Compilation report on the annual accounts
Many Dutch annual accounts of small BVs carry a compilation report (samenstellingsverklaring). It says something about the accountant's work, not about the correctness of the figures.
The short answer
A compilation report is the statement of an accountant (AA or RA) that he has compiled the annual accounts on the basis of the board's information, in accordance with Standard 4410. It gives no assurance: the accountant does not audit the figures and gives no opinion. The law does not require it; banks and shareholders often ask for one, though.
Updated 30 October 2026
Key facts
| Standard | Standard 4410 Compilation engagements from the Nadere voorschriften controle- en overige standaarden (NV COS) of the NBA (the Dutch professional body of accountants) |
| Who | An accountant registered in the accountants' register; the title is protected (art. 41 Wet op het accountantsberoep) |
| Assurance | None. A compilation engagement is not an assurance engagement (Standard 4410, par. 6) |
| Mandatory? | No. The law only provides for the audit for medium-sized and large legal entities (art. 2:393(1) DCC) |
| Publication documents | The report may be omitted from publication documents (Standard 4410, par. 41A) |
What the report says, and what not
In a compilation engagement the accountant supports the board in preparing and presenting the annual accounts. He uses the records, documents and explanations the board supplies. The accountant is not required to verify the accuracy or completeness of that information (par. 6). The board remains responsible for the annual accounts, including the choice of policies and the estimates (par. 7).
The report is therefore not a seal of approval. According to paragraph 39 it is not a means of giving an opinion or a conclusion on the figures. The image of the independent accountant also does not quite hold here: the independence rules for assurance engagements do not apply to compilation engagements (par. A21). The ordinary conduct and professional rules do apply, such as integrity, objectivity and confidentiality.
What does it contain? Paragraph 40 mentions, among other things, a title, the addressee, the statement that the annual accounts were compiled with information from the board, the responsibilities of board and accountant, and the reporting framework applied.
No legal duty, but a professional standard
Book 2 DCC does not mention the compilation report. The law knows one mandatory involvement of an accountant: the audit of the annual accounts (art. 2:393(1) DCC). Small legal entities are exempt from it (art. 2:396(7) DCC) and for micro legal entities the section on the expert examination does not apply at all (art. 2:395a(6) DCC). They may therefore prepare the annual accounts themselves, without any report. The board signs them itself in all cases (for the BV art. 2:210(2) DCC).
If an accountant is engaged to compile annual accounts under Title 9, he must apply Standard 4410 (par. 2). The firm side of this, with the steps software can support, is at compilation engagement and NV COS 4410.
How a compilation engagement runs
- Engagement letter. Beforehand, accountant and board record in writing what the annual accounts are for, which framework applies and who is responsible for what (par. 24 and 25).
- Understanding. The accountant gets to know the activities, the bookkeeping and the reporting framework (par. 28).
- Compiling. He compiles the annual accounts with the information supplied and discusses significant judgements, such as estimates, with the board (par. 29 and 30).
- Reading. Before finishing he reads the annual accounts in light of what he knows about the business (par. 31).
- Signals. If information is incomplete, inaccurate or misleading, he asks for additions and proposes adjustments. If the board refuses, he hands back the engagement (par. 32 up to and including 35).
- Acknowledgement and file. The board acknowledges its responsibility for the final version; the accountant records the reconciliation with the bookkeeping (par. 37 and 38).
Three reports side by side
| Report | Accountant's work | Assurance |
|---|---|---|
| Compilation report | Helps prepare the annual accounts with the board's information | None; no opinion or conclusion |
| Review report | Performs a review engagement | Limited; a conclusion |
| Auditor's report | Audits whether the annual accounts give a true and fair view | Reasonable, a high level; an opinion |
The difference is worked out at compilation report or auditor's report.
Worked example: what compiling does deliver
A small BV supplies a trial balance with a profit before tax of € 70.000. The accountant does not audit, but reads the figures with knowledge of the business and asks three questions.
| What stands out | What the board supplies | Processing |
|---|---|---|
| Inventory is exactly the same as last year at € 60.000 | A count at 31 December: € 52.000 | Cost of sales € 8.000 to Inventory € 8.000 |
| One debtor of € 12.100 has been outstanding for over a year | The customer is bankrupt; there will be no payout | Bad debt expense € 10.000 and VAT receivable € 2.100 to Accounts receivable € 12.100 |
| Current account director-major shareholder € 38.000 debit, without an agreement | A loan agreement with interest and repayment | No effect on result; separate disclosure as a receivable from the shareholder |
Profit before tax falls to € 70.000 − € 8.000 − € 10.000 = € 52.000 and corporate income tax at 19% from € 13.300 to € 9.880. The accountant has audited nothing, but the annual accounts have improved. Had the board refused the corrections, he would have had to hand back the engagement.
Compilation report per size class
Whether a compilation report comes into play depends on the audit requirement. The class thresholds below apply to financial years starting on or after 1 January 2024. The class, and with it the audit requirement, follows from at least two of the three criteria on two consecutive balance sheet dates; for the first and second financial year see art. 2:398(1) DCC.
| Class | Legal requirement | Role of the compilation report |
|---|---|---|
| Micro (balance sheet total ≤ € 450.000, net turnover ≤ € 900.000, < 10 employees) | No audit | Voluntary. The report names the framework applied, so also tax-based principles if you choose them (art. 2:395a(7) DCC) |
| Small (balance sheet total ≤ € 7,5 mln, net turnover ≤ € 15 mln, < 50 employees) | No audit (art. 2:396(7) DCC) | Voluntary; usual when a bank or shareholder asks for it. Here too the framework can be tax-based (art. 2:396(6) DCC) |
| Medium-sized (balance sheet total ≤ € 25 mln, net turnover ≤ € 50 mln, < 250 employees) | Auditor's report mandatory (art. 2:393 DCC) | A compilation report does not replace the mandatory auditor's report. A separate accountant can perform a compilation engagement; par. 2A applies to the auditing accountant and his Dutch network. |
| Large (balance sheet total > € 25 mln, net turnover > € 50 mln, ≥ 250 employees) | Auditor's report mandatory | As for medium-sized |
Common misunderstandings
- ‘The accountant approved the figures.’ No: he compiled them with your information and gives no opinion.
- ‘Without a compilation report I may not file.’ The KVK does not ask for it; for publication documents it may even be left out.
- ‘Any bookkeeper can issue one.’ The standard applies to accountants; the title accountant is legally protected.
What Jaarrekening.io does and does not deliver
Jaarrekening.io does not make a compilation report; only the accountant issues that. The software delivers the file on which he can base his work: the imported trial balance, the mapping to line items, the draft annual accounts and the history of changes. Among a legal entity's documents there is a template for the engagement letter of a compilation engagement. If you want an accountant to review your own draft, read having your own annual accounts reviewed.
Sources
- NBA: Standard 4410 Compilation engagements (NV COS)
- NBA: The accountant reports, explanation of compilation, review and auditor's reports
- NBA: protection of the accountant title
- Art. 41 Wet op het accountantsberoep (wetten.overheid.nl)
- Art. 2:393 DCC: examination of the annual accounts by an accountant
- Art. 2:396 DCC: no audit requirement for small legal entities (para. 7)
- Art. 2:395a DCC: micro legal entities
Frequently asked questions
Does my small BV need a compilation report for the KVK or the bank?
Not for the KVK: you file the publication documents, and no compilation report is required for them. For the bank it depends on the credit agreement. Some lenders accept annual accounts compiled by an accountant, others ask for a review or auditor's report.
May a bookkeeper without the accountant title issue a compilation report?
Not under Standard 4410. That standard applies to accountants: AAs and RAs who are in the accountants' register. A bookkeeper or bookkeeping firm may prepare annual accounts and mention that, but may not present itself as an accountant; art. 41 of the Wet op het accountantsberoep (Dutch Accountancy Profession Act) protects that title.
Is the accountant liable if the figures turn out to be wrong afterwards?
The annual accounts remain the board's. The accountant does answer for his own work: he must follow the standard, act on signs of incorrect or incomplete information and hand back the engagement if the board does not correct. If he does not, he can be held to account for it, including through disciplinary law.
Can I have an annual account I prepared myself given a compilation report afterwards?
Not as a rubber stamp. The accountant must carry out the engagement himself: gain understanding, reconcile the figures to the bookkeeping, read the annual accounts and ask for your acknowledgement. Your own draft can be the starting point.
Is the compilation report included in the documents that become public?
Usually not. A small legal entity files only the abridged balance sheet with notes (art. 2:396(8) DCC), and the standard allows the report to be left out of publication documents.
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