Measure 18/12/25

AFM fines BDO for exam fraud

The Dutch Authority for Financial Markets (AFM) has imposed an administrative fine on BDO Audit & Assurance B.V. of €765.000 on December 16, 2025 because its system of quality control and business operations failed to prevent exam fraud. BDO employees shared exam answers or worked together when making exams. This was unbeknownst to the audit firm. The AFM is of the opinion that this is a serious violation and reason for a fine. With this decision, the investigations into exam fraud at the Dutch PIE audit-firms are concluded.

In short

Employees committed exam fraud
BDO did not prevent nor detect exam fraud
Exam fraud in the sector is a manifestation of a deeper underlying problem
BDO is implementing measures to prevent recurrence

Employees committed exam fraud

The AFM determined that BDO did not have specific policies, procedures, measures or controls for taking exams with integrity. BDO conducted its own investigation that revealed fraudulent behaviour when making exams by several hundreds of its professionals over the period 2018 until 2023. These professionals shared answers or worked together when making exams. The exam fraud occurred in all layers of the organization, from employee to partner. A proportion of the exams are mandatory to maintain professional knowledge and skills for the certification as an auditor.

BDO did not prevent nor detect exam fraud

It is expected from an audit firm that it structures its business operations and system of quality control such that harmful behaviour like this does not occur. However, BDO did not prevent nor detect exam fraud within its organisation. For example, BDO did not receive any internal notifications from employees. The AFM has concluded that BDO failed in its business operations in general and its system of quality control in particular and therefore imposes a fine.

Exam fraud in the sector is a manifestation of a deeper underlying problem

Exam fraud is related to factors such as time pressure, commercial interests, the lack of adequate guidance and incorrect exemplary behaviour. Previously the American regulator PCAOB imposed fines in close collaboration with the AFM on the Big 4-firms for exam fraud. Recently, Forvis Mazars was also fined by the AFM.

BDO is implementing measures to prevent recurrence

The AFM is of the opinion that the violations are serious, especially because, with their audits, audit firms add assurance to the annual reports of companies. Therefore, the credibility of an audit firm must be beyond doubt. A fine is therefore appropriate. Fine-reducing circumstances are that internal exams played a relatively small role in the system of quality control at BDO. In addition, the audit firm has cooperated with the investigation and is implementing measures to prevent recurrence. BDO has accepted the fine and the matter has been settled through a simplified procedure. The matter has therefore been closed.