The deadline of 31 December 2027
An independent valuation report referencing 31 December 2025 can be prepared until 31 December 2027. What this deadline means in practice for shareholders.
An independent valuation report establishing the value of unlisted Belgian shares as at 31 December 2025 can be prepared up until 31 December 2027. The deadline gives shareholders time to organise the required documentation, but it does not extend the reference date itself, which remains fixed at 31 December 2025.
- The report can be prepared any time before 31 December 2027.
- The reference date for the valuation stays fixed at 31 December 2025.
- Waiting until close to the deadline increases the risk of missing records.
A window, not a fixed appointment
Shareholders are not required to have an independent valuation report ready immediately. The framework allows for the report to be produced up until 31 December 2027, which gives roughly two years of flexibility after the reference date itself.
This window exists because preparing a proper valuation takes time, requires gathering historical records, and is often not urgent until a shareholder is actually contemplating a sale or transfer of shares.
The reference date does not move
Regardless of when the report is actually drafted and signed, its content must reflect the company as it stood on 31 December 2025. Later developments in the business, whether positive or negative, are not incorporated into this particular valuation.
This means a report signed in 2027 for the 2025 reference date relies on the annual accounts, shareholder register and other documentation as they existed at the end of 2025, not on more recent figures.
Practical reasons to act earlier rather than later
Annual accounts and shareholder registers from 2025 are easier to obtain and verify while they remain current business records. As time passes, staff turnover, accounting system changes or simple administrative drift can make it harder to reconstruct the exact position at the reference date.
Shareholders who anticipate a sale, a family transfer or a restructuring within the next few years often find it more efficient to commission the valuation once the 2025 accounts are finalised, rather than close to the 2027 deadline under time pressure.
What happens if the deadline passes without a report
If no independent valuation report is prepared before the deadline, the statutory formula of equity plus four times EBITDA becomes the applicable reference value for the 31 December 2025 position, without the possibility of substituting a reasoned valuation for that date afterwards.
Planning around the deadline
Because the required inputs are the 2025 annual accounts and shareholder register, the practical planning question is less about the calendar deadline and more about when those documents are complete and available for review.
Questions on this
What happens if the report is signed in 2027 rather than 2026
The report remains valid as long as it references the 31 December 2025 position and is completed before the 31 December 2027 deadline. The signing date itself does not affect the reference date used.
Can the reference date be changed to a later date
No. The reference date tied to this measure is 31 December 2025. The deadline of 31 December 2027 only concerns when the report can be produced, not which date it values.
Is there a benefit to preparing the report earlier
Preparing it earlier means the underlying annual accounts and shareholder records are more readily available and easier to verify, which reduces the practical difficulty of reconstructing the 2025 position.
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This information is general. It does not take your specific situation into account and is not tax advice.