Annual accounts for healthcare (Dutch): DigiMV, WNT and the KVK
A healthcare provider accounts via DigiMV, sometimes also on top incomes, and as a BV additionally at the KVK. These are the three routes, with deadlines and thresholds.
The short answer
A healthcare provider usually has two obligations. Before 1 June you submit the annual accountability report via DigiMV under the Regulation on public annual accountability WMG. If the provider is a BV, you also file the annual accounts with the KVK. If two or more persons provide insured care on behalf of a legal entity, a WNT accountability also belongs in the annual documents.
Updated 30 October 2026
Key facts
| Annual accountability report | Before 1 June after the financial year, via DigiMV at the CIBG (art. 12a and 13 Regulation) |
| For whom | In principle every healthcare provider, including the partnership and sole proprietorship that has care provided |
| KVK | Filing continues to apply to the healthcare BV |
| WNT | As soon as two or more persons provide insured care on behalf of a legal entity |
Two routes side by side: DigiMV and the KVK
In principle every healthcare provider accounts publicly each year (art. 40b Healthcare Market Regulation Act (Wet marktordening gezondheidszorg)). The Regulation on public annual accountability WMG elaborates on that; unlike under the old WTZi regulation, primary care is also covered. The annual accountability report consists of a financial accountability, documents you add to it and a questionnaire on business operations.
For the annual accounts of a legal entity the Regulation refers to divisions 2 to 6 inclusive of Title 9, which apply mutatis mutandis (art. 2(2)); the RJ follows this with chapter 655, RJk C3 for small and RJk M2 for micro healthcare providers. The financial year is always the calendar year (RJk C3.105). You submit to the CIBG via DigiMV, before 1 June after the financial year. The NZa can grant an extension on request until 31 December at the latest, if you apply before 1 April.
Since financial year 2026 a separate Regulation on public annual accountability Youth Act applies to youth care providers and certified institutions that provide only youth care, with the same submission via DigiMV before 1 June. Small providers use models C and D, micro providers A and B, and they also make the profit and loss account public (RJk C3.101a, C3.302, C3.502, M2.302 and M2.501).
That is separate from the Business Register: a healthcare BV files its annual accounts in addition with the KVK (art. 2:394 DCC). If a healthcare foundation makes an equivalent financial accountability public by virtue of the law, Title 9 remains inapplicable to it (art. 2:360(3) DCC).
What do you submit per size class?
The Regulation uses the thresholds of Title 9: two of the three criteria on two consecutive balance sheet dates, in the first financial year the position at the end of that year. The figures of group companies count as well (art. 4(3) Regulation).
| Class | Thresholds (assets, net turnover, employees) | What you submit | What becomes public |
|---|---|---|---|
| Micro | ≤ € 450.000, ≤ € 900.000, < 10 | Abridged balance sheet and abridged profit and loss account, without notes | The abridged balance sheet and a board statement; a micro youth care provider makes the whole annual accountability report public (RJk M2.501) |
| Small | ≤ € 7,5 mln, ≤ € 15 mln, < 50 | Balance sheet and profit and loss account in the prescribed models | Everything; no management report or auditor's report needed |
| Medium-sized and large | Above the thresholds for small | Annual accounts, management report and auditor's report | Everything |
The micro class is available for the annual accountability report from financial year 2024; the associated rules apply since 1 January 2025. Hired freelancers, such as locum doctors, do not count towards the number of employees. For a micro partnership or micro sole proprietorship the figures do not become public. For the KVK: see the size criteria.
WNT: accountability with its own audit by an accountant
The Wet normering topinkomens (WNT, Standards for Remuneration of Senior Officials Act) applies to a healthcare provider as soon as at least two persons provide care on its behalf that falls under the Health Insurance Act or the Long-term Care Act. The WNT does not apply to a sole proprietorship, partnership, vof or cv; it does apply to a practice BV with two practitioners.
A WNT institution includes the WNT accountability in the financial annual documents; anyone who submits via DigiMV thereby makes it public. An accountant must audit the WNT data, even if the annual accounts themselves need no auditor's report. Only very small institutions are exempt: a private-law legal entity with a gross wage bill of up to € 175.000 per year, without a paid senior executive outside an employment relationship and without another audit requirement.
Worked example: healthcare BV with a revenue ceiling
A healthcare BV has agreed a revenue ceiling of € 600.000 with the health insurer. Up to and including November € 585.000 has been claimed. In December it delivers 400 hours of care at € 75, together € 30.000; the claim goes out in January. The insurer has not promised any payment above the ceiling.
- Care delivered in the financial year: € 585.000 + € 30.000 = € 615.000.
- Above the ceiling: € 615.000 − € 600.000 = € 15.000. Payment of that is not probable, so it is not revenue (RJ 270.117).
- Revenue December: € 30.000 − € 15.000 = € 15.000, on the balance sheet as care still to be claimed (art. 2:362(5) DCC).
- Net turnover in the annual accounts: € 600.000.
With € 600.000 revenue, a balance sheet total of € 310.000 and eight employees this BV is micro, if that was also so last year: via DigiMV and at the KVK only the abridged balance sheet becomes public.
Common mistakes at healthcare providers
- Submitting the annual accountability report after 31 May without an extension having been granted.
- Forgetting the WNT accountability while in the practice BV two or more persons provide insured care.
- Recognising care above the revenue ceiling as a certain receivable.
What BVs in this sector file
Healthcare providers fall under SBI section Q, human health and social work activities (SBI 86–88): practices, hospitals, nursing and social services. An accountability submitted only via DigiMV is not in the KVK dataset.
| Balance sheet class, financial year 2024 | Filings | Solvency: p25 – median – p75 | Current ratio: p25 – median – p75 |
|---|---|---|---|
| Micro (balance sheet up to and including € 450.000) | 6.213 | 17,9% – 64,3% – 90,0% | 1,02 – 2,44 – 8,22 |
| Small (balance sheet above € 450.000 up to and including € 7,5 mln) | 5.168 | 41,3% – 76,4% – 95,4% | 1,44 – 4,24 – 19,60 |
| Medium-sized (balance sheet above € 7,5 mln up to and including € 25 mln) | 114 | 20,5% – 45,7% – 70,2% | 1,11 – 1,48 – 2,61 |
| Large (balance sheet above € 25 mln) | fewer than 25 | – | – |
In the small balance sheet class, section Q had a median solvency of 76,4% for financial year 2024, higher than the 73,4% of all balance sheets in that class combined; the median current ratio was 4,24, higher than nationally (3,28). The national figure is high because of the many holding companies.
The balance sheet class follows only the balance sheet total, not the statutory size class. The dataset does not state the legal form; it covers all XBRL filings with this SBI section, mostly by BVs. Source: KVK Business Register Open Dataset Annual Accounts, processed by Jaarrekening.io, CC BY 4.0. Data downloaded and processed on 2 November 2026. Explanation and all sectors: solvency per sector and current ratio per sector.
What Jaarrekening.io does and does not do for a healthcare BV
Two documents you prepare outside Jaarrekening.io: the annual accountability report for DigiMV and the WNT accountability. The software follows the ordinary Title 9 route. Jaarrekening.io does not prepare the annual accounts of a healthcare provider: the intake stops at a healthcare or youth care provider, because the models of the Regulation on annual accountability and DigiMV fall outside the app. So do not use the software for the annual accounts of a healthcare BV; you prepare those with the models of the Regulation.
Sources
- Regulation on public annual accountability WMG (wetten.overheid.nl)
- Healthcare Market Regulation Act (Wet marktordening gezondheidszorg), art. 40b
- Annual accountability in healthcare: legal entities
- Annual accountability in healthcare: healthcare providers (micro from financial year 2024)
- Annual accountability in healthcare: the micro healthcare provider
- Annual accountability in healthcare: exceptions
- Annual accountability in healthcare: WNT, which organisations
- Annual accountability in healthcare: WNT, publication and audit
- RJ Publication 2022-3: draft guideline 655 and RJk C3 (draft); the current text of C3 and M2 comes from RJ Publication 2026-2 (Regulation on public annual accountability Youth Act)
- Dutch Civil Code, Book 2, Title 9
- RJ 270 Revenue (RJ Publication 2020-15, appendix 2, final)
Frequently asked questions
Does a self-employed person (zzp) in healthcare have to submit an annual accountability report?
Not if you provide all care yourself and do not engage other care providers for it, such as employees, locums, subcontractors or hired freelancers. Anyone who provides only care from the supplementary package or only Wmo care is also excluded.
Does submission via DigiMV replace filing with the KVK?
No. The annual accountability report follows from the Healthcare Market Regulation Act (Wet marktordening gezondheidszorg), the filing from Book 2 DCC. A healthcare BV does both: before 1 June via DigiMV and at the latest twelve months after the financial year with the KVK.
Does a small healthcare BV need an accountant?
Not for the annual accountability report: a small healthcare provider need not add an auditor's report. If the BV falls under the WNT, an accountant's report is needed for the WNT data, unless the accountability exemption for very small institutions applies.
Does the annual accountability obligation also apply to a partnership of physiotherapists?
Yes. The partnership accounts as a whole, with a balance sheet and a statement of income and expenditure. The individual partners need not do so separately, unless they also provide care outside the partnership.
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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.
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