The impact of filing electronic annual reports
for large Dutch companies
As of January 1, 2025, the Netherlands will enforce the “Decision on electronic filing with the trade register in connection with the expansion of the obligation to file electronically.” This mandates that large companies must electronically file their annual reports with the Chamber of Commerce starting from the 2025 financial year. In this article, I explain the impact of this legislative change and provide key tips for Finance professionals in large companies. A must-read for those navigating this transition.
reading time 7 min
What defines a large company?
According to the Chamber of Commerce, a company is classified as “Large” if its financial statements meet at least two of the following criteria for two consecutive years:
- Assets: > €25 million
- Net revenue: > €50 million
- Employees: > 250
Dutch companies classified as Micro, Small, and Medium-Sized Enterprises have been required for years to file their financial statements electronically in the XBRL (eXtensible Business Reporting Language) format through SBR (Standard Business Reporting).
Publicly listed companies, since 2020, have been required across Europe to file their financial statements in the electronic ESEF (European Single Electronic Format), also known as the “EU format.”
Until January 1, 2025, large Dutch companies were exempt from electronic filing.
What does electronic filing mean for large Dutch companies?
In short, the legislative change stipulates the following:
- Large companies must file their annual reports electronically via SBR starting from the 2025 financial year, meaning the first electronic filing will occur in 2026.
- These companies may choose between filing in the XBRL or EU format.
- Large companies subject to the European sustainability reporting rules (CSRD) must file in the EU format.
What is the difference between XBRL and the EU Format (iXBRL)?
XBRL is an open standard for exchanging and reporting financial and business data in a structured, machine-readable format. It is commonly used for filing financial statements and other reports with regulators like the Chamber of Commerce. XBRL enhances efficiency, transparency, and data analysis.
The EU Format (ESEF) is a European Union-mandated standard for electronically publishing annual reports of publicly listed companies. The goal of ESEF is to harmonize financial reporting, make it more transparent, and facilitate data analysis.
Since 2020, publicly listed companies must file their financial statements in ESEF, where financial data is reported in XBRL integrated into the iXBRL (Inline XBRL) format.
This format combines machine-readable XBRL data with a human-readable HTML view, allowing both systems and individuals to interpret the report.
An example is the ESEF report by Heijmans.
The key distinction is that XBRL is only machine-readable, whereas iXBRL is both machine- and human-readable. It’s important to note that an iXBRL publication is not a website; it is a downloadable HTML file that can be opened in a browser.
The influence of CSRD on electronic filing
The Corporate Sustainability Reporting Directive (CSRD) is an EU directive requiring companies to extensively report on their environmental, social, and governance (ESG) impacts.
Companies will need to include sustainability reporting in the EU format, ensuring ESG data is both machine- and human-readable. This fosters consistency and comparability in CSRD reporting.
To prevent large companies subject to CSRD from having to prepare multiple types of reports, it has been decided that they must exclusively use the EU format for electronic filing with the Chamber of Commerce. This will result in a single annual report in iXBRL format, containing both financial and non-financial information tagged with XBRL.
Experiences of publicly listed companies
Publicly listed companies have been filing their annual reports in the EU format for several years, providing valuable lessons for large companies transitioning to this requirement.
Recently, the AFM (Netherlands Authority for the Financial Markets) published key takeaways from its analysis of annual reports filed by Dutch publicly listed companies,
which are also relevant for large companies required to use the EU format:
Key points:
- Ensure accurate tagging of facts and use of taxonomies.
- Minimize the use of extensions.
- Start with an HTML-based document.
- Prepare for mandatory ESEF tagging in CSRD sustainability reports.
- Review detailed AFM findings via their webinar.
Why start with an HTML-based document?
One AFM recommendation is to begin with an HTML-based document when selecting a software tool. There are two approaches to creating an iXBRL publication:
- Print-First
This method focuses on producing a printable report (a “booklet”). Typically, this involves creating a Word or formatted PDF version of the annual report, which is then converted into HTML using specialized software, followed by the addition of XBRL tags. - Digital-First
This method prioritizes creating an HTML report optimized for browser display. This allows for interactive features and adaptability to different screen resolutions. XBRL tags are directly embedded into this HTML version.
The Digital-First approach offers advantages in both the process and the end product. The process is more reliable and efficient, making it easier to update tagged data points.
The end product is of higher quality, as the HTML code remains well-structured and readable—something often lost in converted reports.
Tips for Finance professionals
Here are important tips for Finance professionals at large companies preparing annual reports:
- Start early
With 2026 approaching quickly, begin selecting a software solution for creating the iXBRL annual report early. Ideally, conduct a “dry run” with the auditor in Q3 or Q4 of 2025. - Choose a Digital-First process
Opting for an HTML-based, Digital-First approach avoids many issues and ensures a future-proof, high-quality iXBRL report. - Collaborate with CSRD and Communication teams
Since CSRD data must also be tagged with XBRL, involve colleagues responsible for CSRD and communication early in the tool selection process.
Select tools that enable multichannel publication (simultaneous publication to iXBRL, PDF, and website) to enhance brand perception and maximize the report’s reach. - Recognize the importance of iXBRL
Remember that starting from the 2025 financial year, the iXBRL publication will be the version signed off by the auditor.
While PDF and online versions may still be created and hold value for stakeholders, the iXBRL report will always take precedence in case of discrepancies.
Is your annual reporting ready for the future?
As regulations become increasingly stringent, and stakeholder expectations rise, annual financial and non-financial reporting will grow more complex. Fortunately, innovative software solutions are emerging to transform reporting into a positive experience for your team and stakeholders.
With the right Digital-First tools, you can seamlessly integrate ESEF and CSRD compliant XBRL tags and publish your reports in multiple appealing formats, including mandatory iXBRL, PDF, dynamic websites, or InDesign. This ensures compliance while enhancing corporate communication.
Learn more about how F19 can empower your organization to create the annual report of the future using our cloud-based, Digital-First reporting platform.