You need to hold an annual gathering (annual meeting, national meeting, general assembly) that can form the basis for a document that can be used for the reporting.

If you have a very small association with essentially no members, the meeting can possibly take the form of a regular board meeting (either physical or digital), where you go through the minimum requirements for a general assembly. This meeting must, of course, generate the minutes you need for the reporting.

According to the law adopted in the EU regarding the fight against money laundering and terrorist financing, you must meet this requirement. It may seem like a small, silly thing, since you have no ill intentions and would never dream of fraud or anything similar. But in the big picture, it makes sense, as even small businesses and associations can be used for money laundering, etc. Yes, it is even the concept of "the sum of small parts can create something big" that often creates the foundation for organized money laundering.

If you do not have a bank account, then you do not need to hold a general meeting or make your annual report, etc.