonomy (Nederlandse Taxonomie, NT). Within SBR there are two formats: XBRL and iXBRL. “Filing via SBR or in iXBRL” is therefore a category error: it is filing via SBR, in XBRL or iXBRL.
Submission runs either through SBR software via Digipoort or through the KvK’s Zelf Deponeren portal; that portal accepts an iXBRL delivery, but not an XBRL instance.
In practice the annual reporting package becomes structured data that the KvK validates. Detailed tagging applies to the financial statements: line items get an element from the taxonomy being reported against. For the notes, the management report and the other information, block tagging is temporarily exempt; it becomes mandatory one year after ESMA (opens in a new tab)’s revised approach to block tagging under ESEF is settled. The tags also do not all come from the Dutch Taxonomy: an iXBRL delivery requires an extension taxonomy, and entities reporting under EU-IFRS tag against the IFRS/ESEF taxonomy. What used to be a formatted document that someone could still adjust before sending is now a data file that must be correct both technically and substantively.
XBRL or iXBRL: what determines the format
The format follows from the financial statements themselves rather than being a strategic choice. An XBRL instance can only be filed where a predefined entry point in the Dutch Taxonomy fits the financial statements. Where no such entry point fits, iXBRL is mandatory, delivered as an SBR Report Package.
iXBRL is mandatory in cases including:
- financial statements prepared under EU-IFRS, including where the consolidated statements follow IFRS and the company-only statements follow Title 9;
- financial statements following a framework other than Title 9 or EU-IFRS;
- Title 9 financial statements with entity-specific notes or a deviating presentation;
- no predefined entry point that fits;
- a sustainability report filed along with the financial statements.
The difference between the formats lies in what the filed document is:
- XBRL is purely machine-readable: structured data without formatting. The filed file and the designed annual report remain two renderings of the same figures, with the consistency risk that brings.
- iXBRL (Inline XBRL) is one document that both people and machines read: the designed report with the tags woven in, and therefore the same document that the board, supervisory directors and stakeholders read.
The role of the auditor
Large legal entities are subject to a mandatory audit, and the audit opinion is part of the filed documents. For delivery as an SBR Report Package, NBA Alert 50 (opens in a new tab) (June 2025) describes what that asks of the auditor. The Alert covers that route only; it does not apply to an XBRL instance.
Two things are central to it. The auditor gives written consent before the audit opinion may be included in the report package. Before that consent is given, the auditor establishes that the human-readable XHTML document matches the audited financial statements and that the machine-readable markings contain no material inconsistencies.
The Alert does not bring the tagging itself within the statutory audit: marking up the data falls outside the audit engagement, and the audit opinion states that explicitly. For anyone who wants assurance on the tagging, the answer is a separate, voluntary assurance engagement under Standard 3950N.
In practice that means:
- Agree early in the process which version the auditor reviews and how it relates to the file that goes to the KvK. Tagging is not a cosmetic step after the audit.
- Every change after the opinion is issued, even “just one figure”, affects the match that was established and therefore the consent that was given. The document then goes past the auditor again.
- The more reconstructable the process (which source figure, which tag, what has changed since the previous review), the more smoothly that alignment goes.
- The opinion itself has to be produced in the filing format, not attached as a separate PDF. That is the requirement from the previous section, and it applies to the opinion exactly as it does to the financial statements.
Teams that format the annual report in Word and have the filing converted separately usually discover this in the last week: two document streams that must demonstrably be identical, without a mechanism that enforces it.
The timeline for financial year 2025
The filing deadlines themselves do not change, only the format. The main line for a calendar financial year 2025:
- Preparation by the board within five months after the end of the financial year for a BV or NV; the general meeting can extend that term by a maximum of five months. For an association or foundation within the scope of Title 9, the preparation term is six months, extendable by no more than four months on grounds of special circumstances (articles 2:49 and 2:300 BW).
- Adoption by the general meeting. For an association or foundation this happens no later than one month after the preparation term ends.
- Filing within eight days after adoption, and in any case no later than twelve months after the end of the financial year. For financial year 2025, the final date is therefore 31 December 2026.
Housing corporations have their own, tighter term. Article 35(3) of the Woningwet requires the financial statements to be adopted within six months after the end of the financial year — by the supervisory board where the corporation is a foundation, and by the general meeting where it is an association. That article provides no extension.
Note the well-known BV nuance from article 2:210(5) BW: if all shareholders are also directors, signing the financial statements counts immediately as adoption, unless the articles of association provide otherwise. The condition is that all persons entitled to attend the meeting have had the opportunity to review the prepared financial statements and have agreed to this way of adopting them. Where that is the case, the eight-day term starts running immediately and the outer filing date becomes the preparation term plus eight days.
One piece of relief is built into the rules: the temporary block-tagging exemption keeps the tagging work in this first round with the financial statements rather than across the whole report.
For the first digital round, do not plan the delivery as the final step. The format is now part of producing the annual reporting package, not something added afterwards once the board has approved it. Reserve time for the tagging, the validation against the applicable taxonomy and the alignment with the auditor, before the adoption meeting and not after.
How Taxxor does this
Taxxor Disclosure Manager produces the KvK filing and the designed annual report from the same structured source: the iXBRL delivery, the print-ready PDF and the PDF for online publication are consistent by construction. Validation runs against the applicable taxonomy, including the extension taxonomy an iXBRL delivery requires. With full data lineage and an Auditor View, the auditor sees where every figure comes from and what has changed since the previous review, which is precisely the demonstrability that digital filing calls for. Taxxor is listed on XBRL Nederland (opens in a new tab)’s list of KvK Groot providers.
More on the approach for large legal entities: filing financial statements with the KvK — size class large.