Can a grant still make an accountant mandatory?
Yes. Grant conditions can require an accountant's product, even without a statutory audit of the annual accounts. Read the grant decision and protocol.
Short answer
Yes. Grant conditions can require an accountant's product, even without a statutory audit of the annual accounts. Read the grant decision and protocol.
Basis: art. 2:393 DCC; grant decision and applicable audit protocol
Which audit protocol belongs to the grant?
No statutory audit requirement for the annual accounts does not mean that an accountant's report can be dispensed with for every grant. A grant scheme can set its own requirements for the accountability statement. Those requirements may relate to project costs rather than to the full annual accounts. First check, therefore, what exactly must be examined and delivered.
Read the decision, the scheme and the applicable audit protocol together. Note the period, cost categories, submission date and the required accountant's product. For certain project grants, RVO (the Netherlands Enterprise Agency) describes an auditor's report on final determination; the conditions are tied to the scheme concerned and its size. Do not adopt such a threshold as a general rule for all grants. Municipal, European and other schemes may be set up differently. Ask the grant provider for clarification if the decision and a general web page do not give the same impression. Keep the answer in your project file and share it with the accountant.
Which project data are examined?
An audit of project expenditure may require different evidence than the annual accounts. Think of timesheets, invoices, payments, procurement documentation or proof that activities were actually carried out. Set up the records at the start of the project. Reconstructing missing timesheets afterwards can be difficult and does not automatically provide sufficient evidence. Have the accountant look at the protocol in advance, together with the records he expects to need. That is not prior approval of all costs, but it helps prevent you from discovering at the end that essential information was not kept.
Art. 2:393 DCC governs the statutory audit of the annual accounts. A grant audit is a separate engagement that is not automatically covered by an existing report on the annual accounts. Conversely, a report on a project claim does not replace a statutory audit of the entire annual accounts when one is required. Ask, therefore, about the exact subject of the audit, the reporting and the circle of distribution. Nor can a compilation report be used without permission instead of a required auditor's report. Have the accountant confirm that the requested product matches the protocol and the grant provider's conditions.
How does this differ from auditing the annual accounts?
Include the costs and planning of this engagement in your project budget, as far as the scheme allows. Ask in advance how additional examination or incomplete documents are handled. Align the grant settlement with the treatment in the annual accounts, so that advances received, funds spent and any repayment obligations are understandable. Keep the submitted statement and confirmation of receipt alongside the final decision. The right choice is not automatically to order an extensive audit of the annual accounts, but to organise the specifically required examination. That way you meet the grant conditions more precisely and avoid paying for a report the recipient does not accept.
Sources
Frequently asked questions
Does the grant audit lapse for a small BV?
Not automatically. The grant decision and scheme may require a separate accountant engagement.
Is it always about the whole annual accounts?
No. A grant audit can focus specifically on project costs and conditions.
When do you arrange the accountant?
Read the audit protocol early, so that evidence and planning during the project fit it.
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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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