In the coming period, several changes will be implemented that are relevant to parties working with employees and self-employed persons. Below is an overview of three developments that may affect your contract processes, certifications, and risk position: new SNA module for self-employed services, end of leniency by the Tax and Customs Administration, and update on digital signing of payroll taxes.
New: SNA introduces module for self-employed intermediary services (effective 1 January 2026)
As of 1 January 2026, the SNA will expand its quality mark with an additional module for organisations that â in addition to the provision of labour (TBA) â also offer Mediation and/or Intervention for self-employed persons (zzp’ers). This means that intermediaries who facilitate the hiring of self-employed persons will also be certified and audited for these services.
Why this expansion?
The deployment of self-employed workers has been under pressure for some time due to:
- uncertainty in legislation, supervision and case law,
- caution on the part of clients due to the risks of bogus self-employment,
- and a growing need for clarity and quality assurance.
The new SNA module should contribute to a single, recognisable standard for both the deployment of employees and the hiring of self-employed persons â including documentation, assessment and process control.
Key features
| Component | Explanation |
| Mandatory for | All SNA quality mark holders who offer self-employed mediation and/or intervention |
| Content | Standards include assignment description, entrepreneur check, process files, transparency & chain responsibility |
| Inspection begins | 1 January 2026 |
| Transition period | Until 30 June 2026 (no loss of quality mark in the event of shortcomings) |
| Status standard requirements | Final coordination with NBBU, ABU, Bovib and SNA â publication expected in Q4 2025 |
2. Tax authorities to end âsoft landingâ for bogus self-employment as of 1 January 2026
The tax authorities have confirmed that the current leniency period â during which no penalties were imposed if clients could demonstrate that they had made efforts to comply â will end on 31 December 2025.
From 1 January 2026, inspections may once again result in fines, additional tax assessments and corrections in cases of incorrectly designated self-employed constructions. What will change?
| Until 31 December 2025 | From 1 January 2026 |
| No penalties for reasonable effort | Penalties possible for bogus self-employment |
| Inspections primarily focused on providing information | IInspections focused on enforcement |
| Additional tax assessment only for malicious parties | Additional payroll tax assessments possible until 1 January 2025 |
- Important: fines only apply to new offences from 2026 onwards.
- Additional tax assessments may be backdated to 1 January 2025 (end of enforcement moratorium).
- Work carried out before 2025 is not covered by this, unless there is evidence of malicious intent.
Status of legislation
Two bills concerning labour relations are currently being debated in the House of Representatives:
- Self-Employed Persons Act (private member’s bill) â includes minimum rates and entrepreneur test
- VBAR Act â clarifies authority test, embedding, entrepreneurial risk
Due to the elections and the formation of a new cabinet, the implementation date is uncertain, but the issue is high on the political agenda.
Digital signature for payroll taxes: QAES recommended â AES still permitted
Previous reports from the market stated that only qualified electronic signatures (QAES/QES) would still be permitted for payroll tax declarations. This appears to be incorrect or at least premature.
Current status based on available sources:
- The QAES is always legally valid (full legal validity, equivalent to a wet signature).
- The advanced electronic signature (AES) remains permitted for payroll tax-related documents for the time being.
(E.g. DocuSign / AdobeSign / SignRequest, provided that identity verification and log data are available). - There is no official publication from the Tax and Customs Administration that excludes AES as of 2026.
Recommendation for organisations
We advise not to wait for a formal obligation, but to assess in good time whether QAES is desirable or future-proof, for reasons including:
| Aspect | AES | QAES |
| Legal validity | Depending on context / provability | Altijd gelijk aan natte handtekening |
| Acceptability inspection SNA / NEN / Tax authorities | Currently still permitted, but control risk is increasing | 100% zeker |
| Identity check | Often via e-mail / IP-adres | Via erkende trust-provider (eIDAS) |
| Chance that legislation will make it mandatory | TIncreasing | Already fully compliant |
Need help with implementation, impact assessment or compliance advice?
We provide support with:
- preparation for SNA module self-employed service provision
- risk analysis of hiring self-employed workers in connection with the end of the soft landing period
- setting up a digital signing process (AES â QAES migration)
Please feel free to contact us at legal@aame.nl or +31 (0)15 215 8815 .