Notes to the annual accounts: what must be in them and what becomes public
The notes make the figures readable: they say how items were valued, what lies behind a line item and which obligations are not on the balance sheet. The scope differs greatly per size class.
The short answer
The notes are the third part of the annual accounts. They set out the policies for valuation and determination of result, explain items of the balance sheet and profit and loss account and disclose what is not apparent from the figures, such as rental obligations and security. A micro BV discloses almost nothing, a small BV a limited set and a large BV everything.
Updated 30 October 2026
Key facts
| Legal basis | art. 2:361(1) DCC (part of the annual accounts), art. 2:378 up to and including 2:383e DCC (special provisions), art. 2:384(5) DCC (policies) |
| Order | The notes follow the order of the items (art. 2:363(1) DCC) |
| Supplementing | If a true and fair view requires more than the law prescribes, you add that (art. 2:362(4) DCC) |
| Public | Micro: no notes. Small: notes without events after the balance sheet date. Medium-sized and large: notes |
Place and function of the notes
The annual accounts consist of the balance sheet and the profit and loss account with the notes (art. 2:361(1) DCC). The notes are therefore not an appendix, but part of the document that the board prepares and the general meeting adopts. They do three things: they explain how items were valued, they break down and explain items, and they provide information that fits no single item.
The law lists what must be in them at least, but a true and fair view is the yardstick. If more is needed to enable a sound judgement, the legal entity provides additional information (art. 2:362(4) DCC). Conversely, disclosures of negligible importance may be omitted, except those on equity, the number of employees and the remuneration of directors (art. 2:363(3) DCC).
The notes are something different from the management report. That report describes the course of business and the expectations and does not form part of the annual accounts.
What a small BV discloses
Most BVs are small. For them art. 2:396(3) and (5) DCC limits the notes. These are the items almost every small BV has; what else is needed depends on the situation.
| Item | What you disclose | Basis | Public |
|---|---|---|---|
| General information | Name, legal form, registered office and KVK number | art. 2:380b DCC | Yes |
| Standards applied | Title 9 Book 2 DCC and the RJk, or the RJ bundle | art. 2:362(10) DCC | Yes |
| Policies | Valuation of assets and liabilities and determination of result, per item | art. 2:384(5) DCC | Yes |
| Equity | The separate items, and the movement of a revaluation reserve | art. 2:373 DCC, art. 2:396(5) DCC | Yes |
| Term of receivables and liabilities | Total amount with a remaining term of more than one year; for liabilities also more than five years | art. 2:370(2) DCC, art. 2:375(2) DCC | Yes |
| Security and guarantees | Liabilities for which security has been given; liability for debts of others | art. 2:375(3) DCC, art. 2:376 DCC | Yes |
| Off-balance-sheet obligations | Important multi-year obligations, such as rent and leases, and contingent liabilities such as a fiscal unity (RJk B10.201, B10.205) | art. 2:381(1) DCC | Yes |
| Retained result | Which part of the result is retained | art. 2:396(3) DCC | Yes |
| If it applies | Serious doubt about continuity, a change of accounting policy with adjusted comparative figures, tax-based principles | art. 2:384(3) and (6) DCC, art. 2:363(5) DCC, art. 2:396(6) DCC | Yes |
| Employees | The average number of employees in the financial year | art. 2:382 DCC | Yes |
| Directors | Loans, advances and guarantees to directors and supervisory directors | art. 2:383(2) DCC | Yes |
| Events after the balance sheet date | Events with important financial consequences that are not reflected in the figures | art. 2:380a DCC | No (art. 2:396(8) DCC) |
Not mandatory for small entities are, among others, the list of participating interests, the breakdown of turnover, transactions with related parties, the auditor's fee and the remuneration of directors (art. 2:396(5) DCC). Which policies you describe is explained at valuation policies.
Worked example: four disclosures with amounts
A small BV has a bank loan of € 120.000 on 31 December 2025. It repays € 20.000 per year; the last instalment falls due in 2031. The loan and amounts are fictitious.
- Term. In 2026 € 20.000 is repaid. A remaining term of more than one year applies to € 100.000. After five years, so after 31 December 2030, € 20.000 is still outstanding: that is the amount with a term of more than five years.
- Security. A pledge has been created on the equipment and the receivables for the loan.
- Rent. The lease runs until and including 31 December 2028 at € 36.000 per year. The off-balance-sheet obligation is 3 × € 36.000 = € 108.000, of which € 36.000 falls due within a year.
- Director. The BV has lent the director € 20.000 at 4% interest. In 2025 € 5.000 was repaid; on the balance sheet date € 15.000 is outstanding.
None of these four facts can be derived from the balance sheet.
Scope per size class
| Item | Micro | Small | Medium-sized | Large |
|---|---|---|---|---|
| Requirements: two of the three, on two consecutive balance sheet dates (financial years from 1-1-2024) | assets ≤ € 450.000, net turnover ≤ € 900.000, < 10 employees | assets ≤ € 7,5 mln, net turnover ≤ € 15 mln, < 50 employees | assets ≤ € 25 mln, net turnover ≤ € 50 mln, < 250 employees | At least two of the limits for medium-sized exceeded |
| Scope | No notes under section 5; a few disclosures at the foot of the balance sheet (art. 2:395a(3), (4) and (6) DCC) | Limited (art. 2:396(3) and (5) DCC) | Full, without segmentation of turnover and auditor's fee (art. 2:397(4) DCC) | Full |
| Setting out policies | Not mandatory; but the statement that tax-based principles were applied, if so (art. 2:395a(7) DCC) | Yes | Yes | Yes |
| Remuneration of directors | No | No | Yes (art. 2:383(1) DCC) | Yes |
| Making public | Not applicable | Yes, without events after the balance sheet date | Yes, limitation under art. 2:397(5) DCC is allowed | Yes, in full |
For the micro legal entity too, the true-and-fair-view requirement continues to apply. The Raad voor de Jaarverslaggeving (Dutch Accounting Standards Board) gives as an example serious uncertainty about continuity: additional information is then needed, even though art. 2:395a DCC does not prescribe it.
Common mistakes
- Copying standard policies. A paragraph on inventories or participating interests that the BV does not have makes the notes unreliable.
- Forgetting rent and leases. Multi-year contracts are not on the balance sheet and therefore belong in the notes.
- Leaving out the loan to the director. That disclosure also applies to the small BV; see current account director-major shareholder.
- Amounts that do not reconcile. A breakdown adds up to the amount in the balance sheet.
- Concealing a changed policy. You set out the reason and the effect on equity and result (art. 2:384(6) DCC).
- Not mentioning doubt about continuity. If continuation is uncertain, that belongs in the notes, with the effect on equity and result (art. 2:384(3) DCC).
The notes in Jaarrekening.io
The AI of Jaarrekening.io writes a draft per item that you can edit fully; which items appear follows from legal form and size class. The amounts in the draft come from the recorded balance sheet and profit and loss account; if you change a figure afterwards, you update the text. Facts that are not in the bookkeeping, such as a lease, a surety or an event after the balance sheet date, you supply yourself, and the assessment of them remains with the board.
Sources
- Art. 2:361 DCC: the notes as part of the annual accounts (wetten.overheid.nl)
- Art. 2:362 DCC: additional information when a true and fair view requires it (wetten.overheid.nl)
- Art. 2:363 DCC: order and disclosures of negligible importance (wetten.overheid.nl)
- Art. 2:375 DCC: terms of liabilities and security (wetten.overheid.nl)
- Art. 2:380a DCC: events after the balance sheet date (wetten.overheid.nl)
- Art. 2:381 DCC: obligations not included in the balance sheet (wetten.overheid.nl)
- Art. 2:383 DCC: remuneration of and loans to directors (wetten.overheid.nl)
- Art. 2:384 DCC: policies, continuity and change of accounting policy (wetten.overheid.nl)
- Art. 2:395a DCC: micro legal entity (wetten.overheid.nl)
- Art. 2:396 DCC: small legal entity: limited notes and publication (wetten.overheid.nl)
- RJ-Uiting 2016-4: Guideline for Micro Legal Entities (rjnet.nl)
Frequently asked questions
Does a small BV make the whole notes public?
Almost. The filed documents consist of the abridged balance sheet and the notes, but events after the balance sheet date are left out of the public version (art. 2:396(8) DCC). Internally, for the general meeting, they are included.
Does a micro BV really not have to explain anything?
The law switches off the notes requirements for micro entities (art. 2:395a(6) DCC). It does state at the foot of the balance sheet if no accruals are included (para. 3) and reports it if it applies tax-based principles (para. 7). If a true and fair view requires more, it adds that (art. 2:362(4) DCC).
Does the director-major shareholder's salary have to be in the notes?
Not for a micro or small BV. Medium-sized and large legal entities disclose the remuneration of the directors together, but may omit a figure that can be traced to one natural person (art. 2:383(1) DCC).
What are events after the balance sheet date?
Events between the balance sheet date and preparation that have important financial consequences and are not reflected in the figures, such as the loss of a major customer or a fire. You disclose them with the size of the consequences (art. 2:380a DCC).
May I copy last year's notes?
The structure yes, the content not without checking. Amounts, terms and contracts change every year. If a policy changes, you explain the reason and the effect (art. 2:384(6) DCC).
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