Extension moves the reference date

Every corporate compliance calendar has a colour for "late". The question is whether it turns red on the right day. In most of the calendars we have seen, it does not, and the reason is a single missing concept: the extension.

An annual account that was due on 31 May, for which an extension to 30 November has been granted, is not late on 1 June. It is not late on 1 October either. It is late on 1 December, and not a day before. A calendar that keeps the original due date and shows an extension as a note in the margin will show that entity as red for six months. After the third false alarm, nobody looks at the colour any more, and the entity that is genuinely late gets the same shrug as the five that are not.

Three states, not two

The second missing concept is the difference between filed and filed on time. A filing made after the reference date has been made. The obligation is met. But it was not on time, and your auditor, your regulator and your client know that. A dashboard that counts both as "done" is hiding the number that matters.

What this means for a portfolio

With fifteen entities in three jurisdictions you have somewhere between thirty and sixty filings a year. Most of them are routine. The whole value of a compliance overview is that it lets you ignore the routine and look at the two that are not. That only works if the colours are honest.

• Overdue means the reference date has passed. Nothing else is red.
• Within thirty days is amber, so that you see it coming.
• Filed drops to the bottom, but keeps its on-time or late label forever.
• The percentage on the dashboard is "filed on time", not "filed".

Set up this way, a list of sixty filings reads in ten seconds. Set up the other way, it reads as sixty problems, of which none are. The auditor will not thank you for the second one.