Moratorium Regime for Filing Financial Statements

By means of General Resolution 4/2025, issued on January 10, 2025, the Public Registry of Commerce of the City of Buenos Aires (IGJ) has established a moratorium regime that allows several entities to comply with the filing of their financial statements. This measure aims to facilitate compliance with the accounting obligations of entities incorporated abroad and of some local entities operating in Argentina under the jurisdiction of the IGJ.
 

The entities included in the Resolution are:

• corporations,

• limited liability companies whose capital stock reaches ARS 2 billion (section 2, article 299 of the Argentine Companies Law 19550),
• entities incorporated abroad registered under article 118, third paragraph of Law 19550,
• civil associations,
• foundations

The resolution—which will come into force on February 1, 2025—enables these entities to submit accounting documentation for the last 10 annual periods ended August 31, 2024, between February 1 and December 31, 2025.

To file for the procedure, applicants must pay a single “late filing of financial statements” form, according to their type of entity. The IGJ will not impose additional penalties for the owed financial statements.

Additionally, foundations must attach other documentation to their financial statements, such as the Triennial Action Plan.

The measure includes a period of suspension of summary proceedings until December 31, 2025, if statements are not filed. This does not include those cases where there is a court order or a complaint from interested third parties. It also does not include

The Resolution excludes from the moratorium regime those entities that have already received final sanctions for failing to file the documents.

The Resolution mentions that, upon expiration of the term on December 31, 2025, the IGJ will impose the penalties in Chapter II of Law 22315 and in articles 302 and 303 of the Argentine Corporations Law 19550, depending on the relevant entity, without the need for prior notice, as provided for in article 18 of Decree 1493/1982.