RJ 290 Financial instruments: what an SME needs to do

The short answer

RJ 290 governs all financial instruments, from loans to derivatives. For most SMEs it comes down to three things: loans at amortised cost, an interest rate swap or forward exchange contract through cost price hedge accounting, and the disclosure of the market value of derivatives. Trading portfolios and complex products are left out of this page; they call for tailored work.

Updated 30 October 2026

Key facts

What RJ 290 covers, and what this page leaves out

A financial instrument is a contract that gives rise to a financial asset at one party and a financial liability or equity at the other: a bank loan, a trade receivable, a share, an interest rate swap. RJ 290 recognises five kinds of financial assets: what you hold for trading, derivatives, bonds and loans bought from others, loans and receivables you granted yourself, and equity investments. On the liabilities side there are three: trading positions, derivatives and the rest (RJ 290.407 and 413). Per subcategory you choose one basis (RJ 290.502).

For trade receivables, securities, cash and liabilities the detailed rules are in RJ 222, RJ 226 and 228 and RJ 254; RJ 290 gives the framework and the disclosures (RJ 290.103). Trading portfolios, embedded derivatives in detail, the optional IFRS 9 model for credit losses (RJ 290.101) and the rules for banks and insurers are left out here.

Loans: amortised cost

Loans granted, receivables and ordinary liabilities are stated at amortised cost after initial recognition (RJ 290.519 and 523; art. 10(3) Besluit actuele waarde). Transaction costs such as an arrangement fee are part of the initial measurement and are released through the effective interest rate over the term (RJ 290.501). Straight-line spreading is permitted if the difference from the effective interest method is not material (RJ 290.523a). You test receivables for impairment at every balance sheet date (RJ 290.533 to 540 inclusive). Monetary items in foreign currency you translate at the closing rate (RJ 290.504).

Derivatives: which basis

At cost without hedge accounting, periodic settlements belong to their period, but a fair value below cost you always take as an expense (RJ 290.513 and 541). At fair value, changes in value run through the result (art. 2:384(7) DCC), with a revaluation reserve for positive values without frequent quotation (RJ 240.218). A micro entity cannot choose: market value is excluded for it.

Hedge accounting, and why SMEs use cost price hedge

Hedge accounting is a choice per type of hedging relationship (RJ 290.602): the result of the derivative and of the hedged item reach the profit and loss account in the same period. RJ 290 has four models: fair value hedge, cash flow hedge, cost price hedge and the hedge of a net investment in a foreign operation (RJ 290.618). The cash flow hedge rests on the law:

Changes in the value of financial instruments that serve and are effective as a hedge of risks relating to assets, assets on order and other obligations not yet recognised on the balance sheet, or relating to forecast transactions, are taken directly to the revaluation reserve, in credit or in debit, to the extent necessary to ensure that these changes in value are recognised in the result in the same period as the changes in value they are intended to hedge.

For an interest rate swap on a bank loan with a variable rate, cost price hedge accounting is the simplest. The loan is stated at amortised cost, so the swap is also stated at cost, usually nil (RJ 290.633). The conditions:

1. You document in advance, generally for a kind of hedge or per relationship, which risk you hedge, with which instrument and why you expect effectiveness (RJ 290.613 to 615 inclusive).
2. The hedging instrument is a derivative with a party outside the entity; a net written option does not count (RJ 290.605 to 608 inclusive).
3. At every balance sheet date you check whether there is ineffectiveness. If the critical terms match (amount, term, repricing dates, reference rate), there is none; otherwise you measure it (RJ 290.634).
4. You take ineffectiveness as an expense only to the extent that it is a cumulative loss (RJ 290.635). If the derivative hedges more than is left to hedge, the surplus follows the ordinary rules: cost or lower fair value (RJ 290.637 and 541).

From financial year 2027 the guideline expressly states that you may also designate a proportion of a derivative, such as half of the notional amount, and that you may keep the ‘costs of hedging’ outside the relationship, such as the time value of options, the forward points of forward exchange contracts and the currency basis spread (RJ 290.608a, 641 and 642; RJ-Uiting 2026-4). For an ordinary interest rate swap little changes.

Equity or liability, and compound instruments

Whether an instrument issued is equity or debt depends, in the consolidated accounts, on economic reality: as soon as you can be forced to pay cash, it is a financial liability (RJ 290.801 to 804 inclusive). In the company-only accounts you may also follow the legal form (RJ 240.503; see RJ 240). A convertible loan consists economically of a liability and a conversion option in equity: you value the liability as a comparable loan without a conversion right, the rest is equity, and you allocate transaction costs proportionally (RJ 290.813 to 819 inclusive). Whoever follows the legal form in the company-only accounts keeps the whole loan as a liability until conversion (RJ 240.506).

What you disclose

If financial instruments are not valued at current value, the entity discloses:

a. for each category of derivative financial instruments:

1°. the current value of the instruments, if it can be determined by one of the methods prescribed under article 384(4);

2°. information on the size and nature of the instruments; and

b. for financial fixed assets that are valued at an amount higher than the current value and without the second sentence of article 387(4) having been applied:

1°. the carrying amount and the current value of the individual assets or of appropriate groups of the individual assets;

2°. the reason why the carrying amount has not been reduced, as well as the nature of the evidence underlying the belief that the carrying amount will be recoverable.

If you do value financial instruments at current value, art. 2:381a DCC applies: the assumptions of the valuation model, per category the value and the changes in value, and for derivatives the nature, size and terms. Section 9 of RJ 290 elaborates the disclosures. Medium-sized entities must give the policies, the fair value, the liquidity risk and the financial fixed assets above fair value; for interest rate, cash flow and credit risk a recommendation applies (table at RJ 290.9). In the management report of medium-sized and large entities, the board describes the risk policy for financial instruments and the price, credit, liquidity and cash flow risks (art. 2:391(3) DCC).

Which version for 2025, 2026 and 2027

• Financial years 2025 and 2026: RJ 290 (amended 2024). For liquidity risk it may be necessary to explain arrangements such as factoring and reverse factoring (RJ 290.918a); a separate fair value amount is not needed if it is already apparent from the balance sheet per category (RJ 290.937; RJ-Uiting 2024-13).
• Financial year 2027: RJ 290 (amended 2026), with the possibility of designating part of a derivative and excluding the costs of hedging (RJ-Uiting 2026-4). Earlier application is recommended.
• RJk B12 has not been amended since financial year 2020. The chapter has no hedge accounting model of its own; for matters the RJk does not regulate, a small entity chooses an appropriate basis itself, and RJ 290 can give direction.

Per size class

Case: an interest rate swap on a variable-rate loan

Koelhuis Veldzicht BV (fictitious) borrows € 2.000.000 on 1 January 2025 for seven years, interest-only, at the three-month Euribor plus 1,8%. The bank requires an interest rate swap with the same notional amount, the same term and the same repricing dates: Veldzicht pays 2,6% fixed and receives the three-month Euribor. Together it thus pays 4,4% fixed, € 88.000 per year. On 31 December 2026 rates have fallen; the bank quotes a fair value of − € 45.000 for the swap.

Because the terms of swap and loan match, there is no ineffectiveness under the cost price hedge and the swap stays off the balance sheet. As a medium-sized entity, Veldzicht discloses the notional amount, the term until the end of 2031, the fair value of − € 45.000 and its hedging policy. As a small entity it need not state the market value; as a micro entity it gives no notes and fair value is not an option for it.

Follow-up in 2027. Veldzicht repays an extra € 500.000 on 1 January 2027; the swap stays at € 2.000.000. A quarter of the swap then hedges nothing. For that part the cost price hedge lapses and cost or lower fair value applies. If the fair value at the end of 2027 is − € 40.000, Veldzicht takes 25% of that, € 10.000, as an expense; the rest stays in the hedging relationship off the balance sheet.

Common mistakes

• Keeping an interest rate swap at cost without a documented hedging relationship, and then not taking the negative market value as an expense.
• Preparing the hedge documentation only afterwards.
• On an extra repayment, forgetting that part of the swap no longer counts as a hedge.
• As a medium-sized entity, not disclosing the market value of the swap because the bank has it quoted.
• As a micro entity, valuing a derivative or investment at market value.

How it works in Jaarrekening.io

In the notes questions of Jaarrekening.io, a medium-sized or large entity is asked whether there are derivatives not stated at fair value, such as an interest rate swap or forward exchange contract, with the nature and size per category, the fair value (or the reason why it cannot be determined), the policy and the carrying amount. A small entity does not get that question, because the law exempts it. Loans with an arrangement fee are calculated by the Bookkeeping module with the effective interest rate.

Sources

• Art. 2:381a and 2:381b DCC: notes on financial instruments (wetten.overheid.nl)
• Art. 2:384 DCC: changes in value and hedging
• Art. 2:391 DCC: risk policy in the management report
• Besluit actuele waarde (Current Value Decree) (art. 5a: no market value for micro; art. 10: financial instruments)
• RJ-Uiting 2024-13: liquidity risk and fair value in RJ 290 (rjnet.nl)
• RJ-Uiting 2026-4: unavoidable costs of a derivative in a hedging relationship (rjnet.nl)

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