STAY ON TRACK: A Comprehensive Guide to 2026 Key Deadlines for Non-Profit Organisations

This article by Alix Degrez from EY Law Belgium provides a clear and practical overview of the key legal, tax and administrative deadlines non-profit organisations must anticipate in 2026.

I. Introduction

Non-profit organisations (hereafter: “NPO”) are confronted with numerous legal, tax, and administrative obligations. To help you navigate this complex landscape in 2026, EY Law’s Non-Profit & Trade Associations Team has compiled the key deadlines your NPO must respect throughout the year. This article is designed as a roadmap to keep your organisation compliant and on track in 2026.

II. How to use this guide

This guide follows the calendar year in chronological order, so you can anticipate upcoming obligations month by month. For each date, we explain what is required, who it applies to, and key considerations to keep in mind. Obligations that repeat (monthly, quarterly, annually) and those that are linked to your financial year or triggered by corporate events are clearly indicated so they can be integrated into your internal planning cycle.

III. JANUARY

A. January 1^st – Mandatory e-invoicing

From January 1^st, all Belgian business-to-business (B2B) invoices must be issued and sent electronically in a structured format that enables automated processing. This obligation also applies to NPOs which must issue and receive structured electronic invoices if the following conditions are met:

VAT status: The NPO is VAT-registered in Belgium (including those under the small enterprises regime) and does not exclusively perform VAT-exempt activities as listed under article 44 of the Belgian VAT Code;

• Customer: The invoice is issued to another VAT-registered entity in Belgium, which is required to provide its Belgian VAT number, and is also not exclusively performing VAT-exempt activities; and

• Local transactions: The transaction concerns a local supply of goods or services in Belgium that is not VAT-exempt under article 44 of the Belgian VAT Code.

The Belgian authorities have announced a tolerance period during the first quarter of 2026, provided that the taxable person can demonstrate sufficient efforts to ensure the correct and timely application of e-invoicing. However, this tolerance does not delay the go‑live date: e‑invoicing is mandatory as of January 1^st, 2026. It goes without saying that in cases where structured e-invoicing cannot yet be implemented, your NPO must still comply with invoicing obligations by using an alternative format or transmission method.

B. January 31^st/March 31^st – VAT notification for monthly filers (mixed/partial VAT status)

Many NPOs (depending on their activities) are mixed or partial VAT-taxable persons as a result of which the VAT incurred on incoming costs is therefore only partly deductible. This partial VAT deduction can be exercised either via a general pro rata or the real use method. Since respectively January 1^st, 2023, and January 1^st, 2024, a prior e-notification must be done by the mixed or partial VAT-taxable NPO regarding the method used. This prior e-notification is twofold:

• Before January 31, 2026, for monthly filers or March 31, 2026, for quarterly filers: The application of the general pro rata or real use method must be notified via specific forms for new or changed VAT-taxable persons; and

• In one of the first three Belgian VAT returns of the year for monthly filers or the VAT return of the first quarter for quarterly filers: Detailed information regarding the percentages of VAT incurred relating to the VAT-taxable, VAT-exempt/out of scope and both activities, and the special pro rata determined/applied for the overhead/mixed costs.

IV. MARCH

March 31^st, 2026 – Multiple annual obligations:

A. Filling of the compensation tax return

NPOs are subject to an annual wealth tax called “compensation tax for inheritance tax” (hereafter: “compensation tax”) from January 1^st following the date of their constitution onwards. Certain entities fall outside the scope, including—among others—foundations of public utility, de facto associations, foreign non-profit associations, or foundations as well as taxable entities whose taxable basis is below EUR 50,000. Legal entities subject to the tax must file the compensation tax return within the first three months of the relevant tax year, i.e., at the latest on the March 31.

B. Annual VAT client listing

NPOs must submit their annual VAT client listing by March 31, 2026. This listing is an annual return quoting all VAT-liable clients or customers with a Belgian VAT number to whom the NPO has supplied goods or services above EUR 250.

C. Well-being at work (employment)

• Annual training plan (≥ 20 employees)

  Under Belgian legislation on well-being at work, NPOs employing at least 20 employees must establish an annual training plan. The plan must be prepared and approved by March 31 of the current work year, after consultation with the work council (if any), the trade union delegation (if any) or the individual employees.

• Annual report of the internal Service for Prevention and Protection at Work (“SIPPT”/”IDPBW”)

  Under Belgian legislation on well-being at work, all NPOs employing employees must prepare an annual report summarizing preventive measures taken during the previous calendar year. This report must be completed and kept available for inspection by March 31 of the current year.

V. JUNE

A. June 29^th – Filing of form 281.50

NPOs must submit Form 281.50 for the 2025 calendar year by June 29, 2026, reporting payments made to non-residents during that period.

VI. SEPTEMBER

September 30^th – Legal entities/corporate income tax

Under Belgian law, NPOs have 7 months from the end of their financial year to submit their legal entities/corporate income tax return, irrespective of the date of the ordinary general meeting. However, for the NPO whose financial year ends between December 31, 2025, and 28 February 2026, the Belgian tax administration allows filling by September 30, 2026.

VII. NOVEMBER TO DECEMBER

A. Before November 1^st - Annual action plan (well-being at work (employment))

Under Belgian legislation on well-being at work, all NPOs employing employees must prepare an annual action plan—in addition to the five-year global prevention plan—for the upcoming work year and submit it for review and advice before November 1^st to the Committee for Prevention and Protection at Work (if any), the trade union delegation (if any), or to the individual employees.

B. Before December 15^th - Posting of replacement days for public holidays for 2027

The public holidays and replacement days should be included in the NPO’s work rules. In addition, the employer must announce the replacement days for public holidays falling on a Sunday or a regular day of inactivity for the upcoming year no later than December 15 of the preceding year.

C. Before December 31^st - Posting of collective holidays for 2027

NPOs must finalize and announce the collective holiday closure for 2027 by December 31.

VIII. DEADLINES LINKED TO YOUR FINANCIAL YEAR AND CORPORATE EVENTS

A. Within 3 months after the closure of the financial year – Employment plan (age 45+)

Under Belgian legislation on well-being at work, NPOs employing at least 20 employees must establish a one-year or multiple-year employment plan. containing organisation-specific measures designed to maintain or increase the number of employees aged 45 and over. The plan must be prepared and submitted to the works council (if any), the trade union delegation (if any) or the individual employees (and/or the Committee for Prevention and Protection at Work (if any)) within 3 months after the closure of the financial year.

B. Within 6 months after the end of the financial year – Approval of the annual accounts and the budget

• NPOs must keep financial records and prepare annual financial statements. The exact extent of these obligations depends upon the size of your NPO. However, as a general rule, within 6 months after the end of the financial year:

  
  

• The general assembly for (international) non-profit associations and the board of directors for foundations shall approve (i) the annual accounts for the last financial year and (ii) the budget for the ongoing financial year.

  Subsequently, the annual accounts must be filed with the clerk’ office of the Enterprise Court or the National Bank of Belgium (depending on the size of your NPO) within 30 calendar days after approval and at the latest seven months after the financial year’s closure.

C. Within 30 days - Administrative and publication formalities 

Certain events that occur in the life of an NPO entail the obligation to perform administrative and publication formalities: changes in the board of directors’ composition, the person in charge of the daily management, the statutory auditor, the registered office address, amendments to the articles of association, etc.

When these events occur, the NPO must (i) file the document(s) evidencing the latter with the clerk’s office of the Enterprise Court within 30 days, (ii) ensure publication in the Annexes to the Belgian Official Gazette, and (iii) update the Crossroads-Bank for Enterprises.

D. At least once in 2026 – UBO register: Annual update/confirm

Registration with the UBO register is not a one‑off obligation. The UBO register must always be updated within one month of any change in recorded information, and the NPO must confirm the information at least once a year.

Failure to comply with its UBO obligations may lead to personal fines for directors and persons in charge of the daily management, automatic striking off from the Crossroads-Bank for Enterprises, and bank account blocks. Therefore, timely updating of the UBO register should therefore never be overlooked.

IX. RECURING VAT OBLIGATIONS

Belgian VAT return must be filed by 20^th of the month for monthly VAT returns or by 25^th of the month for quarterly VAT returns following the reporting period (extended to the first working day if the deadline falls on a Saturday, Sunday or public holiday).

X. RECURRING PAYROLL AND SOCIAL SECURITY OBLIGATIONS (NON-EXHAUSTIVE)

Quarterly social security contributions (NSSO)

As a Belgian employer, NPOs are subject to several social security obligations. One of the most important is the requirement to file declarations and pay social security contributions, which are calculated based on employees’ gross salaries. These social security contributions must be remitted to the National Social Security Office (NSSO) on a quarterly basis, no later than the last day of the month following the end of each quarter. The deadlines for 2026 are as follows:

-         First quarter: April 30^th, 2026

-         Second quarter: July 31^st, 2026

-         Third quarter: October 31^st, 2026

-         Fourth quarter: January 31^st, 2027

Social security obligations are typically processed with your payroll agency, but the employer remains responsible for withholding and payment.

Monthly pay slips

Each month, NPOs must provide employees with a pay slip clearly summarizing monthly salary and benefits.

Annual employee statements

On an annual basis, NPOs must deliver:

• Individual account summarizing yearly salary and benefits: by March 1^st (2027) of the following year;

• Annual wage statement (tax form 281.10) before February 28^th (2027) of the year following the year to which the income relates.     

XI. ANTICIPATED MEASURE - MANDATORY FEDERAL MOBILITY BUDGET

From January 1^st, 2026, employers offering company cars are expected to be required to provide a so-called mobility budget as an alternative. This system allows employees to choose between (i) an eco-friendly car, (ii) sustainable transport options, or (iii) a cash payment for any unused amount.

Please note that, while the mobility budget has become mandatory as of January 1^st, 2026, it has not yet been transposed into Belgian legislation.