Q&A

Can I file with the KVK myself, without an accountant?

Yes, if you are micro or small. No audit requirement applies, and you may prepare, adopt and file the annual accounts digitally yourself.

✓ First annual accounts free ✓ Micro to large entities ✓ Dutch GAAP: Title 9, Book 2 DCC ✓ Primary database in the EU

The short answer

Yes, if you are micro or small. No audit requirement applies, and you may prepare, adopt and file the annual accounts digitally yourself.

Basis: art. 2:394 DCC

When may you submit the annual accounts yourself?

You file digitally via Zelf Deponeren Jaarrekening of the KVK or with suitable SBR software. The KVK portal lets micro and small entities enter the annual accounts; your own XBRL file is not required for that.

For micro and small entities the law sets no general requirement that an accountant audit the annual accounts. So you can prepare and submit them yourself, provided the annual accounts are correct in substance and of the right scope. Start with your size class over the relevant years. A small BV with, for example, € 2 million in assets, € 4 million in turnover and 12 employees does not fall under the statutory audit requirement because of those amounts. The figures alone, however, say nothing about incorrect valuation, missing notes or a special articles-of-association arrangement with a financier.

Which documents and resolutions do you need?

State the adoption date when filing if the annual accounts have been adopted (art. 2:394(1) DCC). If they have not yet been adopted while the deadline approaches, file the prepared version with the correct status according to the applicable KVK route. A shareholders' resolution does not normally have to be sent as a separate document.

First finish the bookkeeping: reconcile bank accounts, check receivables and payables, book depreciation and determine the tax position. Then prepare the annual accounts, have directors and any supervisory board members sign, and arrange adoption in line with the articles of association and the law. The publication version contains only the data your class requires. Check that the adoption date is entered correctly. If the annual accounts have not been adopted when the deadline expires, follow the KVK instructions for a prepared, non-adopted version. A bare upload without a resolution or check is not a complete year-end close.

How do you check that the filing succeeded?

For medium-sized and large entities a statutory audit by an accountant is in principle required. A director can organise the digital submission, but filing it yourself does not replace the required auditor's report.

Use a permitted digital route, such as the KVK portal for micro and small entities, or SBR software. After sending, check free of charge that the right financial year appears in the Business Register. Save the receipt, the final publication version and the signed internal version. A portal message that fields are technically valid says nothing about the accuracy of, say, a loan. For a medium-sized or large entity the statutory auditor's report is part of the process; pressing the button yourself does not replace that audit.

Filing yourself: checklist before the send button

First check that the bookkeeping is complete and that the annual accounts show the right balance sheet date. Compare, for example, a bank balance of € 24.500 in the annual accounts with the statement of 31 December and the trial balance. Then check the comparative figures, notes and size class. Record who the directors and supervisory board members were when the accounts were prepared and how adoption was arranged. For a micro BV the public version can be very limited; do not thoughtlessly upload the complete internal annual accounts. Finally, see that the KVK number and the financial year belong to the right file.

The work is not done after sending. Save the confirmation and check in the Business Register that the financial year is visible. If a technical error message appears, repair the submission and check again; a file you tried to send has not necessarily been processed. With a non-adopted version, watch for the later final filing. If the company grows to medium-sized, plan the statutory audit before the year-end close. Entering data yourself in a portal remains possible within the current route, but does not remove the statutory accountant's responsibility. Keep the complete internal documents for seven years with the bookkeeping records.

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 annual accounts remain the responsibility of the board (art. 2:362(1) DCC).

Frequently asked questions

Can I upload a PDF of my complete annual accounts?

The permitted form of submission depends on the financial year and size class; the portal or SBR sets its own requirements.

May my bookkeeper file on my behalf?

Yes, provided the required access and authorisation are in place; the board remains responsible for timeliness.

Do I need to check anything after filing?

Check with the KVK, free of charge, that the financial year has been processed and keep the confirmation of receipt.

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.

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