What the HE32 is, and what it is not
The HE32 is the annual return of a Cyprus company to the registrar of companies. What is reported is the state of the company:
- shareholders and their shares
- directors and company secretary
- registered office
- division of the share capital
It is filed together with the annual accounts. The official fee is €20.
Default: €150, not €500
Here older overviews quote one figure that is more frightening than reality, and another that sounds too harmless.
| Amount | |
|---|---|
| First day | €50 |
| Each further day | €1 |
| Cap per return | €150 |
The €150 cap applies to returns from 2021 onwards. Anyone reading a source that speaks of €500 is reading an out-of-date or incorrect position.
That sounds like very little, and for a single return it is. The real sanction is a different one.
The real sanction is being struck off
Under Article 327 of the Companies Law Cap. 113 the registrar can strike a company that does not meet its filing obligations off the register.
That is not a threat for effect but current practice. A struck-off company no longer exists in law: its assets pass to the state, accounts can no longer be operated, contracts stand without a counterparty. Restoration is possible but is a separate procedure with its own costs.
According to an announcement by the registrar, companies in default have until 31 December 2026 to file outstanding returns and accounts. The late filing fees do not fall away as a result; only the striking off is held back until then.
Why the HE32 usually fails on the accounts
The form itself is filled in in twenty minutes. It consists of details that mostly have not changed since the previous year.
What is missing is the annual accounts, which have to be filed with it. And those in turn hang on the whole year’s bookkeeping.
Under Article 152A of the Companies Law every Cyprus company must have its accounts audited, regardless of size and activity. Small companies may have a review instead of an audit if net turnover and total assets do not exceed €300,000 and €500,000, in at least two consecutive financial years. The details are in the guide to annual accounts.
So the chain is: no bookkeeping, no accounts, no HE32, eventually a striking off. It breaks at the first link, not the last.
What we could not substantiate
- Exactly what the 28 days hang on. The sources contradict each other: sometimes 28 days from the return’s reference date, sometimes from the annual general meeting. Both circulate side by side, and we do not present either reading as fact. You should check your own reference date with the registrar.
- The level of the late filing fee in one source. One of the pages we checked describes a different scale with €2 a day from the seventh month and a cap of €500. The majority of sources quote €150. We follow the majority but record the conflict.
- Whether the extension to the end of 2026 applies generally. We found it in one source and could not confirm it in an official notice from the registrar.
If one of these questions is decisive for you, it belongs with somebody who puts their name to it: Cyprus setup from one place.
Bookkeeping: where the chain starts
The HE32 is the last link. Without running books no accounts arise, and without accounts no filing.
In Volk Accountant the books arise from the invoices and receipts that occur anyway, and the reports supply the figures the accounts are built from. Your auditor or accountant sees the same position through the accountant portal, without anybody sending them files.
Which other deadlines fall in the Cyprus year is in the overview of tax deadlines. The second filing that hangs on no payment and therefore slips through just as often is the UBO register.