Not chronologically, but by sanction
The obvious way is to start with the oldest month and work forwards. It is the wrong one.
The consequences of being in arrears are very unequal in weight, and only one of them can no longer be repaired.
| Rank | Obligation | Worst consequence |
|---|---|---|
| 1 | Annual return HE32 | Striking off the register |
| 2 | UBO register | up to €5,000 per company |
| 3 | VAT registration and returns | €85 for each month started |
| 4 | Social insurance contributions | interest plus 3 % a month, up to 27 % |
| 5 | Corporate tax return | administrative penalties and interest |
According to an announcement by the registrar, companies in default have until 31 December 2026 to file outstanding returns and accounts. Details in the guide to the HE32.
The financial consequences are more limited than feared
This is the part that usually relieves people, and it should not tempt anyone into delay.
| Default | Cost |
|---|---|
| HE32 late | €50 on the first day, then €1 a day, capped at €150 per return |
| VAT registration late | €85 for each month started, plus the VAT that should have been charged |
| Social insurance late | interest plus 3 % a month, capped at 27 % |
| UBO confirmation missed | €100 on the first day, €50 for each further one, up to €5,000 |
The item that really hurts is not in the table: the VAT that should have been charged. For customers already invoiced it can usually no longer be collected, and then the company carries it itself. See the guide to VAT registration.
The practical order
1. Obtain bank statements for the whole period. They are the only complete source. Every payment appears in them, including those whose receipt is missing. From them follows the list of what is still needed.
2. Chase missing receipts, all at once. For subscriptions, software, advertising and payment providers, invoices are usually held permanently in the customer account. The older the transaction, the less likely a reissue, and without a receipt the deduction is gone, see the guide to the lost receipt.
3. Close year by year, starting with the oldest. From here the order is chronological after all, because each set of accounts builds on the closing position of the year before.
4. File the returns in order of sanctions, not in the order in which they arose.
Why it cannot be filed in parts
The chain is fixed: no bookkeeping, no accounts, no complete filing.
Under Article 152A of the Companies Law every Cyprus company needs accounts, including one with no turnover, see the guide to the dormant company. The HE32 goes in together with those accounts. So arrears cannot be defused by submitting the form and supplying the accounts later.
What we could not substantiate
- Whether the extension to the end of 2026 applies generally. We found it in one source, not in an official notice from the registrar.
- The level of sanctions for a late corporate tax return. Administrative penalties and interest are mentioned, without an amount or a formula.
- Whether voluntary disclosure reduces the sanctions. On that we found nothing in the sources we checked.
- Whether the registrar refrains from striking off while a catch-up is under way. The announcement names a deadline, not a procedure for individual cases.
With arrears of more than a year, the order is worth discussing with somebody who answers for it: Cyprus setup from one place.
Bookkeeping: catch up once, then keep up
Arrears do not arise from a decision but from twelve monthly closes that did not happen. Anyone who catches up and then carries on as before builds them up again.
What helps with catching up is that movements come in as a file through data import instead of being typed in one by one, and that receipt capture shows which payments are still missing one. Banking shows what is not yet matched to a transaction.
So that it does not happen again, the order is in the guide to the monthly close. If the arrears were built up with the current provider, the handover list is in the guide to changing accountant.