Question & answer

Can my bookkeeper issue an accountant's report?

Only if that person is a qualified accountant for the engagement. A bookkeeping report is not automatically an accountant's report.

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The short answer

Only if that person is a qualified accountant for the engagement. A bookkeeping report is not automatically an accountant's report.

Basis: art. 41 Wet op het accountantsberoep (Dutch Accountancy Profession Act); art. 2:393 and 2:396 DCC

When may someone call themselves an accountant?

The job title bookkeeper does not say whether someone is registered as an accountant. Some bookkeepers are also accountants; others are not. So check who issues the report and which type of report is meant. A compilation report and an audit report set different requirements for the engagement and for qualification. Ask for the name of the responsible professional.

The NBA (the Dutch professional body for accountants) maintains the accountants register. Art. 41 of the Wet op het accountantsberoep protects the accountant titles and the designation accountant. A bookkeeping firm can deliver good year-end work without every employee being an accountant, but may not create a wrong impression about that status. Check the person who signs rather than only the firm's trade name. A logo, trade association membership or software certificate is not a substitute for accountant registration. For an audit engagement, also ask whether the firm has the required qualification and, where applicable, the licence for the type of audit you need.

What can a bookkeeper provide?

In many situations a bookkeeper can help with the records and with preparing annual figures. That does not make a covering letter an accountant's compilation report under NBA Standard 4410. Nor does a compilation report give the assurance of an audit report. The existing explanation of reports covers this difference in more detail. For your choice, what the recipient requires is the key point. Ask a bank or subsidy provider to put the requirement in writing. Then your current adviser can say whether they can deliver the requested product themselves or must cooperate with an accountant.

For an ordinary micro or small BV, support by a competent bookkeeper can be appropriate when no specific accountant's report is requested. The statutory audit exemption must, however, have been assessed correctly; art. 2:393 and 2:396 DCC are relevant here. For medium-sized or large companies and special situations, other requirements may apply. So do not choose only on title or price. Also look at experience with your file, availability, supporting documentation and the quality of the work process. A simple BV needs different support from a group with complex participations and financing.

Which report does the recipient ask for?

Record what you receive: a compiled report, a specific report or only bookkeeping support. Avoid contract wording that summarises everything as 'accountant's report' without further explanation. When a bookkeeper and an accountant cooperate, agree who reconciles the source data, who answers questions and who processes corrections. That prevents duplicate work and extra costs. If your lender requires an accountant's report, do not wait until the report is ready to check qualification. Timely coordination makes clear which professional is needed, while you can leave preparatory work with your trusted bookkeeper where possible.

Sources

Legal notice: this information is general in nature and does not replace tax or legal advice or an audit by an accountant. The accuracy and completeness of the Dutch annual accounts remain the responsibility of the board (art. 2:362(1) DCC).

Frequently asked questions

Is every bookkeeper a registered accountant?

No. Check the AA or RA registration in the accountants register.

Can a bookkeeper prepare annual figures?

Yes. The protected accountant title is not always required for that.

Is a compilation report an audit report?

No. They are different products with a different level of assurance.

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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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