In January we wrote that the Netherlands was tightening the rules on employers of record and staffing agencies through the Wtta, a new admission regime for businesses supplying workers to clients. At the time the dates were expected, and admission itself still felt like a 2028 problem.

It no longer is. A Royal Decree dated 24 June 2026 confirmed the phased introduction of the system, with the admission framework starting on 1 January 2027. In May, the minister had declined further postponement, saying that tackling abuse in the sector outweighed the limited benefit of delay. The current published timetable remains unchanged, and the first registration window opens in just over five weeks.

THE DATES, CONFIRMED

Between 1 November and 31 December 2026, existing EORs and staffing businesses can register for the transitional arrangement. On 1 January 2027, the admission framework takes effect.

Between 1 May and 30 June 2027, businesses outsourcing labour submit their applications. From 1 July 2027, the Dutch labour supply authority assesses applications, and clients can check the public register to check if a supplier is admitted, exempt or operating under transitional protection. From 1 January 2028, the outsourcing and hiring prohibitions take effect and the Labour Inspectorate begins enforcing the admission obligation.

The order of events is important. Most businesses will need an inspection report showing that they meet the required standards. An authorised inspection body checks compliance and prepares the report. Getting an appointment may take time, and any problems found may need fixing before the business can qualify. The government has identified inspection capacity as a risk to implementation.

Registering between 1 November and 31 December 2026 gives qualifying existing EORs and staffing businesses a safety net. It allows you to apply in May and June 2027 without the inspection report and supply it later, and it lets you keep outsourcing workers after 1 January 2028 while the authority decides on your application. Without registration, you need to be admitted before 1 January 2028, which means supplying the inspection report and receiving a decision by then, or you cannot outsource workers from that date.

The safety net comes with conditions. You must still apply between 1 May and 30 June 2027, meet the other requirements and show that you are actively arranging the inspection. There is also a shortcut for businesses with the certification described below. But if you need an inspection, do not leave preparations until enforcement starts.

THE CERTIFICATION SHORTCUT, AND THE CATCH

Some businesses already hold certification from the Dutch Labour Standards Foundation, known as SNA. This can simplify the first application.

If you hold a valid SNA certificate covering labour supply on 30 June 2027, and apply between 1 May and 30 June, you can use it instead of a separate Wtta inspection report for your first admission application.

That does not make admission automatic. The other applicable requirements are still there, including a certificate of conduct where required and a financial deposit unless you qualify for an exemption.

Businesses using this certification route do not have to register in November or December. The authority nonetheless advises them to do so. If you lose the certificate and cannot use that route, timely registration preserves a potential fallback. Treat it as insurance, with the application and compliance requirements still attached.

For businesses needing an inspection report, capacity deserves attention now. Inspection bodies have been able to apply for authorisation to carry out Wtta inspections since 2 July 2026, and the government has identified inspection capacity as an implementation risk. Discuss availability early. A readiness assessment now gives you more time to fix gaps than one in March.

NEW ENTRANTS AND FOREIGN PROVIDERS

Provisional admission is intended for new entrants who have not supplied workers in the twelve months before applying and cannot yet provide an inspection report. It lasts six months and can be extended once by up to six months. The initial deposit is €50,000, rising to €100,000 when applying for full admission.

From 1 January 2028, a new entrant without applicable transitional protection must have provisional admission before outsourcing workers. If you are planning a Dutch launch around that date or later, build the authority's decision into the launch timetable.

The regime also covers foreign EORs and staffing businesses supplying workers who actually work in the Netherlands. The core test is if workers are supplied for payment under another party's supervision and direction, subject to the statutory exceptions. Calling the arrangement an employer-of-record service, consultancy or local partnership does not settle that question.

If your model runs through a local partner, check every outsourcing link. Supplying workers through another staffing business is permitted, but both the employer and the business supplying them onwards must have the required admission, exemption or transitional status. A licensed partner does not remove your own obligations. The end client also needs to check the worker's actual employer.

WHAT TO DO BEFORE 1 NOVEMBER

Check if your business falls within the rules as an EOR or labour outsourcer and decide which application route fits your situation. If you need an inspection report, discuss preparation and availability with an inspection body authorised to carry out Wtta inspections. Make someone responsible for the December registration deadline and the application that follows.

If you use a local partner, establish which entities in the chain need admission and who is responsible for each application. Do not assume that your partner's preparations cover your own business.

Finally, tell your Dutch clients what you are doing. From 1 January 2028, they must check that their suppliers are entitled to outsource under the new rules. Using a supplier that lacks the required status can expose them to fines. The clients who understand your route and timetable now will have fewer questions when the register opens.

Need support ?

If you want to know where the Wtta leaves your Dutch placements, your EOR or partner arrangements, or your client contracts, get in touch. We will walk you through which entities need admission, the route that fits, and what to have ready before the registration window opens. Contact us today to discuss how can we support you.

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