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GAAP conversions for European companies bringing in US investors

For a US fundraise, a US acquisition or a US IPO, starting from your local books

How a conversion works with me

I call this framework Bridge the GAAP, and I run every conversion in bite-sized chunks, so you always know what's next and your team learns it along the way. We start with Phase 1. Once we both know what the differences are, I scope Phase 2 with you, and you decide how much of it your team wants to run.

Your team can take the work in-house at any point from the GAAP Summit
Phase 1 · Understand the differences
  1. Stage 1

    See where you stand

    You just throw all the files at me, or your team does the pre-work in my template. Either way, every account gets explained and your team confirms the current policies I write down.

  2. Stage 2

    Know what changes

    I write your US GAAP or IFRS policies, benchmarked against listed peers. You get a prioritized list of differences in the GAAP matrix, with the files needed to quantify each one.

  3. Stage 3

    The GAAP Summit

    We go through the matrix line by line in a half-day working session, on your own files. Your team agrees the plan and decides who does what next.

Phase 2 · Implement
  1. Stage 4

    Put it in place

    This is where the adjustments, the walk from local GAAP, the consolidation and the memos get done. I prepare some workstreams, and your team prepares others with my templates and review. We agree the split when we scope Phase 2. If your scope includes technical memos in Phase 1, I write those alongside stages 2 and 3, so they're ready for the Summit.

  2. Stage 5

    Through your first audit

    Financial statements your auditors can trace back to the general ledger, and a close checklist so your team can repeat it every year.

Some teams finish the audit on their own and some want me there until the auditors sign. You make that call when you have the full picture, and you can take the work in-house at any point.

If you're buying in Europe more than once, each new acquisition starts again at stage 1.

How long it takes

Phase 1 typically takes 6 to 12 weeks from kickoff to the GAAP Summit, depending on how many entities and frameworks you have and how much of the pre-work your team takes on. A full conversion typically takes 3 to 4 months. I plan Phase 2 backwards from your audit or deal date.

Katrina Nacci, CPA

Who you work with

I'm Katrina Nacci, a US CPA based in Frankfurt since 2013. After nine years at PwC in Boston, Frankfurt and Dubai, in audit, capital markets and accounting advisory, I spent three years building a private equity group's European finance team from scratch, including its IFRS to US GAAP conversion and lease accounting implementation.

I've worked independently since 2022, mainly on GAAP conversions and US reporting for European companies. It's just me, so the person you speak to is the person doing the work. More about me

What working with me looks like

Async by default

I work across entities and time zones in the background while your team runs business as usual. I walk through files on recorded Loom videos instead of extra meetings, and use transcription so I can be fully present on the calls we do have.

One project page

I set up a ClickUp project page with the timeline and tasks, so your team can see progress, open questions and anything waiting on them at any time.

Your team keeps the knowledge

I work on defined projects, so I won't be around forever. I explain the reasoning behind each position as we go, so your team can run the new reporting day to day, and I'll point out where a process could be simpler.

What clients say

“In preparation for our first US GAAP group audit at Taktile, our biggest challenge was to identify all areas in our books that need adjustments, especially the ones that go beyond the obvious. [...] Together with her, we identified the necessary adjustments on group and local entity level, which gave us a clear way to become audit-ready.”
Sven Zeidler, Director Finance, Taktile
“Following investment from a US based listed business, we had to rapidly translate our reporting from UK to US GAAP. [...] Katrina's tried and tested methodology in executing GAAP translation work allowed us to collectively quickly identify where the work needed to be focused.”
Ben Williamson, Group Finance & Commercial Director, Totally Wicked
“Her approach to every topic was quite tailored to our business which meant that she only took us through what was of benefit to our company. [...] My team and I now have the knowledge and confidence we need to report under the US GAAP.”
Tim Kamombo, FD, PensionBee
“Katrina was proactive and pragmatic in her approach, gaining a good understanding of our business and delivering the agreed documentation to underpin the financial statements and to support the audit process.”
Tom Morgan, Head of Financial Control, Snowplow

Read all client reviews in full on Senja

Brands I've worked with

  • Taktile
  • MUBI
  • Snowplow
  • PensionBee
  • HOOKIPA Pharma
  • Stream (formerly Wagestream)
  • Intel
  • Auditdata
  • Totally Wicked
  • Encore
  • IMS Nanofabrication
  • General Catalyst
  • Smartwyre
  • SoftOx
  • Renvio
  • RELX (RLX Technology)
  • Barney's Farm
  • Day Wireless Systems

Planning a US GAAP or IFRS conversion?

Book a call to talk through your entities, frameworks and deadline, or get an estimate from the cost calculator first.

Frequently asked questions

What is a GAAP conversion?

It restates your financial statements from one accounting framework to another, for example from German HGB or UK FRS 102 to US GAAP. The numbers change as well as the format: provisions, pensions, leases, revenue, development costs and deferred tax are the usual areas. I document each difference in a GAAP matrix, then quantify the adjustments (German GAAP to US GAAP).

Does a US investor always require US GAAP?

No. Many US VC and PE investors accept IFRS or local GAAP accounts. US GAAP usually becomes a requirement with an acquisition by a US company, a term in the investment agreement, or a US listing (unless you qualify as a foreign private issuer and report under IFRS as issued by the IASB). Check the information rights clause in your investment agreement before you plan a conversion.

How long does a GAAP conversion take?

Phase 1, from kickoff to the GAAP Summit, typically takes 6 to 12 weeks. A full conversion including Phase 2 (the adjustments, US GAAP financial statements and audit support) typically takes 3 to 4 months, longer with large lease portfolios, complex revenue or several entities.

How much does a GAAP conversion cost?

Phase 1 starts at €25,000 for a single company and €40,000 for a group with subsidiaries to consolidate, or about 35% less when your team does the pre-work. Each additional local framework adds €6,000 and each technical memo about €6,500, and a US IPO or PCAOB audit widens the scope. Phase 2 is priced separately. See pricing for real examples, or get an estimate from the cost calculator.

What will our auditors expect to see?

Five sets of documents: the GAAP matrix, an overall conversion approach memo, subledgers with documented assumptions, memos on significant items, and US GAAP financial statements with a disclosure checklist. Sharing the draft approach memo and matrix with your auditors early prevents rework before fieldwork (the checklist).

Can our auditor do the GAAP conversion?

Often not. If your statutory auditor, or a firm in its network, will audit US GAAP financial statements filed with the SEC, or you are a public-interest entity, independence rules prevent it from preparing them. Before a US listing, SEC rules also bar ten categories of non-audit services, including bookkeeping and valuation, from the first day of the last fiscal year before you first file (ISA audit vs PCAOB audit).

More answers on the FAQ page.

Schedule a strategy call

Tell me where you are today and what's coming, and we'll map out the first steps together.