Sector in Focus 2025 – Accountancy and Reporting

ANALYSIS REPORT Sector in Focus 2025 – Accountancy and Reporting

In brief – In this publication, the AFM provides some insights back to the sector; insights derived from data reported by accounting firms and from the outcomes of our supervision of the reporting of issuers. The insights cover general developments, such as the market share of accounting firms, data-driven versus system-oriented auditing, and signals and notifications. It also covers topics related to quality assurance, such as consultations, technical support, policies for root cause analyses, independence threats, and training and education. Finally, we address the themes of fraud and the reporting of issuers.

NOVEMBER | 2025

© AFM 2025 | Sector in Focus 2025 – Accountancy and Reporting 2

Contents

1. Introduction 3 1.1 Sector in Focus 2025 3 1.2 Data-driven supervision and data quality 3 1.3 Guide to reading 4
2. General developments 5 2.1 Market share 5 2.2 Data-driven versus system-oriented auditing 6 2.3 Signals and notifications 7
3. Quality assurance 9 3.1 Consultations 9 3.2 Technical support 10 3.3 Policy for root cause analyses 11 3.4 Independence threats 11 3.5 Training and education 13
4. Fraud 15
5. Reporting of issuers 17 Appendix: Explanation of analyses 18

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1. Introduction 1.1 Sector in Focus 2025 The AFM provides insights in this publication by returning data reported by accounting firms and outcomes of supervision on issuers to the sector. This publication is limited to a selection of topics that are relevant for supervision based on the AFM Strategy 2023-2026. The topics in this publication are general developments, quality assurance, fraud, and reporting of issuers. Sector in Focus is not an annual overview and does not claim to be comprehensive.

Sector in Focus 2025 is an important supplement to Trendzicht 2026. Trendzicht provides insight into various general developments in the accountancy sector based on data, which can provide a quality impulse as well as bring risks. Sector in Focus supplements this and provides additional insights and in-depth analyses based on data received by the AFM from accounting firms. This gives the sector a broader insight into various relevant topics and developments, and allows accounting firms to benchmark themselves against these sector developments. Unlike Trendzicht, Sector in Focus does not provide interpretation and/or risk assessment of the identified developments.

1.2 Data-driven supervision and data quality Due to the large number of accounting firms under supervision, the AFM adopts a risk-based and data-driven supervision approach. Until 2022, the AFM primarily supervised accounting firms with a license that also extends to performing statutory audits for entities of public interest (hereinafter: OOB-accounting firms). Since 2022, the AFM has also been exercising de facto supervision over the approximately 200 accounting firms with a regular license for performing statutory audits (hereinafter: RV-accounting firms). This expansion of the supervision mandate has led to the development of a more risk-based and data-driven supervision approach due to the large increase in the number of institutions under supervision. For this purpose, the AFM, in consultation with representatives of accounting firms, selected data points per statutory audit. Accounting firms share this data with the AFM to see, understand, and address risks in supervision.

Both the volume and quality of data on statutory audits from RV-accounting firms are increasing. Throughout 2023, RV-accounting firms began filling out questionnaires per statutory audit. By mid-September 2025, the AFM possessed data points from over 31,000 statutory audits from RV-accounting firms (over a period of approximately three years).1 The AFM checks the quality of the received data. Figure 1 shows the percentage of statutory audits with one or more identified deviations in data quality, over the period from the second quarter of 2023 to the third quarter of 2025. This shows that identified deviations in data quality have decreased from 34% in the second quarter of 2023 to 7% in the third quarter of 2025. Since the third quarter of 2024, this percentage has remained stable, which benefits the reliability of the data and thus the analyses in this report.

1 The data position increases annually. In the analyses in this publication, the number of observations for 2022: 1,648, for 2023: 8,449, for 2024: 12,548, and for 2025: 8,334. The data for 2025 are updated to mid-September.

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Figure 1: Percentage of statutory audits with identified deviations in data quality at RV-accounting firms remains stable Source: Data statutory audits RV-accounting firms based on submission date. Note: Due to newly added data quality controls, there are small deviations compared to previous publications, but this does not affect the conclusion.

1.3 Guide to reading Chapter 2 of this publication describes some general developments, including the market share of RV-accounting firms, data-driven versus system-oriented auditing, and signals and notifications. Chapter 3 focuses on quality assurance, with attention to consultations, hiring of technical support, policy for root cause analyses, independence threats, and training and education. Chapter 4 covers fraud. Finally, Chapter 5 addresses questions and actions resulting from supervision of the reporting of issuers. The appendix contains an explanation of the analyses in this publication.

34% 32% 23% 16% 9% 7% 7% 7% 7% 7% 66% 68% 77% 84% 91% 93% 93% 93% 93% 93% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Q2 '23 Q3 '23 Q4 '23 Q1 '24 Q2 '24 Q3 '24 Q4 '24 Q1 '25 Q2 '25 Q3 '25 Percentage of statutory audits without identified deviations in data quality Percentage of statutory audits with one or more identified deviations in data quality

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2. General developments 2.1 Market share The market share of RV-accounting firms based on revenue from statutory audits at non-OOB audit clients continues to increase. In Trendzicht 2026, the market share of RV-accounting firms was reported based on the number of statutory audits. Figure 2 shows the market share based on the revenue ratio of RV- and OOB-accounting firms from statutory audits at non-OOB audit clients over the period from 2014 to 2024. This shows that the market share of RV-accounting firms increases from 18% in 2014 to 40% in 2024. In the same period, revenue from statutory audits at non-OOB audit clients rises from €678 million in 2014 to €1,485 million in 2024. This increase in the market share of RV-accounting firms based on revenue from statutory audits is comparable to the development in market share based on the number of statutory audits as reported in Trendzicht.

Figure 2: The market share of RV-accounting firms based on revenue from statutory audits at non-OOB audit clients continues to rise Sources: AFM Market Monitor 2014-2021; Data RV- and OOB-accounting firms 2022-2024. The numbers above the bars represent revenue in million €.

In addition to the approximately 220 accounting firms, there are now also four audit firms from other member states that may perform statutory audits in the Netherlands based on AFM registration. Since 2017, following the implementation of changes to the European Audit Directive2, it has been possible for audit firms from other European countries to register in the Netherlands to perform statutory audits there. The AFM registered such an audit firm from another member state for the first time upon request in 2023. The four registered audit firms from other member states now perform a limited number of statutory audits per audit firm and have been excluded from Figure 2.

2 Directive 2014/56/EU of the European Parliament and of the Council of 16 April 2014 amending Directive 2006/43/EC on statutory audits of annual accounts (OJ EU 2014, L 158) and implementing Regulation (EU) No 537/2014 of the European Parliament and of the Council of 16 April 2014 on specific requirements regarding statutory audit of financial statements of entities of public interest (OJ EU 2014, L 158), implemented as of 1 January 2017 via the Implementation Act on the amendment directive and regulation on statutory audits of annual accounts in the Act on supervision of accounting firms.

18% 18% 17% 19% 21% 28% 33% 34% 35% 37% 40% 82% 82% 83% 81% 79% 72% 67% 66% 65% 63% 60% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 RV-accounting firms OOB-accounting firms 678 724 762 793 825 911 977 1.016 1.106 1.332 1.485

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2.2 Data-driven versus system-oriented auditing The percentage of statutory audits that RV-accounting firms perform entirely data-driven is increasing. Figure 3 shows the percentage of statutory audits by RV-accounting firms with a predominantly system-oriented (1) to fully data-driven (5) audit approach over the period 2022 to 2025. The share of fully data-driven statutory audits by RV-accounting firms decreases from 52% in 2022 to 48% in 2023, and then increases to 54% in 2025.

Figure 3: Percentage of fully data-driven audits by RV-accounting firms increases Source: Data statutory audits RV-accounting firms based on issuance date of audit report. Explanation: The extent to which the audit is performed in a data-driven manner was scored by the accounting firms themselves on a scale from 1 (predominantly system-oriented) to 5 (fully data-driven). Note: The data for 2025 are updated to mid-September.

Medium-sized RV-accounting firms perform the largest share of statutory audits fully data-driven. Figure 4 shows that medium-sized RV-accounting firms perform 55% of their statutory audits fully data-driven. For large RV-accounting firms, this is 52%, and for small RV-accounting firms, it is 43%. RV-accounting firms are divided in this report into large, medium, and small based on revenue from statutory audits. See the explanation in the appendix for this.

11% 13% 11% 10% 33% 35% 34% 34% 52% 48% 53% 54% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 2022 2023 2024 2025 1 Predominantly system-oriented 2 3 4 5 Fully data-driven

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Figure 4: Percentage of fully data-driven audits is highest at medium-sized RV-accounting firms Source: Data statutory audits RV-accounting firms (cumulative 2022-2025). Note: The data for 2025 are updated to mid-September.

2.3 Signals and notifications The number of notifications of mid-term termination of audit engagements due to the increased audit threshold increased at RV-accounting firms in 2024. The most common statutory audit concerns the audit that is mandatory for medium and large enterprises under the Dutch Civil Code (BW). 3 This obligation depends on size criteria.4 As of 13 March 2024, the size criteria for audit-mandatory enterprises were increased to €7.5 million in assets (was €6 million), €15 million in net turnover over the financial year (was €12 million), and an average of 50 employees over the financial year (unchanged).5 The audited enterprise and the accounting firm must notify the AFM without delay of the withdrawal of the audit engagement by the audited enterprise or the mid-term termination thereof by the accountant(s)/firm. 6 The AFM registers both situations as a notification of mid-term termination. Figure 5 shows the number of received notifications of mid-term termination of audit engagements by OOB- and RV-accounting firms in 2023 and 2024. As a result of the increase in size criteria, the number of notifications of mid-term terminations increased from 159 in 2023 to 417 in 2024. This increase occurs only at RV-accounting firms.

3 Article 393, first paragraph, Book 2 of the Dutch Civil Code. 4 Article 396, first paragraph, Book 2 of the Dutch Civil Code. 5 Enterprises are audit-mandatory if they meet at least two of the three criteria on two consecutive balance sheet dates. 6 Article 393, second paragraph, Book 2 of the Dutch Civil Code.

20% 11% 10% 29% 31% 37% 43% 55% 52% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Small Medium Large 1 Predominantly system-oriented 2 3 4 5 Fully data-driven

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Figure 5: Number of notifications of mid-term termination of audit engagements increases at RV-accounting firms Source: Internal AFM data.

The AFM received more incident notifications from RV-accounting firms in 2024 than in 2023. Accounting firms are required to notify the AFM without delay of incidents with serious consequences for the proper exercise of their business.7 The AFM has provided clarification in an interpretation of what constitutes an incident.8 In 2023, the AFM received 48 incident notifications (OOB-accounting firms: 21; RV-accounting firms: 27). This increased in 2024 to 56 incident notifications (OOB-accounting firms: 18; RV-accounting firms: 38).

7 Article 21, first and second paragraphs, Act on supervision of accounting firms in conjunction with Article 32, second and fourth paragraphs, Decision on supervision of accounting firms. 8 Interpretation of the term incident in the context of the Act on supervision of accounting firms and the Decision on supervision of accounting firms.

74 85 76 341 OOB-accounting firms RV-accounting firms Number of notifications of mid-term terminations 2023 2024

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3. Quality assurance 3.1 Consultations In 2024, accounting firms used technical support through consultations in approximately one-third of statutory audits. Accounting firms must ensure that their external accountants seek advice from competent persons as necessary for the execution of a statutory audit and record this in the audit file.9 This seeking of advice is often referred to as consulting. In 2024, a consultation took place in an average of 32% of statutory audits by RV-accounting firms. For OOB-accounting firms, this is 25%. Figure 6 shows a further breakdown of this by large, medium, and small RV-accounting firms, as well as by regular and OOB audits of OOB-accounting firms.

Often, consultation occurs on more than one topic. For statutory audits with consultations, the average number of consultations per audit is 1.5 for RV-accounting firms and 1.9 for OOB-accounting firms.

Figure 6: In 2024, the percentage of statutory audits with consultations varies among accounting firms Source: Data statutory audits RV- and OOB-accounting firms with request year 2024 for OOB-accounting firms and issuance year of audit report 2024 for RV-accounting firms.

OOB- and RV-accounting firms mostly consult on the same topics. Table 1 shows the top five consultation topics in 2024. The percentages indicate what percentage of the total number of consultations took place on a specific topic. For OOB-accounting firms, 16.1% of all consultations concern continuity, while for RV-accounting firms, 26.7% of all consultations concern the audit report. From this top five, it appears that accounting firms consult most often on the audit report, continuity, independence, fraud/corruption, and (complex) reporting issues.

9 Article 17 of the Decision on supervision of accounting firms.

14% 25% 40% 23% 38% 0% 5% 10% 15% 20% 25% 30% 35% 40% 45% RV: Small RV: Medium RV: Large OOB: Regular audits OOB: OOB audits

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Table 1: Top five consultation topics in 2024 are the same for OOB- and RV-accounting firms OOB-accounting firms RV-accounting firms 1 Continuity 16.1% Audit report 26.7% 2 Audit report 15.8% Independence 22.6% 3 Reporting 13.3% Continuity 9.0% 4 Fraud/corruption 11.3% Fraud/corruption 8.0% 5 Independence 10.4% Complex reporting issues 7.0% Source: Data statutory audits RV- and OOB-accounting firms with request year 2024 for OOB-accounting firms and issuance year of audit report 2024 for RV-accounting firms.

3.2 Technical support OOB-accounting firms devoted slightly more FTE to technical support and compliance in 2024 on average than in 2023. The average number of FTE for technical support rises from 56.7 in 2023 to 66.6 in 2024. The average number of FTE for compliance rises from 13.4 in 2023 to 14.9 in 2024. A caveat to this analysis is that the classification of FTEs may differ between accounting firms and financial years due to choices they make in categorization.

Small RV-accounting firms hire more technical support than large and medium RV-accounting firms. In addition to consultations, accounting firms can also (temporarily) hire personnel to provide technical support. Figure 7 shows the average number of FTE that RV-accounting firms hire for technical support over the period 2022 to 2024. On average, small RV-accounting firms hired 1.0 FTE of technical support in 2024, compared to 0.7 FTE in 2022. Large and medium RV-accounting firms hire less technical personnel: on average 0.2 FTE in the period from 2022 to 2024.

Figure 7: Small RV-accounting firms hire more technical support Source: Data RV-accounting firms based on financial year.

0 0,2 0,4 0,6 0,8 1 1,2 2022 2023 2024 Average number of FTE Large Medium Small

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The number of RV-accounting firms requesting technical support from NBA and SRA is increasing. In addition to hiring technical support, accounting firms can also make use of the services of the NBA and SRA. The percentage of RV-accounting firms that used technical support from the SRA increased from 45% in 2021 to 54% in 2024. The percentage of RV-accounting firms that used technical support from the NBA increased from 17% in 2021 to 20% in 2024.

3.3 Policy for root cause analyses The number of RV-accounting firms with written policy for conducting root cause analyses increases slightly, and this share is largest among large RV-accounting firms. Data from 2021 to 2024 shows that the percentage of RV-accounting firms with a written policy for root cause analyses increases slightly, from 29% in 2021 to 36% in 2024. Figure 8 shows the distribution of policy for root cause analyses among RV-accounting firms, split into written policy, policy not yet (formally) documented, and no policy. This shows that large RV-accounting firms have the largest share with a written policy for root cause analyses, namely 56%.

Figure 8: Large RV-accounting firms have the largest share of written policy for root cause analyses Source: Data RV-accounting firms (cumulative 2021-2024).

3.4 Independence threats The percentage of statutory audits in which RV-accounting firms identify at least one independence threat has remained stable at approximately 60% in the period 2022-2025. In the execution of statutory audits, independence from the audit client is required, and the accounting firm is responsible for taking measures to ensure this independent execution. 10 The external accountant identifies and assesses possible threats to independence and takes measures to limit these threats.11 In many cases, these measures are sufficient so that there are no impediments to performing the statutory audit. But in some situations, the independence threat is a reason to terminate or refuse the engagement. Figure 9 shows the percentage of statutory audits by RV-accounting firms with 0, 1, 2, or 3 identified independence threats over the period 2022 to 2025. This shows that the share of statutory audits with identified independence threats is stable, and

10 Article 19, Act on supervision of accounting firms. 11 Based on the Regulation on the independence of accountants in assurance engagements.

28% 28% 56% 45% 55% 39% 26% 17% 5% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Small Medium Large Yes, a written policy Yes, but the policy is not (formally) documented No

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that the percentage of statutory audits with two or more identified independence threats decreases, from 18% in 2022 to 14% in 2025.

Figure 9: Percentage of statutory audits with identified independence threats remains stable Source: Data statutory audits RV-accounting firms based on issuance date of audit report. Note: The data for 2025 are updated to mid-September.

Large and medium RV-accounting firms have the highest percentage of statutory audits with identified independence threats. Figure 10 shows the distribution of the number of identified independence threats at large, medium, and small RV-accounting firms. This shows that large and medium RV-accounting firms identify at least one independence threat in 64% and 60% of statutory audits, respectively. For small RV-accounting firms, this is lower at 44%.

Figure 10: Percentage of statutory audits with identified independence threats is highest at large and medium RV-accounting firms Source: Data statutory audits RV-accounting firms (cumulative 2022-2025). Note: The data for 2025 are updated to mid-September.

40% 40% 40% 39% 42% 44% 46% 47% 16% 15% 14% 14%