Ministerial Decision 46982/18.6.2025 sets out in detail the criteria for imposing fines and the respective amounts applicable as of early 2026 by the General Commercial Registry (G.E.MI.) on businesses and legal entities that fail to comply with commercial publicity rules.
1. Scope of Application
The decision applies to all entities and legal forms required to register and maintain records with G.E.MI., including:
- Sociétés Anonymes (S.A.)
- Limited Liability Companies (E.P.E.)
- Private Capital Companies (I.K.E.)
- Partnerships (general and limited)
- Branches of foreign companies, etc.
2. Types of Violations & Fines
The main categories of violations subject to fines are:
- Failure to register with G.E.MI. within the statutory deadlines.
- Delayed submission or failure to submit mandatory documentation (e.g. articles of association, general meeting minutes, balance sheets).
- Failure to register acts or information required by law (e.g. change of registered office, amendments to articles of association).
- Submission of inaccurate or false information to the registry.
- Failure to publish financial statements in accordance with accounting standards. This violation does not include the initial and final liquidation balance sheets, nor interim financial statements.
It is noted that fines for failure to publish financial statements are particularly high and vary depending on the legal form and category/size of the entity.
The below table is summarizing the types of violations and corresponding fines:
3. Procedure for Imposition and Appeal
Violations may be identified ex officio by the competent authorities (through G.E.MI. automated systems or inspections), following notification by another public authority, through random audits, or even upon a complaint submitted by an individual or legal entity.
Obliged entities will receive an electronic fine notification via their G.E.MI. electronic mailbox and by email. Within 15 days of receiving the notification, they may submit their views electronically, using the application available through the G.E.MI. fine management system, and provide documented reasons why the fine should not be imposed.
After this deadline, or if the justification provided is not accepted by the competent G.E.MI. authority, the act imposing the fine will be officially communicated to the entity.
4. Fine Reductions
The fine amount is reduced by 50% if, within 30 days of notification of the fine, the entity pays the fine and simultaneously proceeds with the registration/amendment/deletion of the act for which the fine was imposed.
A 50% reduction also applies to companies under liquidation or special liquidation.
5. Repeat Offenses
In case of a repeat violation of the same type within three years, the fine is doubled whereas in case of multiple repeated violations, the fine is tripled.
6. Adaptation period
An adaptation period is provided until December 31, 2025, for liable entities to proceed with corrective actions without triggering any administrative penalties. More specifically, the liable entities may:
- register with the General Commercial Registry (GEMI), if they are required to do so and have not done yet,
- proceed with any pending submissions, the omission of which results in the imposition of a fine,
- proceed with any submissions, for which they have been set under suspension
- request from G.E.M.I. to correct errors made through their own fault.
- respond to invitations they receive either through automated messages or from G.E.M.I.
