How it works for your bookkeeping firm
You open a case file in the client’s name, or import contacts through an integration. A Dutch legal entity fills in from the trade register. For a private limited company you record the structure with directors and shareholders, and see the UBOs at a glance.
You send the NOAB onboarding as a procedure. Your client goes through the steps in the client portal, in your firm’s house style, and everything they sign and fill in lands in their file automatically. You draw up your own engagement letter in the contract builder, and your client signs it in the same portal.
You screen the business and its owner for PEP status, sanctions, adverse media and insolvency. Each hit gets your verdict and counts towards the risk level. To start screening as soon as the client completes the onboarding, you set up a workflow that notifies you or assigns the file to the reviewer.
Before you approve, you see whether the client file is complete. If the client is a PEP, you also ask for the source declaration. A reviewer approves or rejects the file, and that decision is recorded straight away. You export the client file as a PDF.
After that the client stays current. The default workflows re-screen them on a fixed rhythm that follows their risk, and expiring documents are flagged in time. At the reassessment after one, two or three years, the client confirms their PEP status and sends a fresh Chamber of Commerce extract. Templates for bookkeeping firms are ready to use.
When the Wwft applies to your bookkeeping firm
If you keep the books for others on your own account, the Wwft, the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act, applies to you, even as a sole trader. Article 1a(4)(b) Wwft covers accountants and anyone who independently performs comparable work on a professional basis. If the firm also prepares tax returns, part (a) for tax advisers applies as well. According to the BFT guidance of 24 October 2024, what counts is the nature of the work, not the size of the firm.
The Financial Supervision Office (BFT) supervises these firms under Article 1d of the Wwft and sets out its expectations in its specific guidance for accountants, tax advisers, bookkeeping firms and the other institutions under parts (a) and (b). The NOAB is a trade association, not a supervisor. On 15 January 2026, however, the NOAB and the BFT agreed a supervision arrangement that folds Wwft supervision into the NOAB quality mark.
The BFT keeps finding the same shortcomings at bookkeeping firms. Its annual report for 2025 records breaches of the training duty (Article 35) in a large share of its full investigations, mostly at smaller firms, and breaches of risk policy in half of them. In a survey of around fifty bookkeeping firms, two thirds fell short on several duties, including identifying clients and drawing up Wwft procedures.
In RiskResolve, client due diligence already starts in the onboarding, where the client verifies their identity and fills in the PEP declaration. RiskResolve supports client due diligence per client and keeps a record of it. The firm’s own risk assessment and policy (Articles 2b and 2c), staff training and any report to FIU-the Netherlands remain the firm’s own work. To file a report, a bookkeeping firm must be registered with FIU-the Netherlands.
Questions from bookkeeping firms on the Wwft
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