WBSO SPECIALIST · AMERSFOORT · SINCE 2004 +31 33 453 08 18info@klarensubsidieadvies.nl
AFTER THE APPLICATION WBSO records Hours records Project records Costs & expenditures Reporting the actuals RVO audit Information notice Objection Innovation box

AFTER THE APPLICATION · AUDIT

WBSO audit by RVO: what is checked and how do you prepare?

After granting WBSO, RVO can check whether your application corresponds with practice and whether you meet the administrative obligations. The audit can take place via a remote desk audit or at your business location. RVO assesses among others the R&D activities carried out, the realised hours and — with actual costs and expenditures — the amounts made and paid.

BY PETER KLAREN · LAST CHECKED SEPTEMBER 2026 · SOURCE: WBSO GUIDE 2026 (RVO)

What does RVO check in a WBSO audit?

RVO carries out retrospective audits at companies that have received an R&D declaration. Core of the assessment: does the application correspond with practice, and is that demonstrable?

ComponentWhat does RVO look at?
ApplicationDo the activities carried out connect with what was approved?
Project recordsIs the nature, content and progress of the R&D demonstrable?
Hours recordsWho worked how many hours when on which project?
Leave and sicknessDo the registered R&D hours logically connect with these?
Actual costsWere costs granted in advance, made and paid?
Actual expendituresAre investment, use and R&D attribution substantiated?
RealisationDo the reported hours and costs connect with the records?

In an RVO audit it is not about a perfect file afterwards, but about a credible and verifiable relationship between what you applied for, what was technically actually carried out, which hours and costs belong to it and what was ultimately realised.

Desk audit or on-site audit

RVO can carry out the WBSO audit remotely or at your company on location. In advance you receive notice of the audit, which data RVO wants to receive and within which period you must supply it.

Desk auditCompany visit
Supplying documents digitallyAudit at the business location
Remote assessment of the recordsRecords plus substantive explanation
Additional questions possibleTechnical employees can provide explanation
Preparation of the file is centralBoth file and conversations are important

In both cases: the audit is announced in advance. So you know which documents to supply and when.

Which documents can RVO request in an audit?

Which documents are relevant differs per project. The file must above all convincingly show what actually happened.

Records

hours recordsproject recordsactuals reportR&D declaration(s)

Technical evidence

technical drawingstest and measurement reportsphotos of prototypescalculationstechnical e-mailsGit commits and pull requestsJira/GitHub issuesbenchmark resultsresearch reports

With actual costs and expenditures

invoicesproof of paymentquotationsorder confirmationssubstantiation of equipment attribution

More per record type: hours records, project records and costs and expenditures.

Which hours often attract attention?

The job title is not decisive. A director or project manager can only declare R&D hours insofar as he or she personally carries out technically substantive R&D activities within the approved project.

RVO looks at the activities actually carried out, not at the role on paper. Employees not involved in technical substance — for example marketing or secretarial staff — do not deliver R&D hours.

No R&D hours

general managementplanning and coordinationadministrationcommerce and salesorganisational activitiesmarketingsecretarial work

For the full rules see the WBSO hours records.

Software projects in an RVO audit

In software projects, Git history, issues, technical designs, benchmarks and test results can form very important evidence.

But a large number of commits in itself does not yet prove that R&D was involved. It must also be clear which programming-technical bottleneck was solved and how the technical development proceeded.

See also WBSO software and project records for software.

Product, process and research projects in an audit

Product development

Designs, changes, calculations, prototype logs and test reports make the development process visible.

Process development

Process measurements, test run reports and settings show which technical uncertainty was resolved.

Technical scientific research

Research design, measurement series, interim findings and results together form the research trail.

How do you prepare for a WBSO audit?

  1. 1Put the application and R&D declaration side by sideWhich activities were exactly approved?
  2. 2Check the hours recordsPer person, project and day; within the 10-working-day rule; connecting to leave and sickness records.
  3. 3Check the technical fileIs the development or research chronologically traceable?
  4. 4Check actual costs and expendituresInvoices, payments, direct attribution and service.
  5. 5Compare with the actuals reportWere the same totals and projects used?
  6. 6Identify deviations in advanceWhy did hours, technical approach or planning go differently? A good explanation in advance is stronger than a surprise during the audit.
  7. 7Ensure someone with technical project knowledge is availableSubstantive questions are best answered by someone who did the work themselves.

RVO-proof file check: can you answer these seven questions with “yes”?

1.Is it clear per project what was technically done?
2.Do the hours connect with the technical progress?
3.Are documents dated and traceable to the maker?
4.Are failed solution directions also kept?
5.Do the hours connect with sickness and leave data?
6.Are actual costs and expenditures demonstrably paid?
7.Does the actuals report connect with the records?

Is any of these answers “no”? Then there is a potential audit point. Preferably resolve that before RVO asks about it.

Connection with the approved R&D activities

The activities actually carried out must recognisably connect with the approved R&D project.

That means not that every experiment must proceed exactly according to the application. New technical bottlenecks, failed solution directions and changes during the development process are not strange — they belong to R&D. The file must however clearly show that the work remained within the approved technical development or research direction.

What happens if RVO finds deviations?

If the audit shows that the WBSO requirements or administrative requirements were not met, RVO can issue a corrected R&D declaration . Previously granted R&D payment reduction can thereby be wholly or partially withdrawn.

ConsequenceExplanation
Corrected R&D declarationThe correction can amount to at most the originally granted R&D payment reduction
FineRVO can, depending on the established violation, impose a fine
ProcessingThe fine is included in the corrected R&D declaration

More about corrections: Report WBSO actuals.

WBSO audit for self-employed professionals

For self-employed professionals, the 500-hour requirement is especially important. If the audit shows that fewer than 500 qualifying R&D hours were realised, RVO withdraws the R&D declaration.

RVO audit or Tax Administration audit?

These two audits are not the same and are carried out by different authorities.

RVO checksThe Dutch Tax and Customs Administration checks
The content of the R&D projectPayroll tax and returns
The realised R&D hoursThe fiscal offset
The project recordsThe correct processing of the decision
Actual costs and expendituresThe tax-technical application

Disagreeing with a correction or fine?

You can within 6 weeks of the dispatch date object to the corrected R&D declaration and/or the fine.

Note: you must still process the corrected R&D declaration during the objection procedure. Objection does not automatically suspend that processing.

→ Everything about WBSO objection
→ Received an information notice from RVO?

Frequently asked questions about the WBSO audit

How does a WBSO audit by RVO proceed?
The audit can take place at your business location or via a remote desk audit. RVO announces the audit in advance and states which data is needed and by which date you must supply it.
What does RVO exactly check in WBSO?
Whether the application and the actual activities correspond, how many R&D hours were actually spent and — with the choice for actual costs and expenditures — which amounts were made and paid.
Which records must I be able to show?
The hours records and project records, and with actual costs and expenditures also the cost and expenditure records with invoices and proof of payment.
Does RVO always visit for an audit?
No. A WBSO audit can also take place entirely remotely as a desk audit.
Can RVO correct granted WBSO?
Yes. RVO can issue a corrected R&D declaration up to a maximum of the originally granted R&D payment reduction.
Can RVO impose a fine?
Yes, depending on the established violation. The fine is included in the corrected R&D declaration.
What if a self-employed professional realised fewer than 500 hours?
Then RVO withdraws the R&D declaration.
How long do I have to object?
Six weeks from the dispatch date of the corrected R&D declaration or the fine. Meanwhile you must still process the correction.

Has RVO announced a WBSO audit?

We test your file in advance, compare application, hours, project records and realisation, and help you make any weak spots transparent before the audit.

SOURCES AND SUBSTANTIVE REVIEW

RVO — WBSO Guide 2026

Reviewed by Peter Klaren, WBSO specialist since 2004. Last substantively updated: 21 September 2026.