Obviously when it comes to depriving the right not to be coerced into incriminating oneself from its very essence, mere administrative obligations like drafting accounting statements can hardly be put on a par with severe physical or psychological mistreatment by government authorities. So the underlying issue here is whether the prospect of facing an accounting penalty for lack of full disclosure of contingent tax liabilities already classifies as improper compulsion. Prima facie it seems not to be; the mere existence of a severe sanction for certain behavior – even in combination with statements by government officials concerning their intensified ‘pursuit’ of fraudulent accounting in general – is unlikely to meet the standard of improper compulsion as long as there has not been an act by either the tax authorities or by a (government-endorsed) accounting supervisor that may lead a company to conclude that a criminal charge is imminent.36 Be that as it may, if a company where to disclose a multi-million Euro tax liability of which the tax authorities are not aware before publication of the accounting reports, it is just a matter of time before proceedings will be initiated in most cases. I cannot but wonder whether such imminent disclosure of (potential) previous offences would already suffice to conclude that criminal proceedings (including tax proceeding leading up to substantial penalties) can be anticipated.37 In my view, the answer is affirmative although this still does not make a criminal charge ‘imminent’ as currently required by ECtHR case-law.