Filing of annual accounts (eCDF) – Article 70
This service is available to subsidiary companies that meet the conditions of Article 70 of the law of 19 December 2002 concerning the RCS. Under certain conditions, they may not apply the general provisions relating to the content, filing and publication of their annual accounts and invoke the special regime for parent companies and subsidiaries.
Subsidiary companies may choose not to file or publish their annual accounts or to file them for purely administrative purposes, without making them available for consultation by third parties.
If they opt to file their accounts for administrative purposes, they must first prepare certain documents of the accounting bundle on the eCDF platform (electronic platform for the collection of financial data).
The user can then, when creating their filing request with the RCS, directly retrieve the data previously validated on the eCDF platform. They must also attach any other documents required by law in PDF/A format.
What documents have to be attached?
In addition to the accounting documents prepared on the eCDF platform (if the subsidiaries have chosen to file their annual accounts with the RCS for purely administrative purposes, they will not be available for consultation by third parties), the user will have to attach to the filing: the consolidated accounts of the parent company, which will be published, the consolidated management report and the report of the certified auditor.
The following must also be attached: the declaration of all the shareholders or associates of the subsidiary company stating their agreement to the exemption and the declaration of the parent company guaranteeing the commitments made by the subsidiary company.
What information must be entered in the RCS and how can the required documents be attached?
Dates of the financial year
The user first has to enter the start and end date of the financial year of the annual accounts filed. The dates must be consistent with those mentioned in the eCDF declaration and any other accounting documents to be attached to the filing request.
They then click Next to continue creating their filing request.
Choice of language for the accounting bundle
The user then has to select the language of the accounting bundle filed, i.e. the language of the forms chosen on the eCDF platform.
Selection of the eCDF declaration
If the subsidiary company has opted for the filing of its accounts with the RCS, it has first made its declaration on the eCDF platform.
The user then has to select the eCDF declaration concerned from the drop-down list (plan comptable).
The other documents, namely the balance sheet, the profit and loss account and the mapping table, will be attached automatically and cannot be modified.
Note that the declaration selected by default is the one most recently prepared on the platform.
The content of the declarations can be refreshed by clicking on the Refresh button.
The user also has to choose whether the profit and loss account can be consulted by third parties.
To continue the filing request, the user then has to click on Complete publication.
Declarations as referred to in Article 70 of the law of 19 December 2002
The user has to attach the declarations referred to in Article 70 of the law of 19 December 2002 under the heading Publication in the field Documents to be published by mention.
They should be attached in a single PDF/A file. The file will be available for consultation by third parties and published in the RESA by means of a filing mention generated automatically by the RCS administrator.
The user can choose a specific publication date if they wish. They then have to check the box I wish to specify the publication date and indicate the desired date. Otherwise, the publication date corresponds to the date on which the filing request was accepted by the RCS administrator.
To continue their filing request, the user then has to click on Add documents to attach.
Other accounting documents relating to the parent company and the subsidiary
The other accounting documents relating to the parent company should be attached under the heading Attached document(s) in the field Document(s) to be filed - Other accounting documents of the parent company not to be published.
They should be attached as a single document in PDF/A format. The document will not be available for consultation by third parties.
The subsidiary's other accounting documents must be attached, in a single document in PDF/A format in the field Other accounting documents of the subsidiary not to be published. This document will not be available for consultation by third parties.
To finalise their filing request, the user then has to click on Verification of the filing application.
