Does AI replace the accountant?
A program with AI can do much of the compilation work, but Dutch law assigns some tasks to an accountant. Where the line lies and when an accountant is sensible even without an obligation.
The short answer
Not where the law prescribes an accountant. A medium-sized or large entity needs an auditor's report from a registered accountant or an AA with the required designation (art. 2:393 DCC); no software issues that. Micro and small entities have no audit requirement: there, software with AI can do most of the compilation work and you decide whether to engage an accountant.
Updated 30 October 2026
Key facts
| Audit requirement | Medium-sized and large (art. 2:393(1) DCC) |
| No audit requirement | Micro (art. 2:395a(6) DCC) and small (art. 2:396(7) DCC) |
| What only an accountant issues | Auditor's report, review report and a compilation report under Standard 4410 |
| What software with AI takes over | Classifying accounts, calculating, first versions of text and checking texts for completeness |
| Who signs | Always the board (art. 2:210(2) DCC) |
What the law reserves for the accountant
For a medium-sized or large entity, a registered accountant, or an Accountant-Administratieconsulent with the designation the law requires, must audit the annual accounts (art. 2:393(1) DCC). That accountant also checks whether the management report has been prepared in accordance with the law and is consistent with the annual accounts (art. 2:393(3) DCC), and reports the outcome in an auditor's report (art. 2:393(5) DCC). That report is unqualified, qualified, adverse, or a disclaimer of opinion (art. 2:393(6) DCC).
Without that report the general meeting cannot, in principle, adopt the annual accounts (art. 2:393(7) DCC). The law places the task with a person holding a protected title, who is subject to disciplinary rules. A program or language model can support the work, but cannot issue a report, and the board remains responsible for the true and fair view the annual accounts give (art. 2:362(1) DCC).
Micro and small: no audit requirement
For a micro entity, the section on the expert audit does not apply (art. 2:395a(6) DCC); for a small entity the audit requirement is disapplied (art. 2:396(7) DCC). The board may then prepare, adopt and file the annual accounts itself, without a report from anyone.
Even so, small businesses often have an accountant or bookkeeper compile the annual accounts. That is a service, not an obligation. An accountant does it as a compilation engagement under Standard 4410: they compile the annual accounts from your data and state what they have done, without an opinion on accuracy (see compilation report). Bookkeeping firms sometimes issue their own statement, such as the NOAB compilation report of NOAB members. It is precisely this compilation work that is largely standard, and software with AI can take over a lot of it.
What software with AI takes over from compilation work
This is how Jaarrekening.io divides the work that a compiler would otherwise do by hand:
| Task | How the app does it | What is left for you |
|---|---|---|
| Reading in the trial balance and making it balance | Fixed rules for XAF, Excel and CSV; the AI only reads a PDF | Supplying a complete, closed set of accounting records |
| Classifying accounts into the statutory line items | Via RGS codes and your earlier choices; an AI suggestion for the rest | Reviewing suggestions with low certainty |
| Balance sheet, result and size class | Fixed calculation rules | Valuing and recording the figures |
| Notes and management report | AI drafts based on the recorded figures and your answers | Adding what only you know and reading every paragraph |
| Checking completeness | The AI check: is anything missing that Title 9 requires? | Deciding per finding what you change |
| Publication version and XBRL | Fixed rules per size class | Filing, yourself or through an accountant |
What is left is the work where an accountant makes the difference: judgements on valuation, provisions and continuity, tax choices, and the conversation about what the figures mean for the business.
What an accountant keeps doing, even with AI
- Issuing reports. The auditor's report for medium-sized and large entities, and a review report (Standard 2400) when a lender wants less assurance than an audit.
- Judgements with consequences. A provision for a dispute, the write-down of a participating interest, the question of whether a loss-making BV can continue (art. 2:384(3) DCC).
- Tax advice. The corporate income tax return, a small entity's choice of tax-based accounting policies (art. 2:396(6) DCC), dividends and the distribution test (art. 2:216(2) DCC).
- Structure questions. Holding and operating company, a first consolidation, an acquisition or restructuring.
- Assurance for third parties. A bank or investor that wants to see a report from an accountant.
When you engage an accountant
| Situation | Accountant needed? |
|---|---|
| Medium-sized or large entity | Yes, by law (art. 2:393(1) DCC) |
| Micro or small BV, records in order, no group | No, preparing it yourself is allowed |
| The bank asks for a compilation report from an accountant (Standard 4410) | Yes; ask which type of report the bank accepts |
| Doubt about continuity | Advisable: accounting policies and notes depend on it |
| First annual accounts of a holding with subsidiaries | Advisable, for consolidation and exemptions |
| The articles of association or a shareholders' agreement require an accountant | Yes, according to that agreement |
If you are in doubt, use the audit requirement check or read when an accountant is mandatory.
Software and accountant together
Where an audit is required, software and accountant do not exclude each other. In Jaarrekening.io the board, controller and accountant work in one workspace with their own roles and invitations by email. A reviewer or approver places comments and suggested text changes with their name attached, approves per section, and an audit trail records recorded actions. You prepare the file that the accountant audits; for a large entity the accountant submits the XBRL file with the auditor's report using SBR software. If you work at a firm, read annual-work software for firms.
Does AI replace the bookkeeper?
A bookkeeper does different work from an accountant: bookkeeping throughout the year, preparing the VAT return, the year-end closing. Here too, software with AI takes over part of the work, for example with an AI suggestion when booking the bank and reading purchase invoices. Booking remains a deliberate human act. What the AI does in bookkeeping is described on AI and bookkeeping.
Sources
- Art. 2:393 DCC: audit requirement, report and adoption (wetten.overheid.nl)
- Art. 2:395a DCC: micro entity: no expert audit (wetten.overheid.nl)
- Art. 2:396 DCC: small entity: art. 2:393(1) does not apply (wetten.overheid.nl)
- Art. 2:210 DCC: preparation and signing for the BV (wetten.overheid.nl)
- Art. 2:384 DCC: going concern assumption (wetten.overheid.nl)
- Art. 2:362 DCC: true and fair view requirement (wetten.overheid.nl)
- NOAB Disciplinary Board, ruling TC 74-2021 (NOAB compilation report)
Frequently asked questions
Can AI issue an auditor's report?
No. Only a registered accountant (registeraccountant) or an AA with the statutory designation may issue that report (art. 2:393(1) and (5) DCC). Software can support the work, but it cannot issue the report.
Do I need an accountant as a small BV?
Not by law. A small entity has no audit requirement (art. 2:396(7) DCC), nor does a micro entity (art. 2:395a(6) DCC). The board may prepare and file the annual accounts itself.
Is a compilation report mandatory?
No, the law does not mention it. Banks and shareholders often ask for one, though. A compilation report under Standard 4410 is issued by an accountant; some bookkeeping firms issue their own statement, such as the NOAB compilation report. Ask which type the recipient accepts. Software with AI does not issue a report.
Can my accountant look along in Jaarrekening.io?
Yes. You invite them to the workspace, for example as a reviewer or approver. They see the figures and the texts, place comments and suggested text changes, and approve per section.
Does AI make the accountant cheaper?
That is up to the firm. If you supply a balanced trial balance, classified accounts and a draft file, the accountant no longer has to do that work. Ask in advance how the firm charges for it.
Read more
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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