Size class · large

Dutch annual accounts of a large entity

Q: Must a large BV file in iXBRL, or is XBRL allowed too?

Both formats are allowed. XBRL works with a fixed framework from the taxonomy. According to the frequently asked questions of the SBR Business Register domain, iXBRL is prescribed if the annual accounts are prepared under IFRS, if under Dutch GAAP they have their own notes or a deviating layout, or if no suitable entry point exists.

Q: Can a large subsidiary avoid filing its own annual accounts?

Yes, with the group exemption of art. 2:403 DCC. The parent company accepts joint and several liability for the debts arising from legal acts of the subsidiary, the shareholders consent every year, and the figures are included in consolidated accounts that are filed with the Business Register.

Q: Must the accountant audit the digital version of the annual accounts?

No. According to the SBR FAQ of 24 September 2026, current legislation does not require an opinion from the accountant on the tagging of the data in iXBRL. His written consent is needed, however, to include the auditor's report in the digital file.

Q: May a large entity apply IFRS instead of Title 9?

Yes. Art. 2:362(8) DCC allows the annual accounts to be prepared under the IFRS standards endorsed by the European Commission, provided all applicable standards are applied. Of Title 9, the rules on the management report, other information, audit and disclosure, among others, then continue to apply (paragraph 9).

No more exemptions: full balance sheet, profit and loss account and notes, management report, audit by an accountant and, since financial year 2025, mandatory digital filing.

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The short answer

An entity is large if, on two consecutive balance sheet dates, it does not meet two of the three requirements for medium-sized: balance sheet total of at most € 25 mln, net turnover of at most € 50 mln, fewer than 250 employees. Title 9 then applies without exemptions: full annual accounts, management report, audit by an accountant and full disclosure. From financial year 2025, filing via SBR is mandatory.

Updated 30 October 2026

Key facts

Legal basis	Title 9 Book 2 DCC without the exemptions of section 11; the limit follows from art. 2:397(1) DCC
Large if	two of three exceeded: balance sheet total € 25 mln, net turnover € 50 mln, 250 or more employees
Always the full regime	public-interest entities (art. 2:398(7) DCC)
SBR requirement	financial years from 1 January 2025, in XBRL or iXBRL
Number in the Netherlands	about 11.100 large entities in the KVK (Dutch Chamber of Commerce) return for 2022; an estimated 1.600 of them became medium-sized (explanatory memorandum, Stb. 2024, 52)

When is an entity large?

Dutch law does not define 'large' itself. An entity is large if it falls outside art. 2:397(1) DCC: on two consecutive balance sheet dates, it meets at most one of the three requirements.

Requirement for medium-sized	From financial year 2024	Up to and including 2023	Large at
Value of the assets	≤ € 25 mln	€ 20 mln	a higher balance sheet total
Net turnover	≤ € 50 mln	€ 40 mln	a higher turnover
Average number of employees	< 250	< 250	250 or more

Mind the count: exceeding two limits is enough. A trading house with 40 employees, € 60 mln turnover and € 30 mln balance sheet total is large.

Large because of the group or by nature

Group count. A holding adds the assets, turnover and employees of the group companies it would have to consolidate (art. 2:397(2) DCC). That is how a holding company with three employees of its own becomes large.
Intermediate holding. If it does not consolidate because its data are included in the consolidated accounts of a larger whole (art. 2:408 DCC), it tests its own figures.
Public-interest entities. Listed companies, banks and insurers never apply the exemptions, regardless of their size (art. 2:398(7) DCC).
Subsidiary with a 403 declaration. A group company that applies art. 2:403 DCC does not have to organise its annual accounts under Title 9 and does not have to file them; see 403 declaration.

In a group, enter the group figures in the size class calculator; the definitions are at the size criteria.

What do you prepare?

Component	Content	Basis
Balance sheet and profit and loss account	all items of sections 3 and 4, without combining	art. 2:364 DCC up to and including art. 2:377 DCC
Notes	in full, with turnover segmentation, auditors' fees, related parties and remuneration	art. 2:378 DCC up to and including art. 2:383e DCC
Cash flow statement	according to the Dutch Accounting Standards (RJ 360)	RJ standards
Consolidated accounts	for the head of a group or part of a group	art. 2:406 DCC
Management report	balanced analysis of position, development and results, the principal risks and uncertainties and the expected course of business; where needed with non-financial performance indicators	art. 2:391 DCC
Other information	auditor's report, statutory profit appropriation, special control rights, non-voting shares and branches	art. 2:392 DCC

Instead of the rules of Title 9, an entity may apply the IFRS standards endorsed by the European Commission, provided in full (art. 2:362(8) DCC).

What do you make public?

Everything. The annual accounts are filed in full (art. 2:394(1) DCC), together with the management report and the other information (paragraph 4). For the large business class the KVK lists:

management report;
extended balance sheet, extended profit and loss account and extended notes;
auditor's report;
special rights regarding control, number of profit certificates and branches with their names and countries of establishment;
statutory provision and proposal for the appropriation of profit or treatment of the loss.

The management report and other information may also be available for inspection at the office, provided notice of this has been given to the Business Register; the auditor's report is always filed (art. 2:394(4) DCC).

The notes without exemptions

Disclosure	Article	Falls away for medium-sized?
Net turnover by line of business and by geographical area	art. 2:380 DCC	yes
Fees of the external auditor, in four categories	art. 2:382a DCC	yes
Nature, business purpose and financial effects of arrangements not included in the balance sheet	art. 2:381(2) DCC	partly
Transactions with related parties outside normal market conditions	art. 2:381(3) DCC	largely
Aggregate remuneration of directors and of supervisory directors	art. 2:383 DCC	no
Events after the balance sheet date	art. 2:380a DCC	no
Participating interests with equity and result	art. 2:379 DCC	no

For certain NVs, the individual remuneration disclosures of art. 2:383c DCC up to and including art. 2:383e DCC are added; the delimitation is in art. 2:383b DCC.

Audit by an accountant

The audit requirement of art. 2:393(1) DCC applies in full. The engagement goes to a registered accountant (registeraccountant), an accountant-administratieconsulent with the required authorisation, or an accountancy organisation in which such accountants work together.

Principal. The general meeting, otherwise the supervisory board, otherwise the board (paragraph 2). Withdrawal is only possible for well-founded reasons; a difference of opinion about reporting or audit procedures is not one.
Report. The accountant reports to the supervisory board and the board, at least on the reliability and continuity of the automated data processing (paragraph 4).
Report of the auditor. It contains, among other things, an opinion on the view given, on the consistency of the management report with the annual accounts and a statement on material uncertainties concerning continuity (paragraph 5).
Public interest. The intended accountant is notified to the AFM (Dutch Authority for the Financial Markets) in advance (paragraph 1).

Filing: via SBR since financial year 2025

Up to and including financial year 2024, large entities were exempt from the SBR requirement. For financial years beginning on or after 1 January 2025, it applies to them too (art. 2(3) Besluit elektronische deponering handelsregister, the Dutch decree on electronic filing with the Business Register, amended on 18 December 2024).

Format	Characteristic	Route according to the KVK (7 January 2026)
XBRL (SBR Instance)	fixed framework with a predefined entry point from the taxonomy	SBR software; not yet via the Zelf Deponeren portal
iXBRL (XHTML, SBR Report Package)	own layout, readable by humans and machines; according to SBR the format for IFRS and for own items or a deviating presentation	Zelf Deponeren portal or SBR software

The auditor's report goes along in the same format. Filing by post or email no longer applies. The periods are those of every BV or NV: prepare within five months, file within eight days after adoption and no later than twelve months after the financial year (art. 2:394(1) and (3) DCC). A listed company in principle prepares within four months, without extension (art. 2:101(1) DCC).

Check the dates with the filing deadline calculator. The taxonomy version per year is at annual accounts 2025.

Worked example: large through the group, and back again

A fictitious holding BV holds all the shares in three operating companies and does not apply art. 2:408.

At 31-12-2025	Holding stand-alone	Group (to be consolidated)
Balance sheet total	€ 9 mln	€ 31 mln
Net turnover	€ 0,4 mln	€ 64 mln
Employees	3	280

For the test the group figures count: all three limits are exceeded. If that was also so on 31 December 2024, the holding is large for 2025, also for its stand-alone annual accounts. If the group sells an operating company in 2026 and 2026 and 2027 end at € 24 mln balance sheet total, € 49 mln turnover and 255 employees, it again meets two requirements on two balance sheet dates. For 2027 it is then medium-sized; 2026 is the transition year in which the full regime still applies.

Large compared with medium-sized

Subject	Medium-sized	Large
Profit and loss account	gross operating result as one item	turnover and costs separately
Notes	without segmentation and auditors' fees	in full
Management report	without non-financial performance indicators	in full
Other information in the Business Register	without control rights and non-voting shares	in full
SBR requirement from financial year	2017	2025

The simplifications themselves are worked out under the medium-sized entity.

Common mistakes

Thinking all three limits must be exceeded. Two is enough.
Forgetting the group: a small holding above a large group is itself large.
Still wanting to email financial year 2025 as a pdf.
Forgetting the accountant's written consent for including his report in the digital file (SBR FAQ, question 2.6.4).

Large in Jaarrekening.io

For a large entity, Jaarrekening.io is a preparation and file tool, not audit or filing software. You import the trial balance or the XAF audit file, work out the annual accounts and management report and record approval and changes per section for your accountant. The app then produces the full stand-alone annual accounts as an XBRL file in the KVK large model, as a validation candidate. Your accountant submits it with SBR software, with the auditor's report in the same format. The app does not deliver an iXBRL file or consolidated accounts in XBRL, and it prepares only under Title 9 Book 2 DCC, not under IFRS. The price is € 5.000 excl. VAT per set of annual accounts per financial year; the first annual accounts in your account are free.

Sources

Legal notice: this information is general in nature and does not replace tax or legal advice or an audit by an accountant. The substantive correctness and completeness of the annual accounts remain the responsibility of the board.

Frequently asked questions

Must a large BV file in iXBRL, or is XBRL allowed too?