- The order approves new models for filing annual accounts with the Commercial Registry, in electronic format.
- The normal model and the abridged and SME models change, with fewer notes and new sheets for the average payment period.
- 2016 accounts not yet filed must use the new models: check the calendar for approval and filing.
On 25 May 2017 the State Gazette published Order JUS/471/2017 of 19 May, approving the new models for filing with the Commercial Registry the annual accounts of those obliged to publish them. It replaces the 2009 models and adapts to the changes to the General Accounting Plan introduced by Royal Decree 602/2016 and to the European directive on annual accounts.
It arrives in the middle of the season: companies must draw up their accounts within three months of the year end, approve them at a general meeting within the following six months and file them with the Commercial Registry in the month after approval. For those with a calendar year-end, that puts filing at the end of July at the latest. 2016 accounts approved and filed before the order took effect do not need to be filed again.
Which models and what changes
The order approves the normal, abridged and SME models, and makes them bilingual to reflect the co-official status of other languages. It keeps the electronic XBRL format for filing and seeks to reduce companies’ reporting burden. In the normal model, the notes become optional, although the standardised tables must be accompanied by the rest of the non-standardised information.
In the abridged and SME models, the statement of changes in equity is removed and several notes are dropped, such as those on financial assets and liabilities, income and expenses, grants, environmental information and supplier payments. The average supplier payment period and the allocation of profit are now captured in additional identification sheets.
Goodwill and other details
Other changes affect goodwill: the “goodwill reserve” is excluded from the allocation of profit and accumulated goodwill amortisation is included in the reconciliation table, in line with the accounting reform. References to intangible assets with an indefinite useful life are also removed. In the normal model, raw materials and other supplies are broken down between long and short term.
There are also adjustments in the normal model for related-party transactions, which adds a row for civil liability insurance premiums and a column on employees with a disability of 33% or more. Some automatic error checks in the electronic file go from mandatory to recommended, and others change formula. These are technical details that the filing software must capture.
What to review
Companies that have not yet filed their 2016 accounts should check with their accountant which model applies and whether their software already includes the changes. It is also worth verifying that the general meeting to approve the accounts is called and held on time, and that the documents accompanying the filing, including the audit report where applicable, are prepared in good time.
Not filing the accounts has consequences: the Commercial Registry may close the company’s registry sheet and there are fines for non-compliance, which can range from 1,200 to 60,000 euros. Filing on time protects the company and its directors and avoids complications with banks, suppliers and public tenders, which often ask for filed accounts.
Filing accounts on time and with the right model avoids fines and registry closures.
This article is general information. It is not legal, tax or investment advice, and it does not take anyone’s particular circumstances into account.
