Key Points
- The Wta requires every firm performing statutory audits in the Netherlands to hold an AFM licence, either a regular licence or an OOB (public interest entity) licence.
- As of 2024, the AFM register lists 13 OOB licence holders and approximately 275 regular licence holders.
- The Wijzigingswet accountancysector, adopted in October 2025 with entry into force targeted for 1 July 2026, expands AFM enforcement powers over non-OOB firms.
- Firms that fail to meet Wta quality requirements risk licence withdrawal, which prohibits them from signing any statutory audit report.
What is the Wta?
The Wta created a two-tier licensing regime. OOB licence holders (firms auditing listed companies, banks, and insurers) face direct AFM supervision with the full force of EU Regulation 537/2014 layered on top. Regular licence holders (firms performing statutory audits of non-PIE entities) operate under the same Wta quality framework but historically faced lighter AFM oversight, with the NBA and SRA conducting peer reviews on the AFM's behalf.
Wta article 14 requires every licence holder to maintain a system of quality management that meets the standards set by the Bta. The Bta translates ISQM 1 requirements into binding Dutch regulation, covering acceptance and continuance, engagement performance, monitoring, and ethical conduct. Wta article 15 mandates a compliance officer for OOB firms. Article 22 gives the AFM power to withdraw a licence when a firm structurally fails to meet quality requirements.
The Wijzigingswet accountancysector, adopted by the Tweede Kamer on 23 September 2025 and by the Eerste Kamer on 7 October 2025, changes this architecture. AFM supervision of non-OOB firms becomes direct rather than delegated. Large non-OOB firms (those with at least EUR 3 million in statutory audit revenue and at least 150 statutory audits per year for three consecutive years) must establish a supervisory body. The AFM gains new enforcement tools, including the power to impose administrative fines for non-compliance with audit quality indicator reporting obligations. Entry into force is targeted for 1 July 2026.
Worked example: Van der Berg Logistics B.V.
Client: Dutch transport and logistics company, FY2025, revenue EUR 19M, Dutch GAAP (RJ) reporter. Van der Berg's statutory audit is performed by a 20-person firm in Rotterdam that holds a regular Wta licence.
Step 1 — Verify licence status
The engagement partner confirms the firm's regular Wta licence is active in the AFM register before signing the engagement letter. The firm does not audit any OOB clients and therefore holds only the regular licence. The partner also confirms that no AFM enforcement measures are pending against the firm.
Step 2 — Apply Wta quality requirements to the engagement
The firm's quality management system, designed to comply with Bta requirements (which incorporate ISQM 1), requires a risk assessment for every statutory audit. The engagement partner identifies two quality risks for Van der Berg: high volume of cash transactions in the logistics sector (relevant to Wwft obligations that intersect with Wta article 25) and a recent change in the entity's ownership structure that requires updated independence checks under the Wta's ethical provisions.
Step 3 — Comply with reporting obligations
After completing the audit, the firm files the required data with the AFM through the annual compliance report. This includes the number of statutory audits performed, the hours spent per engagement category, and (under the incoming Wijzigingswet) the firm's audit quality indicators. The compliance officer reviews the submission for completeness.
Conclusion: the engagement file demonstrates compliance with both Wta licensing requirements and the Bta quality framework, defensible because the licence verification, quality risk assessment, independence evaluation, and regulatory reporting form a documented chain from engagement acceptance through post-audit filing.
Why it matters in practice
The AFM's 2025 Sector in Beeld report found that only 28% of medium and smaller regular licence holders had written policies for structural evaluation of audit quality findings, compared to 56% of large firms. The Wta and Bta require all licence holders to maintain a functioning quality management system. Firms that treat quality management as a paper exercise rather than an operational process expose themselves to enforcement action, particularly as the Wijzigingswet brings non-OOB firms under direct AFM supervision.
Regular licence holders frequently underestimate the Wta's reporting obligations. Wta article 26 requires firms to notify the AFM of material incidents and identified defects in statutory audits. The Wijzigingswet lowers the threshold for this notification obligation. Firms that wait for the AFM to discover problems during an inspection rather than self-reporting face more severe enforcement outcomes.
Wta vs. Wet op het accountantsberoep (Wab)
| Dimension | Wta | Wab |
|---|---|---|
| Scope | Audit firms performing statutory audits | Individual accountants (RA and AA title holders) |
| Regulator | AFM | NBA (professional body) with oversight from the Ministry of Finance |
| Primary focus | Firm-level licensing, quality management, and public oversight | Individual registration, professional competence, CPE requirements, and disciplinary regime |
| Enforcement | AFM can withdraw the firm's licence, impose fines, issue instructions | NBA can impose disciplinary measures; the Accountantskamer handles complaints under the Wet tuchtrechtspraak accountants |
The distinction matters because the Wta regulates the firm while the Wab regulates the individual. A firm can hold a valid Wta licence while an individual partner faces Wab disciplinary proceedings, and vice versa. The Wijzigingswet amends both laws simultaneously, recognising that firm-level quality and individual competence are interdependent.
Related terms
Frequently asked questions
What is the difference between an OOB licence and a regular Wta licence?
An OOB licence permits the firm to audit public interest entities (listed companies, banks, insurers, and pension funds). A regular licence permits statutory audits of all other entities. OOB licence holders face additional requirements under EU Regulation 537/2014, including mandatory firm rotation and a cooling-off period. Wta article 5 defines the licence categories.
What happens if an audit firm loses its Wta licence?
The firm can no longer sign statutory audit reports in the Netherlands. Wta article 22 gives the AFM the power to withdraw a licence when a firm fails to meet quality requirements. Existing audit engagements must be transferred to a licensed firm. The AFM publishes the withdrawal decision, which makes the loss of licence public information.
Does the Wta apply to review and compilation engagements?
No. The Wta applies only to wettelijke controles (statutory audits) as defined in article 1 of the Wta. Review engagements under NV COS 2400 and compilation engagements fall outside the Wta's scope, though the performing accountant remains subject to NBA professional regulations and the Wet op het accountantsberoep (Wab).