PCAOB 2025 Inspection Report: Deloitte Netherlands

2025 Inspection Deloitte Accountants B.V.

(Headquartered in Rotterdam, Netherlands)

February 9, 2026

PORTIONS OF THE COMPLETE REPORT ARE OMITTED FROM THIS DOCUMENT IN ORDER TO COMPLY WITH SECTIONS 104(g)(2) AND 105(b)(5)(A) OF THE SARBANES-OXLEY ACT OF 2002 PCAOB RELEASE NO. 104-2026-037 THIS IS A PUBLIC VERSION OF A PCAOB INSPECTION REPORT

TABLE OF CONTENTS

2025 Inspection ............................................................................................................................. 2

Overview of the 2025 Inspection and Historical Data by Inspection Year ................................... 3

Part I: Inspection Observations ..................................................................................................... 5

Part I.A: Audits with Unsupported Opinions ................................................................................ 5

Part I.B: Other Instances of Non-Compliance with PCAOB Standards or Rules ........................... 5

Part I.C: Independence.................................................................................................................. 5

Part II: Observations Related to Quality Control .......................................................................... 7

Appendix A: Firm’s Response to the Draft Inspection Report ..................................................... A-1

2025 INSPECTION

In the 2025 inspection of Deloitte Accountants B.V., the Public Company Accounting Oversight Board (PCAOB) assessed the firm’s compliance with laws, rules, and professional standards applicable to the audits of issuers. Our inspection was conducted in cooperation with the Dutch Authority for the Financial Markets. We selected for review three audits of issuers with fiscal years ending in 2024. For each issuer audit selected, we reviewed a portion of the audit. We also evaluated elements of the firm’s system of quality control.

2025 Inspection Approach

In selecting issuer audits for review, we use a risk-based method of selection. We make selections based on (1) our internal evaluation of audits we believe have a heightened risk of material misstatement, including those with challenging audit areas, and (2) other risk-based characteristics, including issuer and firm considerations. In certain situations, we may select all of the firm’s issuer audits for review. When we review an audit, we do not review every aspect of the audit. Rather, we generally focus our attention on audit areas we believe to be of greater complexity, areas of greater significance or with a heightened risk of material misstatement to the issuer’s financial statements, and areas of recurring deficiencies. We may also select some audit areas for review in a manner designed to incorporate unpredictability. Our selection of audits for review does not necessarily constitute a representative sample of the firm’s total population of issuer audits. Additionally, our inspection findings are specific to the particular portions of the issuer audits reviewed. They are not an assessment of all of the firm’s audit work or of all of the audit procedures performed for the audits reviewed. View the details on the scope of our inspections and our inspections procedures.

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OVERVIEW OF THE 2025 INSPECTION AND HISTORICAL DATA BY INSPECTION YEAR

The following information provides an overview of our 2025 inspection as well as data from the previous inspection. We use a risk-based method to select audits for review and to identify areas on which we focus our review. Because our inspection process evolves over time, it can, and often does, focus on a different mix of audits and audit areas from inspection to inspection and firm to firm. Further, a firm’s business, the applicable auditing standards, or other factors can change from the time of one inspection to the next. As a result of these variations, we caution that our inspection results are not necessarily comparable over time or among firms.

Firm Data and Audits Selected for Review

2025 2022 Firm data Total issuer audit clients in which the firm was the 3 3 lead/principal auditor Total issuer audits in which the firm was not the 46 20 lead/principal auditor Total engagement partners on issuer audit work8 16 1 Audits reviewed Total audits reviewed3 3 2 Audits in which the firm was the lead/principal auditor 2 1 Audits in which the firm was not the lead/principal auditor 1 2 Integrated audits of financial statements and 3 2 internal control over financial reporting (ICFR) Audits with Part I.A deficiencies 0 0 Percentage of audits with Part I.A deficiencies 0% 0%

The number of engagement partners on issuer audit work represents the total number of firm personnel (not necessarily 1 limited to personnel with an ownership interest) who had primary responsibility for an issuer audit (as defined in AS 1201,

Supervision of the Audit Engagement) or for the firm’s role in an issuer audit during the twelve-month period preceding the

outset of the inspection. The population from which audits are selected for review includes both audits for which the firm was the lead/principal 2 auditor and those where the firm was not the lead/principal auditor but played a role in the audit.

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Audit Areas Most Frequently Reviewed

This table reflects the audit areas we have selected most frequently for review in the 2025 inspection and the previous inspection. For the issuer audits selected for review, we selected these areas because they were generally significant to the issuer’s financial statements, may have included complex issues for auditors, and/or involved complex judgments in (1) estimating and auditing the reported value of related accounts and disclosures and (2) implementing and auditing the related controls. 2025 2022 Audit area Audits reviewed Audit area Audits reviewed Revenue and related accounts Revenue and related accounts 3 3 Cash and cash equivalents Inventory 2 1 Income taxes Income taxes 1 1 Expenses Certain assets 1 1 Other assets 1

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PART I: INSPECTION OBSERVATIONS

Part I.A of our report discusses deficiencies, if any, that were of such significance that we believe the firm, (1) at the time it issued its audit report(s), had not obtained sufficient appropriate audit evidence to support its opinion(s) on the issuer’s financial statements and/or ICFR or (2) in audit(s) in which it was not the lead/principal auditor, had not obtained sufficient appropriate audit evidence to fulfill the objectives of its role in the audit. Part I.B discusses certain deficiencies, if any, that relate to instances of non-compliance with PCAOB standards or rules other than those where the firm had not obtained sufficient appropriate audit evidence to support its opinion(s) or fulfill the objectives of its role in the audit(s). This section does not discuss instances of apparent non-compliance with rules related to maintaining independence. Part I.C discusses instances of apparent non-compliance with rules related to maintaining independence. Consistent with the Sarbanes-Oxley Act (“Act”), it is the Board’s assessment that nothing in Part I of this report deals with a criticism of, or potential defect in, the firm’s quality control system. We discuss any such criticisms or potential defects in Part II. Further, you should not infer from any Part I deficiency, or combination of deficiencies, that we identified a quality control finding in Part II. Section 104(g)(2) of the Act restricts us from publicly disclosing Part II deficiencies unless the firm does not address the criticisms or potential defects to the Board’s satisfaction no later than 12 months after the issuance of this report.

PART I.A: AUDITS WITH UNSUPPORTED OPINIONS

In the 2025 inspection, we did not identify any deficiencies that were of such significance that we believe the firm, (1) at the time it issued its audit report(s), had not obtained sufficient appropriate audit evidence to support its opinion(s) on the issuer’s financial statements and/or ICFR or (2) in audit(s) in which it was not the lead/principal auditor, had not obtained sufficient appropriate audit evidence to fulfill the objectives of its role in the audit.

PART I.B: OTHER INSTANCES OF NON-COMPLIANCE WITH PCAOB STANDARDS OR RULES

In the 2025 inspection, we did not identify any deficiencies related to other instances of non-compliance with PCAOB standards or rules.

PART I.C: INDEPENDENCE

PCAOB Rule 3520, Auditor Independence, requires a firm and its personnel to be independent of the firm’s audit clients. This requirement encompasses not only an obligation to satisfy the independence criteria set out in PCAOB rules and standards but also an obligation to satisfy all other independence criteria applicable to an engagement, including the independence criteria set out by the SEC in Regulation S-X, 17 C.F.R. § 210.2-01, Qualifications of Accountants.

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In the 2025 inspection, we did not identify, and the firm did not bring to our attention, any instances of apparent non-compliance with PCAOB Rule 3520. Although this section does not include any instances of apparent non-compliance with PCAOB Rule 3520 that we identified or the firm brought to our attention, there may be instances of non-compliance with rules related to independence that were not identified through our procedures or the firm’s monitoring activities. While the firm did not bring to our attention any instances of apparent non-compliance with PCAOB Rule 3520, the number, large or small, of firm-identified instances of apparent non-compliance may be reflective of the size of the firm, including the number of associated firms; the design and effectiveness of the firm’s independence monitoring activities; and the size and/or complexity of the issuers it audits, including the number of affiliates of those issuers. Therefore, we caution against making any comparison of firm-identified instances of apparent non-compliance across firms.

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PART II: OBSERVATIONS RELATED TO QUALITY CONTROL

Part II of our report discusses criticisms of, and potential defects in, the firm’s system of quality control. We include deficiencies in Part II if an analysis of the inspection results, including the results of the reviews of individual audits, indicates that the firm’s system of quality control does not provide reasonable assurance that firm personnel will comply with applicable professional standards and requirements. Generally, the report’s description of quality control criticisms is based on observations from our inspection procedures. This report does not reflect changes or improvements to the firm’s system of quality control that the firm may have made subsequent to the period covered by our inspection. The Board does consider such changes or improvements in assessing whether the firm has satisfactorily addressed the quality control criticisms or defects no later than 12 months after the issuance of this report. When we issue our reports, we do not make public criticisms of, and potential defects in, the firm’s system of quality control, to the extent any are identified. If a firm does not address to the Board’s satisfaction any criticism of, or potential defect in, the firm’s system of quality control within 12 months after the issuance of our report, we will make public any such deficiency.

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APPENDIX A: FIRM’S RESPONSE TO THE DRAFT INSPECTION REPORT A-

Pursuant to Section 104(f) of the Act, 15 U.S.C. § 7214(f), and PCAOB Rule 4007(a), the firm provided a written response to a draft of this report. Pursuant to Section 104(f) of the Act and PCAOB Rule 4007(b), the firm’s response, excluding any portion granted confidential treatment, is attached hereto and made part of this final inspection report. The Board does not make public any of a firm’s comments that address a nonpublic portion of the report unless a firm specifically requests otherwise. In some cases, the result may be that none of a firm’s response is made publicly available. In addition, pursuant to Section 104(f) of the Act, 15 U.S.C. § 7214(f), and PCAOB Rule 4007(b), if a firm requests, and the Board grants, confidential treatment for any of the firm’s comments on a draft report, the Board does not include those comments in the final report. The Board routinely grants confidential treatment, if requested, for any portion of a firm’s response that addresses any point in the draft that the Board omits from, or any inaccurate statement in the draft that the Board corrects in, the final report.

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