Purpose
Prepare annual financial statements that provide a true and fair view and complete all required external review, approval, CBCS submission and publication steps.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Confirm framework and deadlines | Confirm the applicable accounting framework, reporting period, statutory approval deadline, CBCS submission instruction, publication deadline and audit or external-expert requirement from current sources. Accounting standards follow Dutch GAAP, proportionally adapted to the company’s scale. Large companies (thresholds: >20 employees, >ANG 5 million assets, >ANG 10 million turnover) are required to prepare audited IFRS accounts. | |
| 2 | Complete year-end close | Complete the year-end close and reconcile the general ledger, tax accounts, bank accounts, client and safeguarding positions and material disclosures. | |
| 3 | Prepare financial statements | Prepare at least the balance sheet, profit and loss account and notes, together with solvency, liquidity and other required disclosures. Bitkaya, as a VASP, must submit to the CBCS annual financial statements containing at least a balance sheet and a profit and loss account with accompanying notes for the past financial year. Accounts must provide a “true and fair view” of financial position, solvency, and liquidity. | |
| 4 | Prepare disclosure checklist | Prepare a disclosure and compliance checklist and document material judgments, estimates, related parties, contingencies, subsequent events and differences between financial and tax accounts. The CBCS may establish generally binding regulations concerning the annual financial statements, and the form and method of submission. | |
| 5 | Obtain Finance and Board review | Obtain Finance review and Board review before submitting the statements and supporting records to the appointed independent expert or auditor. Internal audit functions may be replaced initially by an external review from a qualified accounting professional until growth justifies a dedicated internal function. | |
| 6 | Resolve adjustments | Resolve or formally accept proposed adjustments and track the management letter and findings to closure. | |
| 7 | Obtain external-expert statement | Obtain the external-expert fairness statement and management letter required for VASP reporting. The annual financial statements must be accompanied by a statement issued by an external expert regarding the fairness of the financial statements, as well as a management letter. | |
| 8 | Obtain general-meeting approval | Obtain approval by the general meeting and preserve the resolution and signed final statements. Accounts must be approved by the general meeting. | |
| 9 | Submit to CBCS | Submit the approved annual statements and required accompanying documents to CBCS within the current deadline and retain acceptance evidence. Submission must occur within a period determined by the CBCS after the end of the financial year. | |
| 10 | Publish statements | Publish the approved statements on Bitkaya’s website within the applicable period and through any additional CBCS-directed method. Bitkaya shall publish the annual financial statements on its website within one month after the financial statements must be approved pursuant to Book 2 of the Civil Code. In addition, the CBCS may require Bitkaya to publish its annual financial statements for the past financial year, within a period determined by the Bank, in another manner established by the Bank. | |
| 11 | Reconcile published versions | Reconcile the published and submitted versions to the approved signed statements and record any correction or late submission under REG and ICA escalation. |
Evidence
- Current annual-account obligations and timetable
- Year-end close and reconciliation pack
- Draft and signed financial statements
- Disclosure and accounting-framework checklist
- Expert or auditor engagement, statement and management letter
- Board and general-meeting records
- CBCS submission and acceptance evidence
- Website publication and version verification
- Findings and remediation log
Relationships
- Policy: POL-FIN-001 Finance and Tax Compliance Manual
- Reporting procedure: PROC-REG-005 Coordinate Tax and Audited Financial Reporting
- Audit procedure: PROC-ICA-005 Coordinate External Regulatory and Financial Audits
- Control: CTRL-FIN-003 Ensure Annual Financial Statements Are Approved Reviewed Submitted and Published
History
- 2026-07-26: Created from sections 2.3, 4.1, 4.3 and 6.3 of the approved FIN Manual.