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TAX & BUSINESS
Submission of Annual Accounts to the Commercial Register
A change to the regulation on electronic legal communication results in adjustments to the formal requirements for filing accounts.
The submission of the annual accounts has been carried out since July 2022 in structured electronic form as an XML file, previously via FinanzOnline. With the regulatory amendment, which entered into force on 1 March 2025, the following changes apply:
FinanzOnline will be discontinued as a transmission route from 1 January 2026. From then on the following filing routes will be available:
Conversely, the new file structure “JAb 4.0” (previously JAb 3.32) has been mandatory since 1 March 2025. Annual accounts for 31 December 2024 may still be disclosed using the JAb 3.32 structure. Where transmission in structured electronic form is not possible, the documents may exceptionally also be submitted as a PDF attachment, provided the reason for the impossibility is stated at the time of filing.
Penalties for defaults
Timely disclosure is a legal obligation. If the nine‑month period from the balance‑sheet date is exceeded, coercive fines of EUR 700 to EUR 3,600 (for micro‑companies EUR 350 to EUR 1,800) are to be expected. This applies both to the company itself and to individual managing‑director and board members. For example, a company with two managing directors would be subject to a minimum coercive fine of EUR 3 × 700 = EUR 2,100. In case of continued default, the fine may increase after two months to three times the amount (for medium‑sized companies) or even six times (for large companies).
Obligation to file
Companies are required to file their annual accounts electronically with the competent commercial‑register court no later than nine months after the balance‑sheet date. Accordingly, annual accounts for 31 December 2024 must be disclosed by 30 September 2025 at the latest. The disclosure obligation applies to all companies, including so‑called “capitalist partnerships” such as GmbH & Co KG, where no natural person is an unlimited‑liability partner.
Depending on the size of the company, the scope and content of the required documents differ; for instance, a micro‑company only has to disclose its balance sheet without notes. Branches of foreign companies in Austria are also required to disclose.
Conclusion
As the requirements for electronic disclosure of commercial‑register annual accounts become increasingly complex and the penalties for default can accumulate, we recommend early advice and the handling of the transmission of annual accounts to the commercial register by our staff.
FinanzOnline will be discontinued as a transmission route from 1 January 2026. From then on the following filing routes will be available:
- for micro‑companies and small companies: form on justizonline.gv.at for direct, manual entry
- XML file via an ERV transmission centre or via an online form on justizonline.gv.at
Conversely, the new file structure “JAb 4.0” (previously JAb 3.32) has been mandatory since 1 March 2025. Annual accounts for 31 December 2024 may still be disclosed using the JAb 3.32 structure. Where transmission in structured electronic form is not possible, the documents may exceptionally also be submitted as a PDF attachment, provided the reason for the impossibility is stated at the time of filing.
Penalties for defaults
Timely disclosure is a legal obligation. If the nine‑month period from the balance‑sheet date is exceeded, coercive fines of EUR 700 to EUR 3,600 (for micro‑companies EUR 350 to EUR 1,800) are to be expected. This applies both to the company itself and to individual managing‑director and board members. For example, a company with two managing directors would be subject to a minimum coercive fine of EUR 3 × 700 = EUR 2,100. In case of continued default, the fine may increase after two months to three times the amount (for medium‑sized companies) or even six times (for large companies).
Obligation to file
Companies are required to file their annual accounts electronically with the competent commercial‑register court no later than nine months after the balance‑sheet date. Accordingly, annual accounts for 31 December 2024 must be disclosed by 30 September 2025 at the latest. The disclosure obligation applies to all companies, including so‑called “capitalist partnerships” such as GmbH & Co KG, where no natural person is an unlimited‑liability partner.
Depending on the size of the company, the scope and content of the required documents differ; for instance, a micro‑company only has to disclose its balance sheet without notes. Branches of foreign companies in Austria are also required to disclose.
Conclusion
As the requirements for electronic disclosure of commercial‑register annual accounts become increasingly complex and the penalties for default can accumulate, we recommend early advice and the handling of the transmission of annual accounts to the commercial register by our staff.