An owner-manager is preparing a refinancing. The valuation is difficult, the forecast is optimistic, and the bank wants signed accounts by Friday. Management sees a technical loose end. The audit team sees evidence that needs more work. Nobody wants to delay the deal.
That room is where audit responsibility becomes real. The pressure sits in the hours before the signature, when someone must challenge an assumption, request another document or escalate an unresolved point.
In April, the AFM explained that the Accountancy Sector Amendment Act clarifies that responsibility for statutory-audit quality can also rest with the audit firm through its quality-management system. Parliament has adopted the law, but its commencement date remains undecided. The AFM expects implementation to move towards 1 January 2027.
The direction is clear enough for daily business. Responsibility no longer ends comfortably at the partner’s signature. The signature still matters. So do the staffing, challenge, consultation, review and escalation behind it.
The signature is only the visible edge
When a difficult judgment becomes a dispute, the polished annual report rarely settles much. Attention travels backwards through the work. What did the engagement cover? Which information was available? Who challenged the assumptions? Was conflicting evidence followed up? Did somebody warn management, and what happened after that?
Dutch case law shows how practical these questions become. In ECLI:NL:GHARL:2026:3095, the Arnhem-Leeuwarden Court of Appeal applied the standard of care expected from a reasonably competent and reasonably acting professional colleague. The case concerned subsidy advice rather than a statutory audit. Its working logic is familiar: scope, professional care, warning, causation and loss shape the outcome.
That is why a file should capture more than its final conclusion. A decision without its reasoning can look fragile years later. A sensible telephone call, left out of the record, gives little support when memories differ and money has already been lost.
A review can comply and still miss the weakness
The AFM gave this issue sharper form on 9 July 2026. Six investigated public-interest-entity audit firms had carried out internal quality reviews in line with legal requirements. The regulator still wanted more unpredictability and representativeness in the selection of completed audit files.
That distinction matters. A review programme may meet the basic rules while repeatedly looking where everyone expects it to look. If teams know which engagements are likely to be selected, or reviewers concentrate on large and obvious risks, quieter weaknesses can remain untouched.
Small professional firms face their own version of this pressure. A close partner may know every client and employee. That familiarity can be valuable. It can also make independent challenge harder when the same trusted people have worked together for years.
The ordinary repeat client may then receive less scrutiny than the visibly difficult assignment. A useful review is the one that finds something inconvenient before a client, lender, regulator or court finds it later.
Personal exposure depends on more than a title
The word partner carries different legal meanings. Legal form, contracting party, engagement terms, actual role and the basis of a claim all shape the position.
A 2018 judgment, ECLI:NL:GHSHE:2018:472, shows why structure matters. The ’s-Hertogenbosch Court of Appeal dealt with work performed through a maatschap. It held that a maatschap has no legal personality and that Article 7:407(2) of the Dutch Civil Code can make each partner liable to the client for the whole obligation arising from the assignment. That exposure could continue after departure from the maatschap.
The governance lesson reaches beyond that legal structure. The name on the door, the entity named in the engagement letter and the people who perform the work should tell a consistent story. When they do not, uncertainty usually appears when the file is already under pressure.
The cost begins before damages are decided. Partner time disappears into reconstruction, insurer discussions and legal support. Client work slows. Records must be preserved and explained. A professional dispute can become a cash and capacity problem long before a court reaches its outcome.
What the owner-manager can see early
Return to the refinancing meeting. The founder cannot inspect the audit firm’s entire quality system. Some signals are visible, however. Difficult questions should surface before the final deadline. Requests for evidence should connect clearly to material judgments. Unresolved points should have an owner, an escalation route and a recorded conclusion.
The same discipline belongs inside the company. A clean audit opinion does not replace management’s own controls. Forecasts still need support. Valuations need assumptions. Related-party transactions need clarity. Important decisions should not depend on one private inbox or somebody’s memory of a telephone call.
A useful governance check is modest. Read the engagement letter as part of the working relationship, rather than as drawer material. Notice who is contracting, what falls within scope, how concerns are reported and what happens when evidence remains weak.
For professional firms, an occasional review of an ordinary completed engagement may reveal more than another examination of the obvious flagship risk. Audit disputes look dramatic when they reach named partners. Their beginnings are usually quieter: a deadline, an assumption, an unanswered question, or a review that looked elsewhere.
Responsibility is easier to locate when those moments were challenged and recorded while the work was still alive. That is professional care made visible.
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The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
