EU national GAAP & the Accounting Directive
IFRS is mandatory in the EU only for the consolidated accounts of listed groups (IAS Regulation 1606/2002). The other ~99% of EU entities report under national GAAPs, all derived from one EU law: the Accounting Directive 2013/34/EU. Shillinq already covers the Dutch national leg (BW2 Title 9 + RJ); this page covers the EU-wide backbone and the other major member-state GAAPs.
Verified June 2026 against EUR-Lex and national standard-setters (DRSC, ANC, OIC, ICAC). National GAAP text is largely in the national language and often behind official portals; links point to the authoritative standard-setter or law.
EU Accounting Directive 2013/34/EU
The Directive is the legal backbone every member-state GAAP transposes. It sets the layouts, recognition/measurement options, disclosures, and — crucially — the size categories that drive disclosure and audit relief.
| Size category | Basis (2 of 3 criteria) | Typical relief | Source |
|---|---|---|---|
| Micro | very small thresholds | minimal accounts, no notes | Directive 2013/34/EU |
| Small | small thresholds | abridged balance sheet, no management report, usually no statutory audit | Directive 2013/34/EU |
| Medium-sized | medium thresholds | abridged layouts | Directive 2013/34/EU |
| Large | above medium | full accounts + audit | Directive 2013/34/EU |
Thresholds are revised periodically (last EU-level uplift via a 2023 delegated act) and transposed per member state — confirm the current national figures. The Dutch transposition is art. 2:395a–398 BW.
EU-endorsed IFRS
What is legally binding in the EU is not raw IASB IFRS but EU-endorsed IFRS — IFRS as adopted by the European Commission on EFRAG's advice under the IAS Regulation. It can lag IASB issuance until endorsement completes (e.g. a new standard like IFRS 18 is not EU-law until endorsed) and has historically carried carve-outs (the IAS 39 "carve-out"). For an EU filer this is a distinct framework from IFRS (IASB).
| IFRS (IASB) | IFRS (EU-endorsed) | |
|---|---|---|
| Issued by | IASB | European Commission (EFRAG advice) |
| Binding for | global voluntary adopters | EU-listed consolidated accounts |
| Timing | on issuance | after EU endorsement (may lag) |
| Source | ifrs.org | IAS Regulation summary |
German HGB
The Handelsgesetzbuch (HGB) is German commercial law and the GAAP for all German non-listed entities (the EU's largest economy). Group-level guidance comes from the DRSC (Deutsche Rechnungslegungs Standards, DRS). In practice German bookkeeping runs on the DATEV SKR03 / SKR04 standard charts of accounts.
| Element | What it is | Source |
|---|---|---|
| HGB §§238–342e | Commercial-law accounting rules (Buchführung, Jahresabschluss) | HGB (gesetze-im-internet) |
| DRS | German Accounting Standards (group accounts) issued by DRSC | DRSC standards |
| SKR03 / SKR04 | DATEV standard charts of accounts (process- vs balance-sheet-ordered) | DATEV SKR overview (verify) |
HGB is conservative/prudence-driven (like Dutch GAAP), differing materially from IFRS on development costs, leases and provisions. SKR03/SKR04 are table-stakes for a German-facing bookkeeping product.
French PCG
The Plan Comptable Général (PCG) — currently ANC Règlement 2014-03, issued by the Autorité des normes comptables (ANC) — is France's GAAP and a legally mandatory chart of accounts (unlike Germany's de-facto SKR).
| Element | What it is | Source |
|---|---|---|
| PCG (ANC Règlement 2014-03) | The mandatory French chart of accounts + recognition/measurement rules | ANC — Plan Comptable Général |
| Consolidated PCG (1 Jan 2026) | Current consolidated version | PCG 1 Jan 2026 (PDF) |
Italian OIC
Italian non-listed entities apply the Codice Civile supplemented by the OIC standards (Organismo Italiano di Contabilità). Italy is the EU's 3rd-largest economy.
| Element | What it is | Source |
|---|---|---|
| OIC standards | Italian accounting principles supplementing the Civil Code | OIC — use of IFRS by jurisdiction (Italy) |
Spanish PGC
Spanish entities apply the Plan General de Contabilidad (PGC), a mandatory general accounting plan issued/overseen by the ICAC (Instituto de Contabilidad y Auditoría de Cuentas). Broadly IFRS-aligned.
| Element | What it is | Source |
|---|---|---|
| PGC | Spanish mandatory general accounting plan | ICAC (verify) |
Why these are in the catalogue
A Dutch BV reports on BW2/RJ; a German GmbH on HGB; a French SARL on the PCG. When a group spans jurisdictions, more than one basis applies and the Standards policy decides which wins. IFRS for SMEs is deliberately not in the catalogue — despite being the IASB's purpose-built private-entity standard (3rd edition, 2025), no EU member state has adopted it because it conflicts with the Accounting Directive; the EU's SME layer is the national GAAPs above.