Preparing publication documents for your clients
Publication documents are the filing version of the adopted annual accounts. What they must contain depends on the size class. From one file you produce both versions.
The short answer
Publication documents are the documents that an entity files with the Business Register of the KVK. They follow from the adopted annual accounts, but micro, small and medium-sized entities may apply publication exemptions (art. 2:395a, 2:396 and 2:397 DCC). The date of adoption must appear on the filed annual accounts (art. 2:394(1) DCC).
Internal annual accounts (inrichtingsjaarrekening) and publication documents
The internal annual accounts (inrichtingsjaarrekening) are the annual accounts that the board prepares and the competent body adopts; for a BV or NV that is the general meeting. They contain what the client and its shareholders or members need, including the profit and loss account. The publication documents are derived from them: only what the law wants to be public.
For a large entity there is no difference. For the other classes there is, and that difference is larger than many clients think. A small BV, for example, does not have to file a profit and loss account.
Professional literature notes that in practice the publication documents of small companies are often more extensive than art. 2:396(8) DCC requires (G.P. den Hollander, Accountant.nl, November 2025). Check for each note line whether the law requires it for the client's class.
What each size class files
| Class | What you file | What does not have to be public | Basis |
|---|---|---|---|
| Micro | An abridged balance sheet with the notes information at the bottom of the balance sheet | Profit and loss account, further notes and management report | art. 2:395a(3), (4) and (8) DCC |
| Small | An abridged balance sheet with abridged notes | Profit and loss account and management report; other information lapses | art. 2:396(3), (7) and (8) DCC |
| Medium-sized | Balance sheet with less detail, an abridged profit and loss account, notes, management report, other information and the auditor's report | Some other information (art. 2:392(1)(d) and (e)) | art. 2:397(5) through (8) DCC |
| Large | The full annual accounts, the management report, the other information and the auditor's report | No publication exemptions based on size | art. 2:394 DCC |
The exemptions only apply if the general meeting has not decided otherwise no later than six months after the start of the financial year (art. 2:398(2) DCC). In the first and second financial year, the class on the balance sheet date of the first financial year counts (art. 2:398(1) DCC).
art. 2:394 DCCart. 2:395a DCCart. 2:396 DCCart. 2:397 DCCart. 2:398 DCC
Procedure for the firm
- Determine the size class per client over two consecutive balance sheet dates. A one-off outlier does not change the class.
- Draw up the internal annual accounts. The board prepares and signs them; the competent body adopts them (for a BV or NV the general meeting, for a foundation the body designated in the articles, art. 2:300(3) DCC).
- Derive the publication version from the same figures, without retyping. Every retyped amount is a chance of a difference from the adopted version.
- State the date of adoption.
- File within eight days after adoption and no later than twelve months after the end of the financial year (art. 2:394(1) and (3) DCC).
- If the annual accounts have not been adopted within two months after the preparation deadline, file the prepared annual accounts without delay stating that they have not yet been adopted (art. 2:394(2) DCC).
Micro and small entities may apply the tax principles, provided all applicable tax principles are followed and this is stated in the notes (art. 2:395a(7) and art. 2:396(6) DCC). For many small clients that saves a separate commercial valuation.
How Jaarrekening.io produces the publication version
From the same figures, the platform compiles a publication version limited to what the size class must make public. You record per financial year whether the annual accounts have been adopted and on which date. If that date is after the latest filing date, the platform reports it.
The printable publication preview is expressly a draft: not a standalone filing file. The platform can produce an XBRL file for every size class, as a validation candidate, for financial years starting in 2023 through 2026. For a large entity that file contains the full single-entity annual accounts; you submit it with your own SBR software, with the auditor's report. See filing for clients.
A standalone calculation aid for business owners is the publication documents generator; the statutory layout is shown in the publication documents template.
Frequently asked questions
Does a small BV have to file the profit and loss account?
No. A small entity files an abridged balance sheet with abridged notes (art. 2:396(8) DCC). The profit and loss account and the management report do not have to be public.
Must the adoption date appear on the publication documents?
Yes. Art. 2:394(1) DCC provides that the date of adoption must be stated. If adoption is missing, the route of paragraph 2 applies: file the prepared annual accounts stating that they have not yet been adopted.
May a client publish more than required?
Yes, that is allowed. But it is rarely in the client's interest: competitors and suppliers can request the documents from the KVK. Check for each item what the law requires for the class.
What if the client changes size class halfway?
A class change only takes effect after two consecutive balance sheet dates above or below the limits. Record the figures of both years in the file so that you can substantiate the class.
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Preparing Dutch annual accounts?
Your first set of annual accounts is free, for every size class. Create an account and prepare the annual accounts of your Dutch company under Title 9 of Book 2 of the Dutch Civil Code.
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