Disclosure deadline for 2022 annual financial statements extended

In cases where the disclosure deadline for the 2022 annual financial statements has already expired, the Federal Office of Justice will not begin to initiate administrative fine proceedings until April.

Certain companies - in particular corporations - are obliged to disclose their accounting documents electronically. For financial years beginning after December 31, 2021, the annual financial statements will no longer be published or filed via the electronic Federal Gazette, but via the company register. The new platform is accompanied by a one-off registration requirement for the person submitting the financial statements.

Even though the annual financial statements for 2022 actually had to be submitted by the end of 2023 at the latest and the deadline cannot be officially extended, the Federal Office of Justice has now announced a similar regulation to previous years. Accordingly, in coordination with the Federal Ministry of Justice, the Office will not initiate administrative fine proceedings before April 2, 2024 against companies whose disclosure deadline for the financial year with the balance sheet date of December 31, 2022 has already expired. This is intended to take appropriate account of the interests of the parties involved in view of the ongoing after-effects of the pandemic.