First: which set of books does your club owe?
Belgian clubs are usually set up as a non-profit association — ASBL in French, vzw in Dutch. The answer below settles the shape of your accounts and where they are filed. A non-profit keeps simplified accounts for as long as it does not exceed more than one of these four thresholds:
- 5 employees, annual average
- €391,000 in income other than non-recurring, excluding VAT
- €1,562,000 in total assets
- €1,562,000 in total liabilities
Crossing a threshold only counts if it repeats: it takes two consecutive financial years to switch, in either direction. Below them, the accounts fit in a statement of income and expenditure; above them, they go double-entry and are filed with the National Bank rather than the court registry.
These amounts are indexed and go up from time to time; check them if your club is anywhere near. A hundred-member club with no staff is nowhere close, and that is the case this page describes.
The word large means something else, and confusing it with this test is the common mistake. The Code reserves it for far higher thresholds — 50 employees, €11,250,000 in turnover, €6,000,000 in total assets — which govern the format of the published accounts. A non-profit can therefore owe double-entry bookkeeping without being a “large association” at all.
The general meeting, within six months
The ordinary general meeting is held within six months of the close of the financial year. Close on 31 December and the meeting must be held before 30 June.
It approves the accounts, votes the next year's budget, and discharges the directors. That discharge is not a formality, but it is not immunity either: it runs towards the association, and covers the management as the meeting knew it. What was kept from the meeting is not covered, nor is what a third party holds against the directors.
Send the accounts and the budget with the notice of meeting, or say in it where members can consult them beforehand — the statutes settle the detail. They are not to be discovered on the night. Anyone seeing the figures for the first time in the room cannot meaningfully discuss them.
The accounts, and where they go
Once approved, the annual accounts are filed within thirty days.
A small non-profit files with the registry of the enterprise court, in its own file — not with the National Bank, which receives those keeping double-entry books. Filing is free. Provide two copies: the second comes back to you and is your proof of filing.
Failing to file is not a harmless oversight: the court can order the dissolution of a non-profit that has not filed its accounts (article 2:113 of the Code of Companies and Associations), on the application of a member, an interested third party or the public prosecutor, or on referral from the chamber for enterprises in difficulty. One missed financial year is enough, and the action opens seven months after that year closes. The remedy is in the same article: filing the missing accounts before the close of pleadings stops the dissolution.
The register of members
Every non-profit keeps a register of its members at its registered office. The Code of Companies and Associations makes this an obligation in its own right, separate from everything above.
It lists, for each full member, surname, first name and address — or the name and registered office for a legal entity. It is updated on every arrival and every departure, not once a year.
A properly kept member file serves as that register, on three conditions: that it holds what the law requires, that it is current, and that only one version is authoritative. So it is not an extra document to produce annually — it is the list you already keep, kept properly.
The UBO register, to be confirmed every year
The UBO register records the association's beneficial owners: the directors, the people entitled to represent it, those in charge of day-to-day management, those in whose main interest it was set up or operates, and anyone else exercising ultimate control over it. In a club the first three almost always overlap. The founders sometimes quoted are a category of the foundation, not of the non-profit.
Two distinct obligations attach to it, and the second is the forgotten one: any change is registered within the month, and every year you must confirm that nothing has changed. The confirmation is one button inside the register. A year without changes is not a year without a task.
When the committee changes
A director's appointment or resignation is published, and the association's data at the Crossroads Bank for Enterprises is updated. So is a move of the registered office.
This is the most fragile moment in a club's life, and not only administratively: it is when the member file, the passwords and the memory of the accounts leave with the person leaving.
The calendar, in one place
- Within six months of closing — general meeting: accounts, budget, discharge
- Within thirty days of approval — file the accounts with the court registry
- Once a year — confirm the UBO register
- Continuously — register of members at the registered office, kept current
- Within a month of a change — UBO, Crossroads Bank, publication of directors
It sums up what comes back every year in a small club, so you know what to ask about. Your situation may carry obligations we do not know of — paid staff, an accreditation, a subsidy file. The court registry, your federation and your accountant remain the sources that count.
What the tool takes on
And above all what it does not: the line is sharp, so it is stated here.
Frequently asked questions
- Our club is not a non-profit — does this apply?
- An unincorporated association has no UBO register and files no accounts, but it also has no legal personality: committee members are liable on their own assets. That is the main reason a growing club eventually incorporates.
- Do we need an accountant?
- Nothing requires one of a small non-profit. Simplified accounting fits in a statement of income and expenditure that an attentive treasurer produces without training. An outside look stays useful in the first year, and at handover.
- What if the general meeting is late?
- Hold it as soon as you can and file straight after. An isolated delay is recoverable: what counts is the filing, and filing the missing accounts stops a dissolution action, even one already brought.
- Must the register of members be on paper?
- No, the form is free as long as it is kept at the registered office, current and consultable. An electronic file qualifies — it is in fact the only form that stays current all year without anyone copying anything.