Dutch notaries are getting earlier proof requests in more transactions. On 6 May 2026, the Bureau Financieel Toezicht set out a tighter read on office money, procedures, integrity, and internal control. Small firms may now need cleaner files before a BV transfer, refinancing, property deal, or share sale.
Why this matters
For founders, owners, advisers, and managers, the notary turns a deal into a binding file. A deed can form a BV, move shares, change articles, or close a property transfer. If the shareholder register is stale or payment approval is unclear, the notary may stop and ask for more proof. That can delay cash, signatures, staff work, tax records, and planning.
Example
A BV share transfer is ready. Buyer, seller, adviser, and notary want to sign. Then the file shows gaps: an old shareholder register and an unsigned board decision. Part of the price comes through a holding company and a family loan. The notary asks for source of funds, authority, ID evidence, and a clean payment route. The deal may be fine. The file is not ready.
XTROVERSO tips
- Check the shareholder register before signing. Match the register with the deeds and current company records. KVK says the board stays responsible for accuracy.
- Build one pre-notary file. Keep incorporation deeds, amendments, share-transfer deeds, board decisions, powers of attorney, current articles, UBO evidence, ID evidence, and bank confirmations together.
- Map the money route early. Write down who pays whom, from which account, and why. Explain holding-company payments, family funding, related-party loans, and cross-border accounts before closing week.
- Keep payment approval personal. For notarial offices and advisers, check that payment approvals, bank cards, deviations, and four-eyes controls are visible in the system.
- Ask the notary what proof is needed. Do this early for BV formation, share transfers, property deals, refinancing, estate files, and any transaction using third-party money.
Need a cleaner transaction file before the notary starts asking urgent questions?
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.
References
- BFT versterkt financieel toezicht op notarissen met vernieuwd accountantsprotocol
- Bureau Financieel Toezicht - Detailed findings from the new protocol
- Bureau Financieel Toezicht - 2026 notarial reporting and follow-up approach
- Bureau Financieel Toezicht - Payment organisation and internal fraud risk
- Rechtspraak - Court signal on negative client-funds position
- FIU Nederland - Notaries and reporting unusual transactions
- FIU Nederland - Annual overview 2025
- KVK - BV or NV in incorporation
