How to Prepare for an NBA Quality Review at Your Dutch Audit Firm

Q: What happens if your firm fails the NBA quality review?

If your firm receives a 'voldoet niet' (does not meet requirements) outcome, the Raad requires you to submit an improvement plan addressing every deficiency with specific actions and timelines. A re-review (hertoetsing) 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.

Key takeaways

The NBA's Raad voor Toezicht selects and reviews firms under the NVKS using data from the annual monitoring questionnaire combined with a risk analysis, and the new "toezicht op nieuwe leest" framework adds a mid-cycle development conversation.
The orientation questionnaire forms the basis for the reviewer's preparation and determines which files they inspect. Treat it as a diagnostic, not an administrative chore.
Recurring deficiencies cluster around the annual quality system evaluation (NVKS requirement), documentation of professional judgment, and gaps between the kantoorhandboek and actual practice.
If you receive a B-rating ("voldoet niet"), you must submit an improvement plan and undergo re-review. Re-reviews in 2024 had an 86% pass rate.

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, conduct it superficially, or fail to involve an external accountant in the discussion.

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, and revenue. 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. In 2023, the total was 288. Year-to-year variation in both volume and pass rates (76% in 2024, 64% in 2023, 74% in 2022) reflects differences in the selected population rather than a structural quality trend, according to the Raad.

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.

This is a point many firms miss: if your handbook sets requirements that go beyond what the NVKS demands, the reviewer will hold you to those higher standards. Before the review, read your own handbook with fresh eyes and remove anything you don't actually follow. A handbook that promises what the firm doesn't deliver is worse than a minimal handbook that matches reality.

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.

Start preparation early

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. Designate one partner as the review coordinator who reads the kantoorhandboek, identifies gaps between documented policy and actual practice, and ensures the files most likely to be inspected are internally reviewed.

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.

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.

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. The end of the day brings the recapitulation discussion, where the reviewers present their findings and preliminary recommendation. 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.

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, do it without sufficient depth, or don't discuss it with an external accountant as the NVKS requires. Related to this, the Raad finds that firms' own annual accounts sometimes fail to meet publication requirements (publicatieplicht).

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 tick-box rather than a considered assessment that references the client's specific circumstances.

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. Sanctions ranged from reprimands to temporary removal from the register.

What happens when you don't pass

If the reviewers identify deficiencies significant enough to warrant a "voldoet niet" (does not meet requirements) 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.

Re-reviews in 2024 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.

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.

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, voluntary audits, and a small number of agreed-upon procedure engagements. It was last reviewed in 2019 and receives notification in January 2026.

1. Self-assessment (January)

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. File the 2024 evaluation report, the notes from the external discussion, and the action points that resulted. Schedule the 2025 evaluation for February.

2. Handbook review (February)

The practice manager reads the kantoorhandboek cover to cover. She finds that the acceptance policy requires a Wwft risk assessment for every new client, but three clients accepted in 2024 have no completed Wwft form. She also finds that the handbook requires an OKB for all audit engagements above €50,000 in fees, which exceeds the NVKS requirement. Either complete the missing forms retroactively or adjust the handbook to match actual practice.

3. File preparation (March)

The team selects four files that the reviewer is likely to inspect and reviews them against the firm's own documented standards. The voluntary audit file is missing a documented rationale for the materiality benchmark. One compilation file lacks the required NV COS 4410 representation letter. Add the materiality rationale with a clear date stamp showing retrospective addition. Document these findings in the pre-review self-check.

4. Review day (April)

The reviewer arrives at 9:00. The managing partner walks through the orientation questionnaire, highlights the annual evaluations and the actions taken from the self-check. The review concludes with a pass and two recommendations.

Preparation checklist

Verify that your last two annual quality evaluations are documented, include specific findings and actions, and were discussed with an external accountant (NVKS requirement).
Read your kantoorhandboek and flag any policy that your firm doesn't actually follow. Remove it or start following it.
Check publication requirements for the firm's own annual accounts and for partners' personal BVs.
Complete a self-review of the files most likely to be inspected: recent completions across each engagement type.
Prepare a brief digital file walkthrough document for the reviewer.
Run through the orientation questionnaire as if it were a diagnostic. Any question you cannot answer points to a preparation gap.

Common mistakes

Conducting the NVKS annual evaluation only before a review. The Raad can detect this from date stamps in the documentation. The 2023 report flagged insufficient or absent annual evaluations as the single most recurring system-level deficiency.
Setting quality standards 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 low-priority. This questionnaire drives the Raad's risk analysis, the selection of reviewers, and the scope of the review day.

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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.