Stricter rules for reserves
"},"paragraphs":[{"componentType":"paragraph","richBody":{"value":"ANBIs are no longer allowed to set aside funds arbitrarily. Only three types of reserves are permitted:
Note: A general reserve without explanation is no longer allowed. For example, if you maintain a buffer for emergency aid or anticipated requests, it may be rejected by the Tax Inspector. Consulting the Tax Authority in advance may be wise.
"}}]},{"title":{"value":"Endowment capital: what is and isn’t allowed?
"},"paragraphs":[{"componentType":"paragraph","richBody":{"value":"You cannot designate endowment capital yourself as a board. Investment gains must be spent unless the donor explicitly stated that the capital must be preserved. If you want to spend a fixed percentage annually, you must support this with a multi-year forecast and reassess it annually.
"}}]},{"title":{"value":"Crowdfunding and intermediary organizations
"},"paragraphs":[{"componentType":"paragraph","richBody":{"value":"Planning to use crowdfunding as an ANBI? You must be substantively involved in selecting and disbursing projects. Simply transferring funds based on donor instructions, without your own public benefit objective, is insufficient. This also applies to intermediary organizations: without a clear public benefit goal, you risk losing your ANBI status.
"}}]},{"title":{"value":"Welfare activities
"},"paragraphs":[{"componentType":"paragraph","richBody":{"value":"Activities focused on relaxation or personal development are only permitted if they target vulnerable groups, such as the elderly or socially isolated individuals. Make sure this is clearly stated in your policy.
"}}]},{"title":{"value":"Foreign organizations
Are you based in a non-EU country without data exchange agreements with the Netherlands? Then you must provide annual transparency, for example through an auditor’s statement. Otherwise, your ANBI status may be revoked.
"}}]}]},{"componentType":"sectionTitle","title":"What does this mean for your organization?"},{"componentType":"paragraph","richBody":{"value":"This new decision is not legislation, but the Tax Authority uses it as a framework for assessment. If your organization does not comply, your ANBI status may be withdrawn. That poses risks for tax benefits and donations. Take the time to critically review your reserves, policies, and practices.
Questions or need to discuss the impact on your organization?
Contact your tax advisor.
Written by Robert Mantel, Tax Expertise Manager.
"}},{"componentType":"accordion","accordionList":[{"title":"Based on the situation as of October 31, 2025.","richBody":{"value":"The information provided by ING in this article is not an offer, advice, or financial service and is intended solely to inform and provide practical tips. We always recommend consulting a specialist regarding your financial and/or wealth planning. This article has been compiled with the utmost care. However, it is possible that the information contains inaccuracies or omissions. ING is not liable for any damage (of any kind) resulting from the use of the information provided. No rights can be derived from the information. Any mentioned rates are indicative and not binding for ING. All rights and changes reserved. This is a publication of ING Bank NV, registered in Amsterdam.
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