October 20, 2026
The NBA and NOREA guidance on AI: what it asks of Dutch firms
In June 2026 the Dutch accountancy bodies published 'Leidraad 2: AI toegepast'. Its core principle: AI must never be a black box.
In June 2026, NBA Accounttech and NOREA, the Dutch professional bodies for accountants and IT auditors, published Leidraad 2: AI toegepast ("AI applied"). It follows their 2024 guidance AI in Control and gives members practical direction for using AI in their work.
What it says
- AI must never be a black box. In the guidance's words, AI may never be a "black box" for NBA and NOREA members.
- Validation and human judgement remain the basis of public trust. The professional stays responsible for the result.
- Reproducibility and ethical frameworks are how firms keep AI from becoming a black box, together with preconditions for its use and validation of its output.
- Dozens of practice cases, from bookkeeping and contract review to fraud detection and ESG reporting, for audit firms and the wider profession.
The guidance itself is the reference; read it on the NBA's website.
Questions a firm can ask of any AI tool
- Can we see, for every result, which documents it was based on?
- Does a person approve each step before anything is booked, sent or filed?
- Is every action recorded, with who approved it and when, so the work can be reconstructed later?
- Do we know where client data is processed, and who else can reach it?
How Bertha is built around these questions
Bertha prepares the routine work and a person approves every step. Every figure links to the document it came from, and every action is recorded with a name and a time. It runs on a machine in the firm's own office, so client data stays there, and every connection the machine makes is logged.
This is our reading of the public summaries of the guidance, not an endorsement by the NBA or NOREA and not a compliance statement. Each firm remains responsible for how it applies the guidance.