What is Controleverklaring (Dutch Auditor's Report)?
Standaard 700.20 requires the auditor to form an opinion on whether the financial statements give a true and fair view (getrouw beeld) in accordance with the applicable reporting framework. The controleverklaring presents that opinion in a format the NBA prescribes. The opinion section and basis for the opinion come first. Subsequent sections address the elements that BW2 article 2:393(5) demands: whether the management report is consistent with the financial statements and whether it complies with BW2 Title 9.
What distinguishes the controleverklaring from an ISA 700 report is paragraph 29 of Standaard 700. The NBA added two mandatory sections in 2021 (effective for periods ending on or after 15 December 2022): "Controleaanpak frauderisico's" (audit approach to fraud risks) and "Controleaanpak continuïteit" (audit approach to going concern). Both require the auditor to describe specific procedures performed, not merely confirm that work took place. NBA Handreiking 1150 provides worked examples of the fraud section. The going concern section must explain how the auditor addressed the continuity assumption, including any events or conditions that cast significant doubt.
For OOB audits, Standaard 701 (the ISA 701 equivalent) adds key audit matters. Non-OOB controleverklaringen omit KAMs but must still include the fraud and continuity sections.
Key Points
- The controleverklaring follows a prescribed format under Standaard 700 that differs from the ISA 700 model through Dutch-specific fraud and going concern sections.
- Since FY2022, every statutory audit controleverklaring must include separate sections describing the auditor's approach to fraud risks and to continuity.
- BW2 article 2:393(5) requires the auditor to report on the consistency of the management report (bestuursverslag) with the financial statements.
- The AFM's January 2025 supervision report found insufficient fraud risk procedures in 17 of 20 non-OOB statutory audits reviewed.
Worked example: Bakker Industrial B.V.
Client: Dutch manufacturing company, FY2025, revenue €42M, IFRS reporter. The engagement team at a mid-size SRA-member firm is drafting the controleverklaring.
Step 1 — Form the opinion
The engagement partner reviews the completed file and concludes that the financial statements give a true and fair view under IFRS as adopted by the EU and Part 9 of Book 2 of the Dutch Civil Code. Standaard 700.20 requires an unmodified opinion when the financial statements comply in all material respects with the applicable framework. Bakker's inventory (€11.4M under IAS 2) and revenue from long-term contracts (€42M, recognised over time under IFRS 15) were the dominant audit areas.
Documentation note: record the basis for the unmodified opinion and the reporting framework applied. Identify the key audit areas and cross-reference to uncorrected misstatements (€0.18M total, below the €0.63M materiality threshold).
Step 2 — Draft the fraud risk section
Standaard 700.29B requires a separate section titled "Controleaanpak frauderisico's." The team describes two identified fraud risks: management override of controls (presumed under Standaard 240.31) and the risk that revenue on long-term contracts is accelerated through premature percentage-of-completion estimates. The section details the procedures performed: journal entry testing focused on manual top-side entries in December 2025, and independent recalculation of percentage-of-completion on the four largest contracts (covering €27.3M, or 65% of revenue) using project cost data verified against third-party supplier invoices.
Documentation note: record each identified fraud risk, the procedures performed in response, the contract sample selected, and the conclusions reached. Specificity matters: the fraud section must describe what the auditor did, not just that something was done.
Step 3 — Draft the going concern section
Standaard 700.29A requires a section titled "Controleaanpak continuïteit." Bakker has a €15M revolving credit facility with a covenant requiring a minimum interest coverage ratio of 3.0x; the year-end ratio stood at 3.4x. The team evaluated management's 12-month cash flow forecast and stress-tested the covenant under a 10% revenue decline scenario (ratio drops to 2.8x, breaching the threshold). Management provided a written representation that the lender agreed to a temporary waiver if revenue falls below €38M. No material uncertainty exists at the reporting date.
Documentation note: record the going concern indicators considered (covenant proximity), the stress-test results, the waiver evidence, and the conclusion. The continuity section must describe the auditor's approach even when the conclusion is favourable.
Step 4 — Include BW2-required reporting
BW2 article 2:393(5) requires the controleverklaring to address the management report (bestuursverslag). The team confirms the management report is consistent with the financial statements and contains no material misstatements. It also verifies that the report includes the information required by BW2 articles 2:391 and 2:392.
Documentation note: record the consistency assessment and the procedures performed on the management report. File the signed controleverklaring with the conclusion and the date of issue.
Conclusion: the controleverklaring contains an unmodified opinion and entity-specific fraud and continuity sections describing actual procedures, paired with the BW2 management report assessment. Each section links to documented work in the file.
Why it matters in practice
The NBA's 2024 analysis of FY2022 controleverklaringen found that many fraud sections used generic, template language rather than describing the specific fraud risks identified and the procedures performed in response. Standaard 700.29B requires the auditor to describe the audit approach to fraud risks with sufficient specificity that the section is meaningful to the reader. Boilerplate text that could apply to any audit fails this requirement.
The AFM's January 2025 supervision report identified insufficient fraud risk procedures in 17 of 20 non-OOB statutory audits. The deficiency sits upstream of the controleverklaring: if the procedures were inadequate, the fraud section either omits material information or describes work that lacked depth. Standaard 240.28–30 requires audit responses specifically linked to assessed fraud risks.
Practitioners sometimes omit the going concern section when no material uncertainty exists, treating it as conditional. Standaard 700.29A requires the "Controleaanpak continuïteit" section in every statutory audit controleverklaring regardless of outcome. The section describes the auditor's approach, not just the conclusion.
Controleverklaring vs. ISA 700 auditor's report
| Dimension | Controleverklaring (Standaard 700) | ISA 700 auditor's report |
|---|---|---|
| Fraud risk section | Mandatory for all statutory audits (Standaard 700.29B) | Not required; no ISA equivalent |
| Going concern section | Mandatory for all statutory audits (Standaard 700.29A) | Not required as a separate described-approach section |
| Management report reporting | Required by BW2 article 2:393(5): consistency, misstatements, and legal compliance | ISA 720 addresses other information but with a narrower reporting obligation |
| Key audit matters | Required for OOB audits only (Standaard 701) | Required for listed entities (ISA 701) |
| Legal framework reference | Must reference BW2 Title 9 or applicable Dutch/EU framework | References the applicable financial reporting framework without jurisdiction-specific legislation |
The distinction matters when a team accustomed to ISA 700 drafts a controleverklaring for the first time. Omitting the fraud or continuity section produces a non-compliant report, even if the underlying audit work was adequate.
Related terms
Frequently asked questions
How is a controleverklaring different from an ISA 700 auditor's report?
The controleverklaring follows Standaard 700, which mirrors ISA 700 but adds Dutch-specific requirements. The two mandatory sections on fraud risks and going concern (Standaard 700.29A–29B) have no ISA equivalent. BW2 article 2:393(5) also requires reporting on the management report's consistency with the financial statements, going beyond ISA 720's scope.
Do non-OOB audits need a fraud section in the controleverklaring?
Yes. Standaard 700.29B applies to all statutory audits in the Netherlands, regardless of OOB status. The NBA made this mandatory for reporting periods ending on or after 15 December 2022. Non-OOB controleverklaringen do not require key audit matters under Standaard 701, but the fraud and going concern sections are not optional.
Can the auditor issue a controleverklaring in English?
Standaard 700 does not prohibit an English-language report. When the financial statements are in English (common for IFRS reporters with international stakeholders), the controleverklaring may also be issued in English. The NBA provides model texts in both languages. For SBR filing with the Dutch Chamber of Commerce, a Dutch-language version is required.