With the annual general meeting held or about to be held, one last step remains for the 2025 accounts: filing, which is an obligation of the directors. If you have not yet held the meeting, you may first want to read our article on the annual general meeting before 30 June.
Deadline: the month following approval
Within the month following approval of the annual accounts, the directors must submit them for filing with the Companies Register of the registered office (art. 279.1 of the Spanish Companies Act, LSC). The period runs from the date of the general meeting that approves them, not from the year-end or from the date the accounts were prepared. So if the meeting is delayed, filing is also delayed, even though a meeting held late is valid (art. 164.2 LSC).
For companies with their registered office in the province of Alicante, the competent register is the Alicante Companies Register.
Which documents are filed
| Document | When it is submitted | Provision |
|---|---|---|
| Certificate of the general meeting resolutions approving the accounts and the appropriation of profit or loss | Always | Art. 279.1 LSC |
| A copy of the annual accounts, duly signed | Always | Art. 279.1 LSC |
| Consolidated accounts | When the company prepares them | Art. 279.1 LSC |
| Management report (with the non-financial information statement where applicable) | When the company is required to prepare one | Art. 279.1 LSC |
| Auditor’s report | If the audit is mandatory, was ordered at the request of minority shareholders or is voluntary with a registered appointment | Art. 279.1 LSC |
If any document has been prepared in abridged form, this must be stated in the certificate together with the reason (art. 279.2 LSC). The accounts must match those prepared and, if the company is audited, those audited: hence the importance of avoiding last-minute changes, as we explain in what to review in the prepared accounts before calling the general meeting.
Registrar’s review and public access
Within fifteen days of the date of the entry recording the submission, the registrar checks whether the documents are those required by law, whether they have been duly approved by the general meeting and whether the required signatures appear. If no defects are found, the filing is deemed to have been made; if defects are found, the submission is treated as a defective document that must be remedied (art. 280.1 LSC). Once filed, anyone may obtain information on the accounts from the Register (art. 281 LSC), including customers, suppliers and financial institutions.
First consequence: closure of the registry sheet
If the board does not file on time, no document relating to the company will be registered with the Companies Register while the failure continues (art. 282.1 LSC). This can block transactions such as a capital increase, a change of registered office or the appointment of new directors.
The law makes an exception for certain documents (art. 282.2 LSC):
- The removal or resignation of directors, managers, general managers or liquidators.
- The revocation or waiver of powers of attorney.
- The dissolution of the company and the appointment of liquidators.
- Entries ordered by a judicial or administrative authority.
Second consequence: the ICAC fine
The failure may also lead to a fine on the company, imposed by the Spanish Institute of Accounting and Auditing (ICAC), the national audit oversight authority, following disciplinary proceedings (art. 283 LSC):
- General amount: €1,200 to €60,000.
- Companies or groups with annual turnover above €6,000,000: the maximum fine rises to €300,000 for each year of delay.
- Determining the amount: the size of the company is taken into account, based on total assets and sales in the last financial year declared to the tax authorities; if those figures are not available, share capital is used.
- Reduction: if the accounts are filed before the penalty proceedings begin, the penalty is imposed at its minimum level and reduced by 50%.
- Limitation: the infringement becomes time-barred after three years.
If the deadline has passed, it pays to regularise the position as soon as possible.
Frequently asked questions
Must I file the auditor’s report if the audit is voluntary?
Only if the auditor’s appointment has been registered with the Companies Register. In other cases of voluntary audit, the law does not require the report to be submitted (art. 279.1 LSC).
What happens if the registrar finds defects?
The filing is not deemed to have been made until they are remedied, because the documents are treated as a defective submission (art. 280.1 LSC). It is advisable to submit with enough margin to correct any defects within the deadline.
Can I appoint a new director while the registry sheet is closed?
The closure prevents company documents from being registered, except for the exceptions in art. 282.2 LSC, which include the removal or resignation of directors, but not their appointment. The prudent course is to file first.
Official sources
- Spanish Companies Act, consolidated text (BOE): arts. 164, 279, 280, 281, 282 and 283
- Spanish Institute of Accounting and Auditing (ICAC)
- Colegio de Registradores de España (Spanish Association of Registrars)
If your company is audited, the report must accompany the accounts when they are filed: find out about our audit of annual accounts service. If you need to prepare or review the accounts you are going to file, we can help with the preparation of annual accounts. We work with companies throughout the province, as we explain on auditors in Alicante. Contact us if you have any questions about your filing.
What if the company has had no activity and filed no accounts for years? We analyse the Iberinform data and the risks for directors in almost two million inactive companies that do not file accounts.
Article prepared by Controlaudit’s technical team. Published 23/06/2026. Reviewed 08/10/2026. Information only; it does not replace professional advice on your specific case.
