RJ 105: IFRS or Dutch GAAP in the Dutch annual accounts

The short answer

A legal entity with securities on a regulated market must prepare its consolidated accounts under EU-IFRS. Every other legal entity may choose (art. 2:362(8) DCC), but the separate accounts follow IFRS only if the consolidated accounts do so too. RJ 105 works out the four combinations and names the Title 9 rules that also apply under IFRS.

Updated 30 October 2026

Key facts

Who must apply IFRS and who may choose

For a legal entity with shares or bonds on a regulated market, Europe decides: the consolidated accounts follow the IFRS adopted by the EU. RJ 105 calls this IFRS*, with an asterisk, to distinguish it from the IASB's own version. For all other legal entities Title 9 opens the choice.

8. A legal entity may prepare the annual accounts according to the standards adopted by the International Accounting Standards Board and approved by the European Commission, provided that the legal entity applies all adopted and approved standards applicable to it. A legal entity that prepares the consolidated accounts according to this title cannot prepare the separate accounts according to the adopted and approved standards. A legal entity that prepares the consolidated accounts according to the standards referred to in the first sentence of this paragraph may apply in the separate accounts the measurement bases it also applied in the consolidated accounts.

IFRS is therefore all or nothing, and the consolidated accounts take priority: only if they follow IFRS may the separate accounts do so too. If a legal entity prepares no consolidated accounts, the separate accounts may follow IFRS independently (RJ 105.103).

RJ 105 is not about borrowing a single standard, such as IAS 19 for pensions via RJ 271: the annual accounts then remain Title 9 (RJ 105.104). Whoever does not choose IFRS may also not depart from Title 9 by invoking IFRS (RJ 105.105). Separately, art. 2:362(1) DCC allows an international group to follow the standards of another EU member state; that falls outside RJ 105.

The four combinations of RJ 105

Combination 3 is popular with groups that already report under IFRS: one set of measurements, with separate accounts in the Dutch layout. The values come from IFRS, layout and notes from Title 9 and the Decree on annual accounts models (Besluit modellen jaarrekening). A provision therefore appears in the separate balance sheet as a separate item, even if the IFRS balance sheet puts it under the liabilities (RJ 105.315).

Even in combination 3, equity may differ, for example with an interest of less than 100%: the consolidated accounts eliminate intercompany profits in full, the separate accounts proportionally (RJ 105.306). You explain such a difference in the notes.

What remains of Title 9

9. The legal entity that prepares the annual accounts according to the standards referred to in paragraph 8 applies of this title only sections 7 to 10 inclusive and articles 362, paragraph 6, penultimate sentence, paragraph 7, last sentence and paragraph 10, 365 paragraph 2, 373, 379 paragraphs 1 and 2, 380b, point d, 382, 382a, 383, 383b to 383e inclusive, 389 paragraphs 8 and 10, and 390. Banks also apply article 421 paragraph 5. Insurers also apply article 441 paragraph 10.

In plain language: IFRS determines the figures, Title 9 regulates what surrounds them. Management report, other information, audit and filing continue to apply. So does capital protection: statutory reserves for development costs, translation differences and revaluations, and the layout of equity. In addition come disclosures that IFRS does not know, such as the KVK number, the number of employees, the accountant's fees, the remuneration of the board and supervisors and the reconciliation between separate and consolidated equity.

What is missing from paragraph 9 is section 11 with the size exemptions. Whoever applies IFRS voluntarily loses the exemptions for layout and publication (RJ 315.104). Section 11 also contains the exemption from the management report and audit for small entities (art. 2:396(7) DCC); discuss with your accountant what that means for you before you choose. And what emerges between preparation and adoption is processed by the board under IFRS by preparing the annual accounts again (RJ 105.110).

Revaluation reserve: the brake on distributions under IFRS

Because art. 2:390 DCC also applies under IFRS, the separate accounts form a revaluation reserve where IFRS measures above cost without a realised profit. This matters in the case of:

• an asset that was set at fair value as deemed cost on transition (IFRS 1); the reserve declines with depreciation or sale, directly to the other reserves (RJ 105.304 and 105.403);
• debt instruments at fair value through other comprehensive income, where the reserve may become negative; for equity interests a decline is deducted directly from the free reserves (RJ 105.313 and 105.404);
• remeasuring an existing interest in a step acquisition or loss of control, unless there are frequent market quotations (RJ 105.310 and 105.311).

A negative revaluation reserve is deducted from the freely distributable reserves, and the notes say so; RJ 105.317 makes this a firm statement.

Case: Kade Logistiek Holding BV chooses combination 2 or 3

Kade Logistiek Holding BV (fictitious) has three subsidiaries and prepares consolidated accounts under IFRS from financial year 2026, because its financier asks for it. The transition date is 1 January 2025. On that date the group sets a distribution centre with a carrying amount of € 2.400.000 at its fair value of € 3.100.000 as deemed cost. The surplus of € 700.000 gives a deferred tax liability of € 175.000. The remaining useful life is 25 years.

Suppose this is the only difference between the two systems. In combination 2 the building remains in the separate accounts at the old cost. Separate equity is then € 483.000 lower than the consolidated figure, and the notes reconcile the two. In combination 3 equity is equal, but the same amount is locked up in the revaluation reserve. Each year € 21.000 (€ 28.000 extra depreciation minus € 7.000 tax) is released directly to the other reserves. The room for dividend is therefore equally large in both cases; only the presentation differs. Whether a distribution is also prudent, the board additionally tests with the distribution test of art. 2:216 DCC.

Kade is large. Had it been small and had it also chosen IFRS for the separate accounts (combination 4), it would have lost the exemptions of section 11.

IFRS by size class

From 2025 to 2027: what changes

• Financial year 2025: chapter 105 did not yet exist. The rules on the combinations, the revaluation reserve and paragraph 9 were in other chapters, including RJ 100 and RJ 240. Substantively the same applied.
• Financial year 2026: RJ 105 brings those rules together for reporting years from 1 January 2026. The Board published the draft in RJ-Uiting 2025-4 (8 May 2025) and made it final unchanged on 2 July 2025.
• Financial year 2027: RJ 105 is unchanged. Following IFRS 18, the Board did amend other chapters, such as RJ 115 and RJ 360 (RJ-Uiting 2026-6); those apply to whoever continues to apply Dutch GAAP.

Common mistakes

• Preparing the separate accounts under IFRS while the consolidated accounts follow Title 9. Paragraph 8 rules this out.
• Recognising a deemed cost on transition without a revaluation reserve in the separate accounts.
• Filing an abridged publication version after a voluntary switch to IFRS.

How it works at Jaarrekening.io

Jaarrekening.io only prepares annual accounts under Title 9 with the RJ or the RJk; the app does not make an IFRS set of annual accounts, and with a stock exchange listing the annual accounts route stops. The notes name the system applied; a small legal entity chooses there between the RJk and the full RJ. If your group chooses combination 2, you can make the Dutch separate annual accounts in the app; you supply the reconciliation with the IFRS equity yourself.

Sources

• Art. 2:362 DCC: true and fair view, IFRS choice and disclosure of the standards (wetten.overheid.nl, in Dutch)
• Art. 2:390 DCC: revaluation reserve (in Dutch)
• RJ-Uiting 2025-4: the new chapter 105 on IFRS* alongside Title 9 (rjnet.nl, in Dutch)
• RJ-Uiting 2026-6: draft guidelines following IFRS 18 (in Dutch)
• Raad voor de Jaarverslaggeving: the Guidelines (in Dutch)

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