News overview

What happened

The Nederlandse Autoriteit Uitleenmarkt (NAU), which grants admissions on behalf of the Minister of Social Affairs and Employment, announced on 2 November 2026 that lenders of staff can register for the transitional scheme of the Wet toelating terbeschikkingstelling van arbeidskrachten (Wtta). The window runs from 1 November to 31 December 2026. Registration, followed by an application for admission or an exemption between 1 May and 30 June 2027, lets a lender go on supplying workers past 1 January 2028 if the NAU has not decided on its file by then.

The Wtta enters into force on 1 January 2027. With the exceptions below, it requires admission for a company that, for payment, supplies workers to work in the Netherlands under another company’s direction and supervision. From 1 January 2028 a breach can bring a fine from the Netherlands Labour Authority for the lender and for the hirer.

Announced
2 November 2026, by the NAU
Registration window
1 November to 31 December 2026
In force
1 January 2027
Enforcement
From 1 January 2028, by the Netherlands Labour Authority

Check before acting: Ask your EOR in writing which legal entity employs your people in the Netherlands and whether that entity has registered for the Wtta transitional scheme. The NAU’s public register of lenders is due from 1 July 2027.

Payroll companies and foreign providers fall inside the Wtta

The Wtta, passed by the Senate on 11 November 2025, amends an older act, the Waadi, which defines payrolling as a form of supplying workers in which the provider did not match the worker to the client on the labor market and may place the worker elsewhere only with the client’s consent. The NAU names payroll companies among the lenders covered. Where the work is done decides coverage, according to its decision tree, so a provider established abroad is covered for work in the Netherlands.

That definition is close to what an employer of record is: a company that employs a person you chose and places that person under your daily direction. Neither the amended Waadi nor the NAU pages we read use the term “employer of record”. Our reading: an EOR whose employees work in the Netherlands under a client’s direction fits the Act’s description of a lender. Notes by the law firms Law & More and CMS and by Meijburg & Co each say payroll companies are in scope; none of them names EOR. If that reading holds for your employer of record in the Netherlands, admission is the provider’s duty and the hirer’s checks are yours, so ask the provider to confirm its own position.

Lending within a group and collegial lending for no more than wage costs fall outside the Act. The exemption for lenders whose lending revenue is under 10% of turnover and at most EUR 5 million a year is closed to temporary agencies and payroll companies, the NAU says. Germany already requires a license for employee leasing under section 1 of its Arbeitnehmerüberlassungsgesetz, which also caps an assignment with one hirer at 18 consecutive months unless a collective agreement differs; ask about that limit if you use an employer of record in Germany.

Registration is the first of two steps

To register, a lender needs eHerkenning at level 3 or higher and a Berichtenbox voor Bedrijven, a government message box, and reports its expected 2026 turnover, in total and from supplying workers, and the application it plans to file. A provider based abroad must first enter the Dutch Business Register at the Chamber of Commerce (KVK), and the NAU warned on 6 August 2026 that the digital credentials can take several weeks.

Registration is optional for a lender that will hold a valid SNA quality mark with the “making workers available” module on 30 June 2027, because a first application can rest on that mark instead of an inspection report; the NAU advises registering anyway. A lender that skips the window and has no admission or exemption by 1 January 2028 has to stop supplying workers.

Admission itself requires an inspection report or the SNA mark, a certificate of conduct (VOG) and, unless waived, a deposit of EUR 100,000 (EUR 50,000 for a new lender under provisional admission). A foreign company with no Dutch directors needs no VOG, the NAU says. Admission lasts four years.

Date What happens Who acts
Date
1 November to 31 December 2026
What happens
Registration for the transitional scheme
Who acts
Lenders
Date
1 January 2027
What happens
Wtta enters into force; record-keeping duties begin
Who acts
Lenders and hirers
Date
1 May to 30 June 2027
What happens
Applications for admission, provisional admission or exemption
Who acts
Lenders
Date
From 1 July 2027
What happens
NAU assesses applications; public register shows each lender’s status
Who acts
NAU; hirers can check
Date
From 1 January 2028
What happens
Lending and hiring without admission, exemption or transitional status are prohibited; fines can follow
Who acts
Netherlands Labour Authority

Wtta dates published by the NAU and in Staatsblad 2026, 159

Hirers must keep records from 2027 and can be fined from 2028

Under article 12d of the amended Waadi, a hirer’s own records must name each supplied worker and the supplying legal entity or business by the day the assignment starts, and be kept for at least seven years after the calendar year in which the assignment ends. The commencement decree (Staatsblad 2026, 159) brings that duty into force on 1 January 2027.

From 1 January 2028, the NAU says, a hirer’s lender must hold an admission or exemption or be covered by the transitional scheme, save for statutory exceptions. Its checklist for hirers advises checking the public register when an assignment starts, keeping proof, and stopping the assignment if admission is suspended or withdrawn.

Articles 16 and 19 of the amended Waadi cap the fine per violation at the fifth category of the Dutch Criminal Code, for lender and hirer alike. The government’s statute database lists that category at EUR 110,000 from 1 January 2026, the figure Forvis Mazars cites. Meijburg’s note of 18 September 2026 says EUR 103,000 and CMS’s note of 16 December 2025 says EUR 90,000, the amounts the database shows for 2024 and 2022. The category is indexed every two years, so it is due to change again on 1 January 2028, and the amounts per type of violation are left to policy rules. The fine is raised by 100% when the same breach is found again within five years and the earlier fine is final.

Six things to ask your EOR before 31 December 2026

Admission cannot be transferred, Loyens & Loeff writes: it attaches to the legal entity or business as entered in the Business Register, so the employing entity is the fact to pin down. The NAU checklist recommends that hirers ask their lenders whether they will register.

  1. Employing entity. Which legal entity, with which KVK number, employs your people in the Netherlands.
  2. Structure. Whether that entity belongs to the provider or to a partner; our guide to direct vs indirect EOR describes both. In a partner chain, ask how each company between the worker and you is covered: the NAU says every lender in such a chain needs admission, an exemption or transitional status.
  3. Registration. Whether the provider treats that entity as a lender under the Wtta and has registered it for the transitional scheme, or will by 31 December 2026.
  4. SNA quality mark. Whether it holds an SNA quality mark with the module for making workers available, and until what date.
  5. Application. Whether it will apply between 1 May and 30 June 2027, and by which route.
  6. Contract. Whether your agreement requires admission, exemption or transitional status for its full term, obliges the provider to report a status change at once, and states what follows a suspension or withdrawal. Our employer of record contract checklist covers the other clauses to read.

If a provider cannot name its entity or its route to admission before the hiring ban starts on 1 January 2028, our guide on how to switch EOR providers sets out the steps for moving the employment. If you are still comparing the best EOR providers for a Dutch hire, put the same six points to each, with the checks in our guide on how to choose an employer of record.

Where things stand on 11 November 2026

Registration closes in 50 days, the Act enters into force the next day, and applications for admission open on 1 May 2027. The Wtta register is not public yet, so until 1 July 2027 a provider’s Wtta status rests on its own statement; until then the NAU points hirers to the existing Waadi register at the Chamber of Commerce.

Fees are not set: the NAU expects to publish application and annual fees in early 2027 and says the 2027 annual fee will not exceed EUR 3,611. The statute database still marks the 2028 text of the Waadi as open to change. The NAU pages we read describe a provider abroad supplying a company in the Netherlands; they do not spell out how the hirer duties apply when the client has no Dutch presence and the employee works from home in the Netherlands, a common EOR arrangement. Ask your provider how it reads that case.

Wtta and EOR FAQs

Does the Wtta apply to employer of record providers?

Probably, in our reading, though no official source we read says so. The Act covers a company that, for payment, supplies workers to work in the Netherlands under another company’s direction and supervision, and the NAU names payroll companies. Ask your provider to confirm its own position.

What is the deadline to register for the Wtta transitional scheme?

The deadline is 31 December 2026. Registration opened on 1 November 2026 and requires eHerkenning at level 3 or higher and a Berichtenbox voor Bedrijven. The lender must then apply for admission or an exemption between 1 May and 30 June 2027.

What must a company that hires through a Dutch EOR do under the Wtta?

If your EOR counts as a lender, two hirer duties follow. A hirer must record which worker is supplied by which lender from 1 January 2027, and from 1 January 2028 may take workers only from a lender that is admitted, exempt or covered by the transitional scheme. The NAU pages we read do not cover a client with no Dutch presence.

What is the fine for hiring from a lender without Wtta admission?

The ceiling is the fifth-category fine in the Dutch Criminal Code, which the government’s statute database lists at EUR 110,000 per violation from 1 January 2026. It applies to lenders and hirers once enforcement starts on 1 January 2028. Notes by Meijburg and CMS quote EUR 103,000 and EUR 90,000, the amounts set in 2024 and 2022.

Sources

The sources behind this story, grouped by type. Dates show when each was published or when we last checked it.

Laws and official guidance

15 sources

  1. Nederlandse Autoriteit Uitleenmarkt (Ministry of Social Affairs and Employment) · toelatinguitleenmarkt.nl

    Uitleners kunnen zich nu aanmelden voor de overgangsregeling

    Published 2 Nov 2026

  2. Nederlandse Autoriteit Uitleenmarkt (Ministry of Social Affairs and Employment) · toelatinguitleenmarkt.nl

    Aanmelden voor de overgangsregeling

    Checked 11 Nov 2026

  3. Nederlandse Autoriteit Uitleenmarkt (Ministry of Social Affairs and Employment) · toelatinguitleenmarkt.nl

    Lending workers in the Netherlands from abroad

    Checked 11 Nov 2026

  4. Nederlandse Autoriteit Uitleenmarkt (Ministry of Social Affairs and Employment) · toelatinguitleenmarkt.nl

    Beslisboom

    Checked 11 Nov 2026

  5. Nederlandse Autoriteit Uitleenmarkt (Ministry of Social Affairs and Employment) · toelatinguitleenmarkt.nl

    Inleners

    Checked 11 Nov 2026

  6. Nederlandse Autoriteit Uitleenmarkt (Ministry of Social Affairs and Employment) · toelatinguitleenmarkt.nl

    Checklist: wat moet u doen als inlener?

    Checked 11 Nov 2026

  7. Nederlandse Autoriteit Uitleenmarkt (Ministry of Social Affairs and Employment) · toelatinguitleenmarkt.nl

    Doorlenen: waar let u op als inlener?

    Checked 11 Nov 2026

  8. Nederlandse Autoriteit Uitleenmarkt (Ministry of Social Affairs and Employment) · toelatinguitleenmarkt.nl

    Openbaar register uitleners

    Checked 11 Nov 2026

  9. Nederlandse Autoriteit Uitleenmarkt (Ministry of Social Affairs and Employment) · toelatinguitleenmarkt.nl

    Vraag eHerkenning niveau 3 en Berichtenbox voor Bedrijven op tijd aan

    Published 6 Aug 2026

  10. Overheid.nl (Wettenbank) · wetten.overheid.nl

    Wet allocatie arbeidskrachten door intermediairs

    Checked 11 Nov 2026

  11. Overheid.nl (Officiële bekendmakingen) · zoek.officielebekendmakingen.nl

    Staatsblad 2026, 159

    Published 29 Jun 2026

  12. Overheid.nl (Wettenbank) · wetten.overheid.nl

    Wetboek van Strafrecht

    Checked 11 Nov 2026

  13. Eerste Kamer der Staten-Generaal · eerstekamer.nl

    Wet toelating terbeschikkingstelling van arbeidskrachten (36.446)

    Checked 11 Nov 2026

  14. Rijksoverheid · rijksoverheid.nl

    Nieuwe wet voor aanpak misstanden bij uitzendbureaus en andere uitleners (Wtta)

    Checked 11 Nov 2026

  15. Bundesministerium der Justiz und für Verbraucherschutz (Gesetze im Internet) · gesetze-im-internet.de

    Gesetz zur Regelung der Arbeitnehmerüberlassung (Arbeitnehmerüberlassungsgesetz – AÜG) § 1 Arbeitnehmerüberlassung, Erlaubnispflicht

    Checked 11 Nov 2026

Press and analysis

5 sources

  1. Meijburg & Co · meijburg.com

    New admission requirement for personnel providers: what does the Wtta mean for hirers and providers?

    Published 18 Sep 2026

  2. CMS · cms.law

    Netherland’s Labour Provision Admission Act to go into effect in 2027

    Published 16 Dec 2025

  3. Law & More · lawandmore.eu

    Wtta: what lenders and hirers must arrange for admission by 2027

    Published 6 Mar 2026

  4. Loyens & Loeff · loyensloeff.com

    Het ter beschikking stellen van werknemers via intermediairs: wat verandert er voor uitleners en inleners

    Published 1 May 2026

  5. Forvis Mazars · forvismazars.com

    Wtta: Admission Regime for Labour Supply in the Netherlands

    Published 26 Oct 2026

If you spot an error or a newer source, send it through the contact page and we’ll review it.

This article reports company announcements, filings and public pages as they stood on the dates shown. It is general information, not legal, tax, accounting or financial advice. Provider terms change, so confirm the current terms in writing before you sign. Read our fact-checking standards or report a correction.