Introduction
The role of the Compliance Officer (CO) within accounting firms is relatively young in the Netherlands. It gained prominence with the introduction of the Wta (the Dutch Audit Firms Supervision Act) and continues to evolve. While the Three Lines of Defence model is widely accepted in the financial sector, its application within accountancy remains at an early stage. The compliance function typically fulfills a dual role: on the one hand, supporting the practice and operating close to the first line; on the other, monitoring and controlling, with an orientation toward the third line. In my observation, a genuine third line is largely absent in practice.
(Note: I do not address Public Interest Entities (PIEs). Everything I write pertains to non-PIE accounting firms, including firms without a Wta license.)
In this series of articles, I describe what compliance means in accounting practice, the role risk management plays in this context, and how both functions can be effectively integrated within a governance and risk management framework. Central to my view is that the Compliance Officer should report and advise broadly — both upon request and proactively — based on the organization’s objectives, the risks that threaten those objectives, and insights derived from audits, investigations, assessments, and, in practice, anything that comes to the CO’s attention. The interaction between compliance and risk management is a key theme throughout this series, as is the question of the appropriate degree of functional separation between the two.
Contents
(Please note: the table of contents below will consist of links to individual chapters once they have been written. Until then, some links will not yet be clickable.)
- Compliance: Judo with Risks
- Compliance in Accountancy
- Accounting Firms and RV-Regulated Practices
- The Regulatory Jungle
- Roles and Responsibilities
- Culture and Governance: The Playing Field of Compliance
- Risk Analysis and Risk Control
- Accountability and Oversight
- Quality and the Public Interest
- Practice Areas: Compilation, Tax, and Payroll
- Practice Areas: Advisory and Valuation
- Specific Duties and Special Obligations
- Internal Reporting and Integrity Systems
My Essay 