RJ 300 and 390: what belongs in the notes, per size class
The notes are where things often go wrong: a small BV writes pages nobody asks for, a medium-sized one forgets disclosures the law does require. RJ 300 gives the structure, RJ 390 three additional topics, and the law determines per size class what is mandatory.
The short answer
The notes are a mandatory part of the annual accounts (art. 2:361(1) DCC): policies, breakdowns of items and information that does not fit on the balance sheet. RJ 300 governs the structure; RJ 390 concessions, off-balance-sheet arrangements and audit fees. Micro prepares no notes, small a limited set (RJk B18), medium-sized an almost complete one.
Updated 30 October 2026
Key facts
| Guidelines | RJ 300 Function and classification (in force from financial year 2025), RJ 390 Other information to be included in the notes (from financial year 2026); for micro and small RJk B18 |
| Legal basis | Sections 5 and 6 of Title 9 Book 2 DCC, with the exemptions of art. 2:395a(6), art. 2:396(5) and (7) and art. 2:397(4) to (7) DCC |
| Order | The same order as the items on the balance sheet and profit and loss account (art. 2:363(1) DCC) |
| Public | Small: the notes to the balance sheet, without events after the balance sheet date (art. 2:396(8) DCC); medium-sized: limited under art. 2:397(5) DCC |
What the notes do, and what they cannot repair
The notes give the reader what the figures alone do not tell: which policies you apply, how an item is built up, which commitments lie off the balance sheet and what happened after the balance sheet date. They cannot make good an error on the balance sheet. An item that is wrongly valued or classified, you correct in the figures themselves; explanation in the notes is no alternative (RJ 300.102; RJk B18.101).
What they contain at a minimum (RJ 300.103): the policies for valuation and determination of result, for consolidated accounts the consolidation policies, additional statements such as the cash flow statement, the breakdowns the law requires, extra detail where the insight needs it and information that does not fit on the balance sheet, such as security and contingent liabilities. Every figure in the notes comes with the prior-year amount (art. 2:363(5) DCC; RJ 300.107). If the insight requires more than the law lists, you give it anyway (art. 2:362(4) DCC).
Structure: a general part and a part per item
The general part begins with name, legal form, registered office and KVK number (art. 2:380b DCC). Medium-sized and large entities also state the address and the main activities (RJ 300.105); for small that is optional (RJk B18.104). Then come the policies: when you recognise income, which costs are in inventories, how you account for taxes and foreign currency, and what has changed in policies or presentation and why.
Write down policies only for items you have. RJ 300.106a lists twenty topics that come into consideration, from leases to grants; the criterion is whether the explanation helps the reader understand how a transaction ended up in the figures. The specific part follows the items in the order of the annual accounts. Large entities put a reference to the notes at every item on the balance sheet, profit and loss account and cash flow statement; for medium-sized that is a recommendation (RJ 300.104).
The three topics of RJ 390
- Concessions. Whoever provides public services under a concession, such as a bus operator or a toll road operator, describes the arrangements, the terms that determine the cash flows and the rights and obligations at the end of the period (RJ 390.1). In the RJk the comparable section B18.3 has lapsed since the 2026 edition.
- Off-balance-sheet arrangements. Factoring, take-or-pay contracts, pledged assets, operating leases and outsourcing can bring risks or benefits that are not on the balance sheet. Large discloses nature, business purpose and financial effects (art. 2:381(2) DCC); medium-sized only nature and business purpose (art. 2:397(6) DCC); small nothing (art. 2:396(5) DCC).
- Audit fees. Only a large entity discloses what the external accountant charged for the audit, other assurance engagements, tax advice and other services (art. 2:382a DCC; RJ 390.304). Since financial year 2026 the fee for assurance on sustainability information is shown separately, or under a suitable name with the other assurance engagements (RJ 390.301). In addition you disclose the method by which you state the audit costs (RJ 390.301a).
Which disclosures per size class
The table gives the commonly occurring disclosures from Title 9. The thresholds for financial years from 1 January 2024 are, for micro, assets ≤ € 450.000, net turnover ≤ € 900.000, < 10 employees; for small, assets ≤ € 7,5 mln, net turnover ≤ € 15 mln, < 50 employees; for medium-sized, assets ≤ € 25 mln, net turnover ≤ € 50 mln, < 250 employees. Two of the three criteria count, on two consecutive balance sheet dates.
| Disclosure | Micro | Small | Medium-sized | Large |
|---|---|---|---|---|
| Policies (art. 2:384(5) DCC) | No; but a statement of tax bases | Yes | Yes | Yes |
| Name, legal form, registered office, KVK number (art. 2:380b DCC) | No | Yes | Yes | Yes |
| Events after the balance sheet date (art. 2:380a DCC) | No | Yes, not public | Yes | Yes |
| Multi-year commitments, such as rent (art. 2:381(1) DCC) | No | Yes | Yes | Yes |
| Off-balance-sheet arrangements (art. 2:381(2) DCC) | No | No | Nature and purpose | Full |
| Related parties (art. 2:381(3) DCC) | No | No | Only the NV, limited | Yes |
| Employees (art. 2:382 DCC) | No | Average number | Per category and abroad | Same |
| Audit fees (art. 2:382a DCC) | No | No | No | Yes |
| Directors' remuneration (art. 2:383(1) DCC) | No | No | Yes, unless traceable to one person | Same |
| Loans to directors (art. 2:383(2) DCC) | No | Yes | Yes | Yes |
| Equity interests (art. 2:379 DCC) | No | No; but the group parent | Yes | Yes |
| Turnover per activity and area (art. 2:380 DCC) | No | No | No | Yes |
| Appropriation of result (art. 2:380c DCC) | No | No | Yes | Yes |
| Movement in equity (art. 2:378 DCC) | No | Only revaluation reserve | Yes | Yes |
A micro entity does state below the balance sheet that it does not recognise accruals for other operating costs, if it uses that simplification (art. 2:395a(3) DCC). In exceptional cases, such as serious doubt about continuity, it too adds information (RJk M1.202). The full list for small is in RJk D4; for medium-sized in RJ 315, appendix 1. See also RJ 305 and 315.
Case: one printing company, two size classes
Drukkerij Meerzicht BV rents its premises for € 48.000 per year until the end of 2030. It sold its printing press to a leasing company, which leases the press back to it until the end of 2028 for € 30.000 per year as an operating lease. The bank has a pledge on the inventories. The director, also sole shareholder, borrowed € 35.000 from the BV at 4% interest and repaid € 5.000 in 2025. On average 23 people worked there. In January 2026 a storage building burns down; the damage after insurance is € 80.000. The accountant charged € 18.000.
| Disclosure | As a small BV | As a medium-sized BV |
|---|---|---|
| Rent commitment | Yes: € 240.000 for five years, of which € 48.000 within one year | Yes |
| Bank pledge | Yes (art. 2:375(3) DCC) | Yes |
| Leaseback of the press | Yes: lease commitment € 90.000 (art. 2:381(1) DCC) | Yes, plus nature and business purpose of the arrangement |
| Loan to the director | Yes: € 30.000 outstanding, 4%, repayment € 5.000, terms | Yes |
| Employees | Average 23 | 23, classified by department |
| Fire in January 2026 | Yes, but not in the filed document | Yes |
| Director's remuneration | No | May be omitted: one person |
| Accountant's fee € 18.000 | No | No |
What differs per financial year
| Financial year | Change |
|---|---|
| 2025 | RJ 300 (edition 2025) refers, for users and their information needs, to the new introduction "Background and principles", which replaced the old Framework (Stramien) (RJ 300.101a) |
| 2026 | RJ 390.301: fees for assurance on sustainability information separately; RJk B18.3 on concessions lapsed |
| 2027 | RJ 115.213a and RJk A2.113a: whether items must be disclosed separately also depends on characteristics such as nature, function, basis, uncertainty, term and restrictions; RJk B18.104 refers for additional information to art. 2:362(4) DCC, for example for important events |
Common mistakes
- Including standard policies for items the BV does not have.
- A small BV that discloses remuneration or accountant's costs and thereby makes private data public.
- Omitting the loan to the DGA, while a small BV too must disclose it.
- Including events after the balance sheet date in the filed document of a small BV.
- No comparative figures with the breakdowns.
How it works in Jaarrekening.io
Jaarrekening.io builds the questions for the notes from the size class and the chosen framework: micro always the RJk, small the RJk or, if you choose it, the full RJ, medium-sized and large the RJ. What the RJk only gives for consideration, such as information on related parties for a small BV, is a voluntary question. In the publication version of a small BV the events after the balance sheet date are left out.
Sources
- Art. 2:381 DCC: commitments, arrangements and related parties (wetten.overheid.nl)
- Art. 2:382a DCC: audit fees
- Art. 2:395a DCC: micro entities
- Art. 2:396 DCC: small entities
- Art. 2:397 DCC: medium-sized entities
- Dutch Accounting Standards Board (Raad voor de Jaarverslaggeving): the Guidelines and the compilations (rjnet.nl)
- Dutch Accounting Standards Board: Ten geleides per annual edition, with the changes per financial year
Frequently asked questions
Must a micro BV prepare notes?
No. Section 5 and the notes requirements of section 6 do not apply to a micro entity (art. 2:395a(6) DCC). Below the balance sheet it discloses only what the law asks there, such as the omission of accruals for other operating costs or the use of tax bases. In exceptional cases, such as serious doubt about continuity, it adds information anyway.
What may a small BV omit from the notes?
Among others the equity interests, the turnover split, off-balance-sheet arrangements, transactions with related parties, audit fees, directors' remuneration (art. 2:396(5) DCC) and the appropriation of result (paragraph 7). It gives the movement in equity only for the revaluation reserve. Policies, multi-year commitments, security, the average number of employees and loans to directors remain mandatory.
Must I disclose the accountant's costs in the notes?
Only as a large entity (art. 2:382a DCC). Small and medium-sized entities are exempt (art. 2:396(5) and 2:397(4) DCC). A large subsidiary need not either if the fees are already in the group's consolidated accounts.
What are off-balance-sheet arrangements?
Arrangements that bring risks or benefits without being on the balance sheet, such as factoring, take-or-pay contracts, pledged assets, operating leases and outsourcing (RJ 390.205). A large entity discloses nature, business purpose and financial effects; a medium-sized one only nature and business purpose; a small one nothing.
May a small BV apply the full RJ instead of the RJk?
Yes. A small entity chooses between the RJk compilation and the compilation for medium-sized and large entities. With the full RJ the notes that the RJ asks for apply too, but the statutory exemptions of art. 2:396 DCC remain.
Read more
Preparing Dutch annual accounts?
Your first set of annual accounts is free, for every size class. Create an account and prepare the annual accounts of your Dutch company under Title 9 of Book 2 of the Dutch Civil Code.
Get started