RJ 600 to 615: the financial sector
Banks, insurers, pension funds and investment funds have their own formats and their own chapters. This overview shows which chapter applies to whom and why size exemptions mostly do not exist there.
The short answer
Five chapters cover the financial sector: RJ 600 banks, RJ 605 insurers (including the mutual insurance association, the onderlinge waarborgmaatschappij), RJ 610 pension funds, RJ 611 premium pension institutions and RJ 615 investment entities. They rest on sections 14 and 15 of Title 9, the Pensions Act (Pensioenwet) and the Financial Supervision Act (Wft). Banks, insurers and listed entities are public-interest entities: the size exemptions do not apply to them.
Updated 30 October 2026
Key facts
| Banks | Section 14 Title 9 (art. 2:415-2:426 DCC), formats K, L and M; RJ 600 |
| Insurers | Section 15 Title 9 (art. 2:427 DCC et seq.); RJ 605, also for the mutual insurance association |
| Pension funds | Pensions Act; RJ 610. Premium pension institutions: Wft and Pensions Act; RJ 611 |
| Investment entities | Title 9 with art. 2:401 DCC and the Wft; RJ 615 |
| 2027 changes | RJ 600 and 605 (cash flows from interest and dividends), RJ 611 (Future of Pensions Act) |
Five chapters at a glance
| Chapter | For whom | Legal basis | Version per 2027 annual edition |
|---|---|---|---|
| RJ 600 Banks | Licensed credit institutions; also non-banks in a bank's consolidation | Section 14 Title 9; Dutch Annual Accounts Formats Decree (Besluit modellen jaarrekening), format K (balance sheet) and L or M (result) | Amended 2026, in force from 2027 |
| RJ 605 Insurance companies | Insurers as NV or mutual insurance association, and insurance groups | Section 15 Title 9; Besluit modellen jaarrekening and Dutch Current Value Decree (Besluit actuele waarde) | Amended 2026, in force from 2027 |
| RJ 610 Pension funds | All pension funds, including under the Mandatory Occupational Pension Scheme Act | Pensions Act, with Title 9 as basis | Amended 2025, in force from 2026 |
| RJ 611 Premium pension institutions | PPIs that run premium schemes without bearing risk themselves | Wft and Pensions Act | Amended 2026, in force from 2027 |
| RJ 615 Investment entities | Collective investors with a Title 9 legal form, with a Wft licence or with a licensed manager | Title 9, art. 2:401 DCC, Wft art. 4:37o, 4:51 and 4:52 | Amended 2023, in force from 2024 |
Payment institutions and electronic money institutions also fall under Title 9 regardless of legal form (art. 2:360(1) DCC), with the requirements of the Wft; they have no RJ chapter of their own in this series.
Banks and insurers: their own sections in Title 9
For a bank, section 14 and formats K, L and M replace the ordinary balance sheet and profit and loss provisions. Sections 3 and 4 do not apply, except for articles listed one by one, and neither does section 11 with the size exemptions (art. 2:416 DCC; RJ 600.104 to 600.106). A bank that applies IFRS falls under RJ 105; if it does not, it follows section 14 with RJ 600.
An insurer follows section 15. RJ 605 deals with investments, technical provisions, profit sharing and a risk section, and pays attention to health insurers, which as non-life insurers also follow the Health Insurance Act (RJ 605.103). The mutual insurance association is an insurer and therefore falls under RJ 605, not under the chapter for cooperatives (RJ 620.101). An entity that provides insurance but falls outside prudential supervision may apply the insurer rules if that serves insight (art. 2:427(2) DCC).
7. Articles 395a to 397 do not apply to legal entities that, as a public-interest entity:
a. have securities admitted to trading on a regulated market of a Member State (...);
b. are credit institutions within the meaning of Article 3(1) of Directive 2013/36/EU (...);
c. are insurance undertakings within the meaning of Article 2(1) of Directive 91/674/EEC (...); or
d. are designated by order in council because of their size or function in society.
Pension funds and premium pension institutions
Under the Pensions Act, the annual accounts of a pension fund must comply with Title 9, without the exemptions for small and medium-sized entities and without a revaluation reserve (RJ 610.103). Investments and technical provisions are stated at fair value. Since the Future of Pensions Act, RJ 610 has its own terms for the annual accounts: a solidarity reserve is called a solidarity fund, a risk-sharing reserve a risk-sharing fund, and both are designated funds; transferring old entitlements (invaren) is an internal collective value transfer through the statement of income and expenses.
A premium pension institution runs premium schemes and bears no insurance or investment risk itself. The investments at the risk of participants are therefore equal to the liabilities against them (RJ 611.102b). If a PPI also runs solidarity premium schemes, the rules of RJ 610 apply by analogy.
Investment entities and the difference from a holding
RJ 615 concerns collective investment: investing for more than one participant, where group companies and related parties do not count as separate participants. The chapter is mandatory for an investment entity with a Title 9 legal form, with a licence under the Wft or with a manager that holds such a licence; for other investment entities it is recommended (RJ 615.101). An investment company may state its investments at market value and let exchange differences run through the reserves (art. 2:401(2) DCC); the RJ recommends running them through the profit and loss account, with a revaluation reserve for increases without a frequent market quotation.
For an investment company to which art. 2:401(1) DCC applies, the micro, small and medium-sized regimes do not apply (art. 2:398(3) DCC). A personal holding that invests the assets of one director-major shareholder (dga) is not a collective investment. It follows the ordinary rules and the size class that fits its figures; RJ 615 is then at most a guide.
Case: Gracht Woningbelegging BV and Holding Van Wijk BV
Gracht Woningbelegging BV (fictitious) collected money from forty private investors and in 2024 bought 24 apartments for € 8.100.000. The investors share in rent and capital growth. That is collective investment with a Title 9 legal form: RJ 615 applies.
| Gracht Woningbelegging BV | 31 December 2025 | 31 December 2026 |
|---|---|---|
| Cost of portfolio | € 8.100.000 | € 8.100.000 |
| Fair value of portfolio | € 9.200.000 | € 9.600.000 |
| Unrealised increase in value in the profit and loss account (recommended route) | € 400.000 | |
| Revaluation reserve before deferred tax | € 1.100.000 | € 1.500.000 |
Because apartments have no frequent market quotation, Gracht keeps a revaluation reserve equal to the unrealised increase, even though that increase runs through the profit and loss account (art. 2:390(1) DCC). If the BV falls under the Wft conduct supervision, so that art. 2:401(1) DCC applies, it cannot use size exemptions.
Holding Van Wijk BV (fictitious) invests € 700.000 in index funds for its sole shareholder. There is one participant, so no collective investment. With turnover below € 900.000 and no staff it is micro, and as such may not state its investments at market value (art. 5a Besluit actuele waarde): they are stated at cost, or lower if the market price is below it. See RJ 120 and 135 and the annual accounts of a holding.
Changes per chapter and financial year
- Financial year 2025: RJ 600 and 605 in the 2019 version, RJ 610 with the amendments for the Future of Pensions Act (RJ-Uiting 2024-16), RJ 611 version 2021, RJ 615 version 2023.
- Financial year 2026: RJ 610 supplemented for spreading gains and losses in a solidarity premium scheme over at most ten years (RJ-Uiting 2025-8).
- Financial year 2027: RJ 600 and 605 amended after IFRS 18: banks and insurers may show interest received and paid and dividends received under operating cash flows if that belongs to their business (RJ-Uiting 2026-6). RJ 611 amended for the Future of Pensions Act (RJ-Uiting 2026-1).
Banks, funds and Jaarrekening.io
When you create an entity, Jaarrekening.io asks whether a reporting regime of its own applies. If you choose bank, insurer, pension fund, premium pension institution, investment institution or collective investor, you do not enter the annual accounts route; a mutual insurance association cannot be created. A personal holding that invests only its own money is not an investment entity and follows the ordinary route.
Sources
- Art. 2:398 DCC: no size exemptions for public-interest entities (wetten.overheid.nl)
- Art. 2:401 DCC: investment companies
- Art. 2:416 DCC: which sections apply to banks
- Art. 2:427 DCC: insurance companies
- RJ-Uiting 2026-6: draft guidelines following IFRS 18 (rjnet.nl)
- RJ-Uiting 2026-1: Guideline 611 Premium pension institutions and the Future of Pensions Act
- RJ-Uiting 2025-8: amendment of Guideline 610 Pension funds
Frequently asked questions
Which RJ chapter applies to a mutual insurance association?
RJ 605 Insurance companies. The mutual insurance association (onderlinge waarborgmaatschappij) concludes insurance with its members and, as an insurer, follows section 15 of Title 9, not the chapter for cooperatives (RJ 620.101).
Is my investment holding an investment entity within the meaning of RJ 615?
Not if it invests only for one shareholder or for group companies. RJ 615 concerns collective investment for more than one participant. For other forms of investment the chapter is at most a guide (RJ 615.101).
May a small bank use the exemptions for small entities?
No. A credit institution is a public-interest entity; articles 2:395a to 2:397 DCC do not apply (art. 2:398(7) DCC). Section 11 is also not among the sections that art. 2:416 DCC declares applicable to banks.
Do size exemptions apply to a pension fund?
No. The Pensions Act requires the annual accounts to comply with Title 9 without the exemptions for small and medium-sized entities, and without a revaluation reserve (RJ 610.103).
What changes in 2027 for the cash flows of banks and insurers?
After IFRS 18, the RJ has narrowed the choices for interest and dividends in the cash flow statement. For banks and insurers, for whom investing and financing are ordinary business, interest received and paid and dividends received may be shown under operating cash flows (RJ-Uiting 2026-6; RJ 600 and 605).
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