Amendment Act on the Accountancy Sector: Impact on Your Organization

ANNEX TO SECTOR REPORT
Amendment Act on the Accountancy Sector: What is the impact on your organization?
In short - The Amendment Act on the Accountancy Sector is expected to enter into force on July 1, 2026. With this publication – intended for all audit firms – the AFM highlights five topics regulated in this act that may impact your audit firm.
APRIL | 2026

© AFM 2026 | Amendment Act on the Accountancy Sector: What is the impact on your organization? 2 Summary With the Amendment Act on the Accountancy Sector, the Minister of Finance has taken additional measures to contribute to the quality of statutory audits. The quality of statutory audits is the basis for trust in the audit and a prerequisite for trust in the accountancy sector. The measures support, among other things, a quality-oriented culture within audit firms. As the name of the Amendment Act on the Accountancy Sector already suggests, this is a law that introduces amendments to other laws. The content of this law must be read in conjunction with the Act on Supervision of Audit Firms (Wta) for topics 1, 2, and 5, and in conjunction with the Act on the Accountancy Profession (Wab) for topics 3 and 4. In this publication, the AFM draws the attention of audit firms and their policymakers to five topics from the Amendment Act on the Accountancy Sector. Some topics concern specific groups of audit firms; other topics have an impact on all audit firms. The AFM calls on policymakers of audit firms to take note of these topics so they can assess the impact on their own organization and determine what actions may be necessary.

1. Strengthening governance of the largest audit firms
2. Clarification of the shared responsibility of the audit firm for the quality of statutory audits
3. Audit quality indicators for OOB audit firms
4. Appointment authority for public interest entities without an auditor
5. Reporting of deficiencies in a statutory audit to the AFM
   Do you have questions about the Amendment Act on the Accountancy Sector? Then send an email to wta@afm.nl.

© AFM 2026 | Amendment Act on the Accountancy Sector: What is the impact on your organization? 3

1. Strengthening governance of the largest audit firms
   The law introduces new governance requirements for audit firms with a regular license to perform statutory audits (AOs-RV) that meet the following size criteria for three consecutive financial years:

• Revenue from statutory audits of at least €3,000,000 per financial year; and
• At least 150 statutory audits per financial year.
  For these largest AOs-RV, the following three governance requirements will apply due to amendments to the Act on Supervision of Audit Firms (Wta, inserted article 24c), which currently already apply to audit firms with a license to also perform statutory audits at public interest entities (OOB-AOs):
• Suitability requirement for policymakers belonging to three collectives (daily policymakers of the audit firm, daily policymakers of the highest network part in the Netherlands, members of the internal supervisory body) of the audit firm (article 16, third to sixth paragraphs, Wta);
• Daily policymakers of the audit firm perform no other activities than those of daily policymaker of the audit firm, unless the supervisory body grants approval for this (article 16a Wta);
• Mandatory establishment of a system of independent internal supervision over the policy and general course of affairs of the audit firm, which includes a supervisory body consisting of at least three natural persons (article 22a Wta).
  Based on a transitional provision in the Amendment Act, for AOs-RV that already meet the size criteria of that article for three financial years at the time of entry into force of article 24c Wta, the three aforementioned requirements apply one year after the entry into force of article 24c. If article 24c Wta enters into force on July 1, 2026, this means that the three aforementioned requirements will apply from July 1, 2027. If article 24c Wta enters into force on July 1, 2026, this means for the suitability requirement that the largest AO-RV may only allow natural persons belonging to the three collectives to take office after the AFM has established the suitability of the intended policymaker from July 1, 2027. Regarding the natural persons belonging to the three collectives who are already in office before or on June 30, 2027, the AFM must rule on the suitability of these policymakers within one year from July 1, 2027. The AFM is already in contact with audit firms that it believes qualify (possibly) as the largest AOs-RV. If you believe that your audit firm also qualifies as the largest AO-RV, and your organization has not yet been approached by the AFM regarding the past, we request that you contact us by sending an email to: wta@afm.nl. For the largest AOs-RV and OOB-AOs, the powers of the required internal supervisory body are supplemented with certain approval rights (amendment of article 22a Wta). These include approval rights regarding a proposal for profit distribution, entering into or terminating a sustainable cooperation of the audit firm, taking (or significantly modifying) a participation in another company, making investments, and terminating the employment contract of a significant number of employees.

© AFM 2026 | Amendment Act on the Accountancy Sector: What is the impact on your organization? 4
2. Clarification of the shared responsibility of the audit firm for the quality of statutory audits
For all AOs, the law clarifies the shared responsibility of the audit firm for the quality of its individual statutory audits (amendment of article 18 Wta). The amendment stipulates that the system of quality management is designed such that the quality of the statutory audits is secured. This gives the provision on the system of quality management a quality objective. This clarification of the shared responsibility of audit firms for the quality of statutory audits reflects the development in the accountancy profession where the quality of a statutory audit is largely influenced by the audit firm, in addition to the individual accountant. This requirement will be further specified in subordinate legislation by setting requirements for the system of quality management, to give content to this shared responsibility.
3. Audit quality indicators for OOB audit firms
For OOB-AOs, a requirement will apply under the Act on the Accountancy Profession (Wab) to periodically report to the Dutch Institute of Certified Accountants (NBA) about quality indicators, often referred to as audit quality indicators (insertion of articles 45a-45c Wab). The NBA will subsequently make the reported information public. These are indicators that provide insight into factors that influence the quality of statutory audits. No quality-enhancing effect can be expected from the introduction of quality indicators on its own. However, data does contribute to conducting a good discussion and making well-founded decisions by all stakeholders, such as audit clients but also the audit firms themselves. The quality indicators to be reported will be established in subordinate legislation under the law, namely a ministerial regulation.
4. Appointment authority for public interest entities without an auditor
For OOB-AOs, it is relevant to take note of the future regulation whereby – as a last resort – an OOB audit firm is assigned to a public interest entity (OOB) (insertion of articles 54a-54e Wab). The Minister of Finance has informed the House of Representatives that he wants this regulation to enter into force only when he is convinced that there is an OOB that has everything in order but has still been unable to contract an audit firm. The regulation gives an OOB that, despite reasonable and timely efforts, cannot find an audit firm willing to accept the assignment for a statutory audit of their financial reporting, the possibility to submit an application to the Dutch Institute of Certified Accountants (NBA) to be assigned an OOB-AO. The NBA will have the authority to decide on the request of an OOB for the appointment of an OOB-AO. This regulation will not yet be brought into force by the Minister of Finance upon the entry into force of the rest of the Amendment Act, but only at a later moment when the minister decides that there is a necessity for this.

© AFM 2026 | Amendment Act on the Accountancy Sector: What is the impact on your organization? 5
5. Reporting of deficiencies in a statutory audit to the AFM
For all AOs, this law limits the confidentiality obligation for audit firms (amendment of article 20 Wta) to allow reporting to the AFM of possible deficiencies in a statutory audit. With this legislative amendment, the obligation of audit firms to keep confidential data or information secret does not apply if they are provided to the AFM in connection with the reporting of a possible violation of the European Audit Regulation or the Wta by an audit firm. A possible violation of the Wta can occur, for example, if an audit firm takes over a statutory audit from another audit firm and finds irregularities in the previous audit. The AFM can include the reports in its supervision of audit firms and their external accountants. In this way, these reports can contribute to the sustainable increase in the quality of statutory audits and thereby increase trust in the audits and the sector. Such a report of deficiencies in a statutory audit can preferably be communicated by email (wta@afm.nl).