NOW subsidy audit statement

Audit requirements regarding the Temporary Emergency Bridging Measure for Sustained Employment (Tijdelijke Noodmaatregel Overbrugging voor Werkbehoud NOW).

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”As a result of the pandemic, we provide accounting and auditing services pertaining to the NOW subsidy regulation.”

On 4 September 2020, the NBA (the professional body for accountants in the Netherlands) issued the accountant’s protocol for statements on the final settlement (vaststelling) of the Temporary Emergency Bridging Measure for Sustained Employment (NOW1).

Companies that have applied for this subsidy (NOW-1), can submit a confirmation request in form of a statement for their final settlement until 31 October 2021 (extended deadline for all statements). Please refer to the information below for more explanation.

The Minister of Social Affairs in the Netherlands announced in which cases a company that applied for a subsidy under NOW1 needs an actual auditor’s opinion and which requirements then apply.


First of all, it must be noted that the requirements vary, depending on whether a compulsory audit requirement applies to the company. Furthermore, it depends on the subsidy amount applied for.

No audit requirement

Companies that have received less than € 20,000 as an advance payment or whose final settlement is less than € 25,000, do not have to file an accountant’s statement. The UWV (Employee Insurance Agency) will perform random checks. Most smaller companies will fall under this regime (90,000 companies applied for a subsidy of less than € 20,000).

Third-party statement

If a company has received an advance subsidy between € 20,000 and € 100,000 or whose final settlement is € 25,000 – € 125,000, a third-party statement is sufficient. This may be a statement from an accountant, but also from a bookkeeper or tax advisor.

Accountants’ products

However, more stringent requirements have been defined for companies that have received larger amounts in subsidy, i.e. the required intensity of the audit procedures varies. The following matrix describes which accountants’ products are required:

NOW Table


Please note that the requirement of an assurance engagement with a reasonable level of assurance (Standard 3900N) also applies to subsidiaries; this is the most stringent protocol.

Accountant’s protocol
The Ministry and the NBA have set up a protocol with requirements for the audit procedures for each of the four quadrants.


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