Most NBA quality reviews fail on the same three files the partner already knew were weak. They just hoped the review wouldn’t sample them. The letter arrives in January. Your firm has been selected for a toetsing by the Raad voor Toezicht. You have a few months to get your quality management system, your files, and your people ready. According to the Raad voor Toezicht’s 2024 annual report, 76% of reviewed firms passed. That means nearly one in four did not.
A Nederlandse Beroepsorganisatie van Accountants (NBA) quality review (toetsing) assesses the design and operation of your firm’s quality management system under the NVKS, covering engagement acceptance through documentation, and results in either a pass (“voldoet”) or a requirement to submit an improvement plan and undergo re-review.
Key takeaways
- How the NBA’s Raad voor Toezicht selects and reviews firms under the NVKS, and what “toezicht op nieuwe leest” changes in that cycle
- How to prepare your orientation questionnaire so the review team arrives with the right expectations (NVKS Section 2)
- Which recurring deficiencies the Raad flags most often, and how to check for them before the reviewer does
- What happens if you receive a B-rating and how the improvement plan and re-review process works
What the NBA quality review actually assesses
The toetsing is not a file-by-file audit inspection. The Raad voor Toezicht assesses your firm’s quality management system (stelsel van kwaliteitsbeheersing) under the Nadere Voorschriften Kwaliteitssystemen (NVKS). That system covers firm-level policies, engagement acceptance and continuance, human resource competency, and engagement performance.
The reviewer checks three things: whether the system exists on paper, whether it exists in practice, and whether it actually works when tested against your completed files. These are the three assessment levels the NVKS uses (opzet, bestaan, and werking), and a failure at any level results in findings.
Under the NVKS, every firm must conduct an annual self-evaluation of its quality system and discuss the results with an external accountant. The Raad voor Toezicht’s 2023 report noted that this annual evaluation is one of the most common areas where firms fall short. Firms either skip it entirely or conduct it superficially without involving an external accountant in the discussion. Since the NVKS introduced this requirement, the Raad asks about it explicitly in the monitoring questionnaire. A firm that has never documented an annual evaluation has a problem that cannot be fixed in the weeks before a review, because the Raad will look at multiple years of documentation.
At the file level, reviewers select completed engagements and test whether the quality system produced the expected documentation, judgments, and conclusions. A firm can have an excellent handbook but poor execution in files. Solid files that happen to match no documented policy also fail. The system and the files must tell the same story.
How firms are selected and what the new cycle looks like
Every October, the NBA asks all accounting practices to complete the annual monitoring questionnaire (monitoringvragenlijst). This questionnaire collects information about the firm’s size, the types of engagements it performs, the number of accountants employed, the revenue booked, and the client-acceptance process in place. The Raad uses this data, combined with a risk analysis, to select firms for review. Firms receive notification at the beginning of the calendar year if they have been selected. You can request a temporary exemption within four weeks of notification, but the exemption lasts a maximum of one year.
The traditional cycle runs every six years. Under the new “toezicht op nieuwe leest” framework, the Raad has added a mid-cycle development conversation (ontwikkelingsgesprek) in the third year. This conversation lasts two to four hours and is intended as a coaching session, not a formal assessment. Whoever leads the development conversation will typically also lead the formal review three years later. The Raad introduced this because its own analysis showed that some firms only engage with their quality system when the review notification arrives, then revert to what one commentator called “hangmatmodus” for the remaining years. The development conversation is designed to break that cycle by creating a touchpoint between reviews. It is not graded, but the team leader forms impressions that carry forward to the formal review.
The SRA is accredited by the Raad to conduct reviews in the NBA domain. In 2024, the Raad and SRA together reviewed 183 firms (of which the Raad conducted the majority and the SRA handled a smaller portion). In 2023, the total was 288, a much larger cohort. Year-to-year variation in both volume and pass rates (76% in 2024, down from 64% in 2023) reflects differences in the selected population rather than a structural quality trend, according to the Raad. These numbers cover non-statutory work only. Statutory audit quality falls under the AFM’s jurisdiction.
Preparing your quality management system documentation
Your kantoorhandboek (office manual) is the reference document for the entire review. The reviewer assesses your quality system against the norms you yourself have documented.
The NVKS requires documented policies on engagement acceptance and continuance, human resources and competency, engagement performance, and monitoring (including the annual evaluation). For each of these areas, the reviewer expects to find not just a policy statement but evidence that the policy operates in practice. An acceptance policy that requires a risk assessment form for every new client is useless if half your acceptance files contain no completed form. And the reviewer will not check just the files you present; the selection is the reviewer’s decision, not yours.
Start preparation six months before the expected review date, not when the notification arrives. The annual evaluation required under the NVKS should be a genuine annual exercise, not a pre-review scramble. If you have never documented an annual evaluation, or have conducted them without documenting the outcomes and actions taken, that gap will be visible to the reviewer regardless of what you produce in the weeks before the review.
A practical preparation approach: designate one partner as the review coordinator. That person reads the kantoorhandboek, identifies gaps between documented policy and actual practice, commissions the annual evaluation if it has not been done, and ensures the files most likely to be inspected are internally reviewed. In our experience, firms that treat preparation as a firm-wide project rather than a last-minute individual effort fare better.
The orientation questionnaire: where most preparation time should go
Once selected, your firm must complete the orientation questionnaire (oriënterende vragenlijst). This questionnaire covers general information, fundamental principles, staff competency, engagement acceptance and continuance, planning, execution, use of experts, and documentation. It forms the basis for the reviewer’s preparation and determines which types of files they will inspect.
Treat this questionnaire as a diagnostic, not an administrative chore. Each question maps to a NVKS requirement. If you cannot answer a question convincingly, you have found a gap before the reviewer does. Service organisations like Auxilium, Novak, Fiscount, and Extendum all offer pre-review support built around walking firms through this questionnaire systematically.
The questionnaire also determines reviewer assignment. The Raad matches reviewers to firms based on the types of engagements reported. A firm performing statutory audits under the Wta will receive a reviewer with audit experience. A firm focused on compilation engagements under NV COS 4410 will receive someone with that background. Accurate completion of the questionnaire ensures the right match, which makes the review day more productive for both sides.
If your firm has changed the types of engagements it performs since the last review (for example, adding voluntary audit work or dropping agreed-upon procedures), make sure the questionnaire reflects current operations. A mismatch between reported engagement types and actual files creates confusion at the review stage and wastes everyone’s time.
What reviewers look at in your files
The reviewer typically arrives at 9:00 AM on the review day. After discussing the orientation questionnaire with the firm’s policy maker (beleidsbepaler), the team moves to file inspection. Depending on the firm’s size and engagement types, the review takes one day or occasionally two.
Reviewers check whether files contain the documentation your quality system says they should contain. For audit engagements, that means engagement letters, risk assessments, materiality calculations, work programmes, and conclusions. For compilation engagements under NV COS 4410 (and Handreiking 1136), reviewers check whether the required elements are present and whether the accountant documented the basis for any judgments made. Most accountancy regulation in the Netherlands is principle-based, which means firms have latitude in how they meet requirements. But that latitude cuts both ways: the reviewer decides whether your interpretation holds up.
A practical point that experienced reviewers emphasise: make your files navigable. If your firm uses digital file management, prepare a brief walkthrough for the reviewer at the start of the day. Reviewers who spend twenty minutes locating documents in an unfamiliar system will form an impression of your file organisation that colours everything they see afterward.
Be available throughout the day. Walk in periodically to check whether the reviewers need clarification on anything. The end of the day brings the recapitulation discussion, where the reviewers present their findings and preliminary recommendation. If the findings are limited to recommendations (aanbevelingen), the preliminary outcome is typically a pass. If findings include formal notices (aanwijzingen), the outcome will likely require an improvement plan.
One critical nuance: the Raad voor Toezicht gives the final verdict, not the reviewers. The on-site team proposes an outcome, but the Raad can override it. If reviewers offer well-intentioned recommendations that aren’t genuine deficiencies, you can politely request that those observations stay verbal rather than entering the written report. Once something is in the documentation, the Raad may interpret it differently than the reviewer intended.
Recurring deficiencies the Raad keeps finding
The Raad’s annual reports consistently identify the same categories of deficiency. At the system level, the most frequent issue is the annual quality system evaluation. Firms either don’t do it or do it without sufficient depth and without discussing it with an external accountant as the NVKS requires. Related to this, the Raad finds that firms’ own annual accounts (or the annual accounts of partners’ personal BVs) sometimes fail to meet publication requirements (publicatieplicht), which reviewers check as part of the general compliance assessment.
At the file level, deficiencies cluster around documentation of professional judgment. The file shows what was done but not why. Engagement acceptance forms are signed but contain no risk assessment. Materiality is calculated but the benchmark choice is not explained. Going concern is addressed with a ticking and bashing pass rather than a considered assessment that references the client’s specific circumstances. Nobody looks forward to a quality review, but the firms that pretend to be surprised by the findings are the ones that have been ignoring them all along. For compilation engagements, the most common gap is incomplete or missing representation letters under NV COS 4410 . The reviewer pulls the exact file you hoped they would not: the one where the senior called TGIF at 11 pm, signed off on a recon that finally balanced, and never documented the three out-of-scope adjustments that got it there.
The Raad noted in its 2024 report that it filed ten disciplinary complaints with the Accountantskamer in Zwolle, eight of which related to firms with structurally inadequate quality systems. Two complaints involved refusal to cooperate with the review process. The Accountantskamer ruled in seven cases, six of which were found to be substantiated. Sanctions ranged from reprimands to temporary removal from the register. These are not theoretical consequences.
What happens when you don’t pass
If the reviewers identify deficiencies significant enough to warrant an “does not meet requirements” (voldoet niet) outcome, the Raad requires you to submit an improvement plan. This plan must address every identified deficiency with specific actions and timelines. The Raad reviews the plan and, if accepted, schedules a re-review (hertoetsing), typically twelve months later.
The Raad’s 2024 annual report shows re-reviews had an 86% pass rate, up from 74% in 2023. That means roughly one in seven firms that failed the first review also failed the re-review.
If the re-review still produces a negative result, the Raad can advise the NBA board to file a disciplinary complaint with the Accountantskamer. The Accountantskamer’s sanctions can include reprimands, fines, conditional or unconditional temporary deregistration, and permanent removal from the register. Four accountants appealed Accountantskamer rulings to the College van Beroep voor het bedrijfsleven (CBb) in the 2024 reporting period.
There is a faster path for minor deficiencies. When a reviewer identifies issues that can be corrected within three months, the reviewer can propose a continued review (voortgezette toetsing). If you accept this proposal and fix the issues within three months, the review can still conclude with a pass. This avoids the cost and time of a formal improvement plan and re-review. The decision to offer this option sits with the reviewer, and the Raad can still override it.
Worked example: Van Dijk Accountants prepares for review
Scenario: Van Dijk Accountants B.V. is a four-partner firm in Amersfoort with €1.8M annual revenue. The firm performs compilation engagements and voluntary audits, with a small number of agreed-upon procedure engagements layered on top. It was last reviewed in 2019 and receives notification in January 2026.
Self-assessment (January, immediately after notification)
The managing partner pulls the 2024 and 2025 annual quality evaluations. The 2024 evaluation was conducted in November 2024 and discussed with an external RA from a neighbouring firm. The 2025 evaluation has not yet been completed.
Documentation note: file the 2024 evaluation report, the notes from the external discussion, and the action points that resulted. Schedule the 2025 evaluation for February, before the orientation questionnaire is due.
Handbook review (February)
The practice manager reads the kantoorhandboek cover to cover. She finds that the acceptance policy requires a money-laundering risk assessment (Wwft) for every new client, but three clients accepted in 2024 have no completed Wwft form. She also finds that the handbook requires an OKB (opdrachtgerichte kwaliteitsbeoordeling) for all audit engagements above €50,000 in fees, which exceeds the NVKS requirement.
Documentation note: either complete the missing Wwft forms retroactively (with a documented explanation of the delay) or adjust the handbook to match actual practice. For the OKB threshold, decide whether to keep the higher standard and ensure all qualifying files have a completed OKB, or lower the threshold to match the regulatory minimum.
File preparation (March)
The team selects four files that the reviewer is likely to inspect (two compilations and one voluntary audit, plus one agreed-upon procedures engagement) and reviews them against the firm’s own documented standards. The voluntary audit file is missing a documented rationale for the materiality benchmark. The compilation files are complete but one lacks the required NV COS 4410 representation letter.
Documentation note: add the materiality rationale to the audit file with a clear date stamp showing it was added retrospectively. Obtain the representation letter for the compilation file. Document these findings in the pre-review self-check so they are part of the quality system’s monitoring function, not ad hoc fixes.
Review day (April)
At 9:00, the reviewer arrives. The managing partner walks through the orientation questionnaire, highlights the annual evaluations and the actions taken from the self-check. File inspection follows, and the reviewer asks about the retrospective materiality documentation. The review concludes with a pass and two recommendations.
Preparation checklist
Common mistakes
- Conducting the NVKS annual evaluation only in the weeks before a review, which the Raad can detect from the date stamps in the documentation. The Raad voor Toezicht’s 2023 report flagged insufficient or absent annual evaluations as the single most recurring system-level deficiency.
- Setting quality standards in the kantoorhandboek that exceed regulatory requirements and then failing to meet them. The reviewer uses your own handbook as the benchmark, not the regulatory minimum.
- Treating the monitoring questionnaire as a low-priority administrative task. This questionnaire drives the Raad’s risk analysis and determines both the selection of reviewers and the scope of the review day. Inaccurate or incomplete responses create problems before the reviewer arrives.
Related content
- Glossary: NVKS (Nadere Voorschriften Kwaliteitssystemen). Explains the quality system framework that forms the basis for every NBA quality review.
- ISA 320 Materiality Calculator. Document your materiality determination with industry benchmarks and ISA 320 paragraph references for NBA quality review readiness.
- ISQM 1 practical implementation for mid-tier firms. Covers the international standard underlying the NVKS requirements.
Related tools and reading
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Frequently asked questions
What does the NBA quality review (toetsing) actually assess?
The NBA quality review assesses your firm's quality management system under the NVKS. The reviewer checks three levels: whether the system exists on paper (opzet), whether it exists in practice (bestaan), and whether it actually works when tested against completed files (werking). A failure at any level results in findings.
How often are Dutch audit firms selected for an NBA quality review?
The traditional review cycle runs every six years. Under the new "toezicht op nieuwe leest" framework, the Raad voor Toezicht has added a mid-cycle development conversation in the third year. Firms are selected based on data from the annual monitoring questionnaire combined with a risk analysis.
What happens if your firm fails the NBA quality review?
If your firm receives a "voldoet niet" outcome, the Raad requires you to submit an improvement plan addressing every deficiency. A re-review is scheduled approximately twelve months later. In 2024, re-reviews had an 86% pass rate. Firms that fail the re-review may face disciplinary complaints with the Accountantskamer.
What is the most common deficiency found during NBA quality reviews?
The most frequently recurring system-level deficiency is the annual quality system evaluation required under the NVKS. Firms either skip it entirely, conduct it without sufficient depth, or fail to discuss it with an external accountant as required. At the file level, deficiencies cluster around documentation of professional judgment.
Further reading and source references
- Raad voor Toezicht Annual Report 2024: Published pass rates (76% in 2024), recurring deficiencies, and disciplinary complaint statistics.
- NVKS (Nadere Voorschriften Kwaliteitssystemen): The quality system framework that forms the basis for every NBA quality review.
- NV COS 4410 : The Dutch standard for compilation engagements, frequently referenced during file inspections.
- Handreiking 1136: Practice note providing additional guidance on applying NV COS 4410 in Dutch practice.