NOW-1 Deadline postponed for accountant’s statement

The Dutch Ministry of Social Affairs and Employment (SZW) and the Royal Netherlands Institute of Chartered Accountants (NBA) have announced that the deadline for the NOW-1 accountant’s statement will be postponed to the 6th of February 2022. However, the NOW-requesting employer must still submit his or her application for final settlement (Dutch: aanvraag tot vaststelling) by the original deadline of 31st of October, even if the accountant’s report or third party statement is not ready.

These changes have been implemented in part to alleviate pressure off auditors who have the task of compiling the NOW statements. It has also been announced that there will be changes to the standard and protocols applicable to the NOW, after complaints of unnecessary complexity for the auditor.

Group definition

The alteration of the NOW audit protocol also removes certain barriers in completing the application for final settlement, especially pertaining to the group definition in context of the NOW scheme. This group definition may lead to extensive auditing procedures in case of a complex international group.

In case the auditor cannot perform the audit in its entirety due to complexity of the corporate structure, the auditor can now give a so-called ‘disclaimer of opinion with inherent limitations’ on the NOW statement. This will not lead to full recovery of the subsidy, but rather a deduction of 10% of the total subsidy.

Further NOW tranches

While the deadline for submission of the application for final settlement remains unchanged for the 2nd tranche of the NOW, the deadlines for the 3rd up until and including the 6th tranche of the NOW have all been changed to the 23rd of February 2023. These changes may also lead to a decrease in costs for NOW-requesting companies, as a number of NOW tranches may be combined, which results in less work for the auditor.