The HE32 annual return: what it is, when it's due, and what happens if you're late

Every Cyprus company files an HE32 annual return every year — and almost every non-resident owner confuses it with a tax return at least once. It isn’t one. The HE32 goes to the Registrar of Companies, not the Tax Department, and it’s a corporate snapshot: who owns the company, who runs it, where it’s registered — with last year’s financial statements stapled to it.

It’s also, quietly, the filing that keeps your company alive. Persistent failure to file annual returns is the classic route to being struck off the register. Here’s how the HE32 works in 2026: the dates, the attachment rule that causes most of the delays, the penalties (smaller than they used to be), and what happens at the extreme end of neglect.

What’s actually in it

The HE32 records the company’s position as at its “date of drafting” (the made-up date): registered office address, directors and secretary, shareholders and their holdings, and share capital. If nothing changed during the year, it’s a confirmation exercise. If things did change, the underlying notifications (HE4 for officers, HE2 for the registered office, transfer and allotment filings) should already have been made within their own short windows — 14 days for officer, office and transfer filings, one month for allotments. The HE32 is the annual reconciliation, not the place changes get reported first.

The two dates that define it

The made-up date. Your first annual return is made up to the day after the company turns 18 months old. Every later return is made up to one year after the previous return’s made-up date — so the date is fixed by your filing history, not by the calendar year or your AGM (older guides still cite an AGM-based rule; the drafting-date mechanism is what operates today).

The filing deadline. The completed return must reach the Registrar within 28 days of the made-up date, filed electronically through the Registrar’s e-Filing system. The filing fee is €20 (plus another €20 surcharge if it goes in overdue).

The attachment rule — where returns actually get stuck

An HE32 must be accompanied by the company’s financial statements for the previous financial year: the return drafted in 2026 carries the 2025 accounts, audited — or reviewed, if the company qualifies for the small-company review option. In practice this is the real bottleneck: the form itself takes minutes, but if last year’s audit isn’t signed, the return can’t be completed. When your provider seems slow with “a simple form,” what’s usually late is the audit behind it — which is usually waiting on bookkeeping, which is usually waiting on you.

What lateness costs in 2026

The €150 cap is worth a paragraph of history, because older articles still quote scarier numbers. The 2019 regime escalated to a €500 cap per return; after years of complaints (and a temporary reduction), a 2024 amendment made the €150 cap permanent. So the direct financial sting of a late HE32 is now modest — the real risk was never the fine.

The real risk: strike-off

The Registrar can strike a company off the register when there’s reason to believe it isn’t operating — and unfiled annual returns are exactly that signal. The process runs warning letter → second letter → notice in the Official Gazette → three-month objection window → dissolution. From there, consequences get serious fast: the company ceases to exist, its assets (including bank balances) vest in the Republic, and the liabilities of directors and members continue as if it had never been dissolved. Restoration is possible — administratively within 24 months, by court order for up to 20 years — but it’s slow, and expensive, and entirely avoidable.

For a founder abroad, the uncomfortable part is that all of this can progress by post to a registered office you never visit. If your provider is the only party who’d see the warning letters, your only defence is that they’re paying attention.

One thing that’s gone: the €350 levy

Until 2023, companies also owed the Registrar an annual levy of €350. It was abolished from 2024 onwards — nothing replaced it. Unpaid levies for 2011–2023 remain collectible, so very old arrears can still surface, but if a 2026 invoice line says “annual government levy €350,” ask what it refers to.