The stock reconciliation is an annual check of your stock of veterinary medicines. You compare the medicines that came in and went out with what is still in stock, and you record the differences. The European veterinary medicines regulation requires this at least once a year, and the results must remain available for inspection for five years.
You need the same count for the annual accounts, because the stock is an asset on your balance sheet. Plan both counts at the same time, around the year end. Then you do the work once and the records and the accounts match.
In short
- At least once a year you compare incoming and outgoing veterinary medicines with the stock. You record differences. That is in article 103(5) of Regulation (EU) 2019/6.
- This also applies if you only administer medicines yourself. According to RVO, the vet must then still meet the record-keeping requirements of article 103.
- The regulation requires five years of retention. The tax retention duty is seven years. So keep records and count sheets for seven years.
In this article
- What exactly is the stock reconciliation?
- Which details must you record per transaction?
- How do you do the stock reconciliation?
- How does the count tie in with your annual accounts?
- How long do you keep the records and count sheets?
- What do you do with the stock when the practice is taken over or sold?
- Why has recording veterinary medicines become so important?
What exactly is the stock reconciliation?
It is the annual detailed stock check from the European veterinary medicines regulation. The text says: at least once a year the retailer carries out a detailed audit of stocks, comparing incoming and outgoing veterinary medicines with the medicines held in stock. Differences are recorded (Regulation (EU) 2019/6, article 103(5)).
The Dutch name refers to the four corners of the check: what was there at the start, what came in, what went out and what is there at the end. RVO uses this term for the obligation (RVO, newsletter on the veterinary prescription, 7 April 2026).
In the Netherlands, there are no veterinary pharmacies separate from the veterinary practice. The vet holds a retail licence for their pharmacy (RVO, 2026). That is why the retailer's duty also applies to your practice.
Which details must you record per transaction?
For each medicine that requires a prescription, you record seven details per transaction (Regulation (EU) 2019/6, article 103(3)):
- The date of the transaction.
- The name of the medicine, with its form and strength where needed.
- The batch number.
- The quantity received or supplied.
- Name and address of the supplier on purchase, or of the recipient on sale.
- Name and contact details of the prescribing vet, and where needed a copy of the prescription.
- The marketing authorisation number of the medicine.
If you administer a medicine once yourself, the prescription does not have to meet the requirements for handing out. You must still meet the record-keeping requirements of article 103, including the stock reconciliation. That applies to food-producing animals and to companion animals (RVO, 2026).
How do you do the stock reconciliation?
For each medicine, take the opening stock, add the purchases and deduct what you administered, handed out or destroyed. That gives the stock according to the records. Then count what is actually there. You record the difference between the two, with an explanation if you have one.
Start with the medicines that move most and cost most. According to a survey of independent practices cited by the ACM, a fifth of a practice's turnover comes from medicine sales. That is more than from operations, consultations, vaccinations or pet food separately (ACM, market study on medical care for pets, 2026).
Many differences have an ordinary cause. Think of an administration not entered in the software, an opened pack that was thrown away, or a delivery booked on the wrong day. The more often you count a few medicines in between, the less work at the end of the year.
How does the count tie in with your annual accounts?
The counted stock is also the stock on your balance sheet. You value it at purchase price. If the current value at the balance sheet date is lower, for example because a medicine is close to expiry, you use that lower value (Civil Code Book 2, article 387(2)). For tax you follow sound business practice with a consistent approach every year (Income Tax Act 2001, article 3.25).
A shortfall in the stock reconciliation is also a shortfall in your accounts. Medicines that have disappeared or expired are written off as a cost. An explanation of differences and write-offs in an ordinary stock count is in a separate article (counting stock on 31 December). How far you may write down old stock is in another article (writing down old stock).
Watch the VAT when writing off. Medicines you hand out are sold at 9%, medicines you administer during treatment fall under 21% (Tax Administration, VAT rate on veterinary medicines). Good records of administering and handing out therefore also help with VAT.
How long do you keep the records and count sheets?
Seven years is the safe period. The regulation requires the results of the check and the records to remain available for inspection for five years (Regulation (EU) 2019/6, article 103(5)). Tax law requires businesses to keep their records for seven years (General Tax Act, article 52(4)).
So keep the count sheet from the end of December together with the annual accounts. Then an inspector can see the stock reconciliation, and a tax inspector can see the basis for the stock on the balance sheet.
What do you do with the stock when the practice is taken over or sold?
Count the stock on the transfer date and do a stock reconciliation on that day as well. Then it is clear which medicines the buyer takes over and at which price. Medicines that have expired or are about to expire do not belong in the price at full purchase cost.
The records continue with whoever carries on the practice. The regulation requires the results of the check and the records to remain available for inspection for five years (Regulation (EU) 2019/6, article 103(5)). So agree in the purchase agreement who keeps the old records and how the other party can see them.
The buyer also benefits from a good count. A shortfall that only appears after the transfer is a cost for the new owner. A count sheet signed by both parties prevents arguments afterwards.
Why has recording veterinary medicines become so important?
Recording helps steer use. Between 2007 and 2012, antibiotic use in farm animals in the Netherlands fell by 56%. Researchers describe that the fall came from a combination of compulsory and voluntary measures with clear targets, in cooperation between government, vets and livestock farming (Speksnijder et al., 2015).
That research concerns antibiotics in farm animals, not the stock of a companion animal practice. It does show why the rules demand accurate records. For the practice, the extra benefit is that a correct stock also gives correct annual accounts.
For farm animals, the farm health plan and the farm treatment plan with regular farm visits remain the basis for limited stocks of antibiotics on the farm (RVO, 2026). Those supplies also belong in your records.
Sources
- Regulation (EU) 2019/6 on veterinary medicinal products, article 103. eur-lex.europa.eu
- RVO, Newsletter 1, The veterinary prescription, version of 7 April 2026 (in Dutch). rvo.nl
- Netherlands Authority for Consumers and Markets, Market study on medical care for pets, 30 April 2026 (in Dutch). acm.nl
- Dutch Civil Code Book 2, article 387, in force from 1 July 2026. wetten.overheid.nl
- Income Tax Act 2001, article 3.25, in force from 21 February 2026. wetten.overheid.nl
- General Tax Act (Algemene wet inzake rijksbelastingen), article 52, in force from 1 October 2026. wetten.overheid.nl
- Tax Administration, VAT rate on veterinary medicines, read 1 November 2026 (in Dutch). belastingdienst.nl
- Speksnijder, D. C., Mevius, D. J., Bruschke, C. & Wagenaar, J. A. (2015). Reduction of veterinary antimicrobial use in the Netherlands. The Dutch success model. Zoonoses and Public Health, 62(Suppl. 1), 79-87. doi.org