A auditor's report (accountantsverklaring) (formally: the annual accounts (jaarrekening)) is the financial report that a legal entity must prepare and file annually with the KvK. For many organizations, this must be done in iXBRL format to comply with SBR or ESEF requirements. Doc2iXBRL automates this process by converting your Word or PDF documents directly into a valid iXBRL file, including the required tags for Dutch GAAP or IFRS. This ensures you remain in control of the reporting process while meeting all compliance obligations of Boek 2 BW. audit opinion (controleverklaring)) is mandatory for legal entities that are classified as medium-sized or large qualify. Micro and small are exempt from the statutory audit. The audit requirement (controleplicht) follows from Article 2:393 BW; your size regime determines whether you are subject to it. Audit-obligated legal entities file the audit opinion (controleverklaring) digitally along with the annual accounts via SBR Assurance.
Key data
For whom it is mandatory: legal entities that as medium-sized (art. 2:397 BW) or large (art. 2:398 BW) qualify.
Exempt: micro (art. 2:395a BW) and small (art. 2:396 BW), no statutory audit obligation.
Legal basis: art. 2:393 BW (obligation to appoint an accountant).
Who is authorized to audit: a registeraccountant (RA) or Accountant-Administratieconsulent (AA) with audit authority.
Filing (deponering): audit-obliged legal entities add the audit opinion (controleverklaring) digitally via SBR Assurance.
Decisive: the size regime (grootteregime), determined on the basis of the size criteria.
What is an audit opinion (accountantsverklaring)?
A audit opinion (accountantsverklaring) is the written opinion of an accountant regarding the annual accounts (jaarrekening). Within the framework of the statutory audit, this is the audit opinion (controleverklaring): the auditor provides a reasonable assurance that the annual accounts (jaarrekening) give a true and fair view, in accordance with the applied framework (Dutch GAAP or IFRS).
The audit opinion (controleverklaring) is something other than an compilation report (samenstellingsverklaring) or an review report (beoordelingsverklaring) A compilation report (samenstellingsverklaring) only confirms that the annual accounts (jaarrekening) have been prepared based on the data provided, without audit assurance. A review report (beoordelingsverklaring) provides a more limited level of assurance than an audit. Only the audit opinion (controleverklaring) complies with the statutory audit obligation of art. 2:393 BW.
⚠ “Accountantsverklaring” is used as a collective term in practice. For the filing obligation, it specifically concerns the audit opinion (controleverklaring) for a statutory audit (wettelijke controle). A compilation or review engagement (samenstellings- of beoordelingsverklaring) does not fulfill the audit obligation.
When is an audit opinion (accountantsverklaring) mandatory?
The statutory audit requirement (wettelijke controleplicht) depends on the size regime (grootteregime)two consecutive financial years meets at least two of the three criteria (balance sheet total, net turnover, average number of employees).
Size regime | Statutory audit requirement | Audit opinion for filing |
|---|---|---|
Micro (art. 2:395a BW) | No | Not required |
Small (art. 2:396 BW) | No | Not required |
Medium-sized (art. 2:397 BW) | Yes | Required, via SBR Assurance |
Large (art. 2:398 BW) | Yes | Required, via SBR Assurance |
The exact threshold amounts for balance sheet total and net turnover have been increased by approximately 25% for financial years starting on or after 1 January 2024. The current amounts per regime are listed in the article about the size criteria (groottecriteria).
⚠ Even without a statutory audit requirement, an audit opinion (accountantsverklaring) may be contractually or statutorily required, for example by a financier, subsidy provider, or the company's own articles of association. This is not a statutory filing requirement, but in practice, it may still require an opinion.
How the audit opinion (controleverklaring) is filed
An audit-mandated legal entity files the annual accounts (jaarrekening) electronically via SBRwith the audit opinion digitally added via SBR Assurance The accountant provides a certified statement (gewaarmerkte verklaring) that is linked to the SBR-depot.
For large starting from financial year 2025, electronic filing via SBR is mandatory. Large legal entities using SBR Assurance proceed via a other entry point (aanknooppunt) than medium-sized legal entities (middelgrote rechtspersonen). See the article about electronic filing via SBR or iXBRL for the phasing per regime.
Audit opinion and the group exemption (art. 2:403 BW)
At the group exemption (groepsvrijstelling) of Art. 2:403 BW the subsidiary is exempt from, among other things, the audit of its own annual accounts (jaarrekening) In place of that, it relies on the consolidated annual accounts (geconsolideerde jaarrekening) of the parent, and those consolidated annual accounts (jaarrekening) must be provided with an audit opinion (controleverklaring). The exemption shifts the audit to the consolidated level; it does not make it disappear.
Types of audit opinion in the auditor's report
The accountant can issue four types of audit opinions. The type of opinion does not change the filing obligation (deponeringsplicht): the auditor's report is included in all cases. The opinion reflects the outcome of the audit:
Unqualified opinion: the annual accounts (jaarrekening) provide a true and fair view.
Qualified opinion: true and fair view, except for a specific point.
Adverse opinion: the annual accounts (jaarrekening) do not provide a true and fair view.
Disclaimer of opinion (oordeelonthouding): the auditor cannot express an opinion, for example due to insufficient audit evidence.
Related topics
The size criteria for the annual accounts (jaarrekening) determine whether you are micro, small, medium-sized, or large, and therefore whether you are subject to an audit (controleplichtig).
File electronically via SBR or iXBRL, including SBR Assurance for medium and large.
What is SBR and how does filing via SBR work? for the background of the SBR system within which SBR Assurance also operates.
Frequently asked questions
What is an auditor's report (accountantsverklaring)? An audit opinion (accountantsverklaring) is the written judgment of an auditor regarding the annual accounts (jaarrekening). Within the framework of the statutory audit, this is the audit opinion (controleverklaring): the accountant provides a reasonable level of assurance that the annual accounts (jaarrekening) give a true and fair view. Compilation and review reports are other forms of auditor's reports, but do not satisfy the statutory audit obligation.
When is an audit opinion (accountantsverklaring) mandatory? For the annual accounts (jaarrekening), an audit opinion (controleverklaring) is legally required for legal entities classified as medium-sized or large qualify for audit (art. 2:393 BW). Micro and small are exempt from the statutory audit and do not need to file an audit opinion.
What is the difference between an audit opinion (controleverklaring) and a compilation report (samenstellingsverklaring)? A audit opinion (controleverklaring) provides a reasonable assurance that the annual accounts (jaarrekening) provide a true and fair view and comply with the statutory audit obligation. A compilation report (samenstellingsverklaring) only confirms that the annual accounts (jaarrekening) have been prepared based on the data provided, without audit assurance, and does not fulfill the audit obligation.
Does a small bv have to file an audit opinion (accountantsverklaring)? No. A legal entity in the small or micro regime is exempt from the statutory audit and does not file an audit opinion (controleverklaring). The audit obligation only arises upon qualification as medium-sized or large.
How is the auditor's report (accountantsverklaring) submitted to the KvK? Audit-obligated legal entities (controleplichtige rechtspersonen) file electronically via SBR and add the audit opinion (controleverklaring) digitally via SBR AssuranceLarge legal entities use a different entry point than medium-sized ones.
Does the group exemption (groepsvrijstelling) affect the audit opinion (controleverklaring)? Yes. With the group exemption (art. 2:403 BW), the audit of the daughter company's own annual accounts (jaarrekening) is waived, but the consolidated annual accounts (geconsolideerde jaarrekening) of the parent company must include an audit opinion (controleverklaring). The audit shifts to the consolidated level.
Doc2iXBRL for audit-required filings
An audit-obligated annual accounts (jaarrekening), medium or large, requires the correct SBR entry point and the inclusion of the audit opinion via SBR Assurance. Doc2iXBRL converts your approved annual accounts (jaarrekening) into validated iXBRL or SBR, supports the entry points, and validates against the filing rules (Arelle plus proprietary pre-filing checks), keeping the reviewer in control, without guaranteeing a KvK outcome. Would you like to see how this works for your size regime?
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Civil Code Book 2 (Burgerlijk Wetboek Boek 2), art. 2:393 (audit requirement) and art. 2:395a-2:398 (size regimes), wetten.overheid.nl: https://wetten.overheid.nl/BWBR0003045
NBA, Koninklijke Nederlandse Beroepsorganisatie van Accountants (The Royal Netherlands Institute of Chartered Accountants): https://www.nba.nl
SBR Nederland, SBR Assurance: https://www.sbr-nl.nl
