WTTA 2027: Is Your Recruitment Firm Prepared?

A practical masterclass for recruitment firms, temporary staffing agencies, secondment firms, payroll companies, brokers, MSPs, and international staffing organizations.

The Act on the Authorization of the Provision of Workers, known by its Dutch abbreviation Wtta, will fundamentally change the Dutch labor-supply market.

The Wtta enters into force on January 1, 2027. From January 1, 2028, companies may only supply workers in the Netherlands if they hold a valid authorization or exemption, fall under the transitional arrangement, or can rely on a statutory exception.

Hirers will also have obligations. They must verify which labor suppliers they work with, keep records of the workers deployed, and from January 1, 2028 may no longer hire workers from a supplier that is subject to the authorization requirement but does not have valid status.

The most important question is not:

“Are we a temporary employment agency?”

The correct question is:

“Do we supply workers who work under the direction and supervision of another party?”

The name of your organization, the title of your agreement, and the country in which your company is established are not decisive.

The facts determine whether the Wtta applies.

From January 1, 2028, your Wtta status will also help determine whether you retain access to Dutch clients and supply chains.

WATCH THE FREE WTTA MASTERCLASS

In our WTTA Masterclass, we explain in clear language:

  • who is subject to the Wtta;
  • when authorization is required;
  • how the rules apply to foreign recruitment firms;
  • what on-supply means for brokers and MSPs;
  • which exceptions and exemptions may be available;
  • which obligations apply to labor suppliers and hirers;
  • which authorization requirements must be met;
  • and which steps you must take before the application period.

Would you like to share this information with Dutch colleagues, directors, shareholders, or clients?

WHO IS THE WTTA RELEVANT TO?

The Wtta may apply to, among others:

  • temporary employment agencies;
  • secondment firms;
  • payroll companies;
  • on-suppliers;
  • brokers and MSPs;
  • consulting firms that effectively supply personnel;
  • foreign recruitment firms that deploy workers in the Netherlands;
  • international staffing organizations without a Dutch establishment;
  • companies that outsource their legal employer responsibilities;
  • back-office and payroll organizations;
  • and companies that supply personnel occasionally or as a secondary activity.

In principle, it does not matter whether supplying personnel is your main activity. A consulting, project, or technology company may also fall within the scope of the Wtta if its employees effectively work under the direction and supervision of a client.

The proportion of revenue generated by labor supply may, however, be relevant when determining whether an exemption is available.

WHEN DOES THE SUPPLY OF WORKERS APPLY?

At its core, the assessment involves three questions:

  1. Does your organization make an employee available to another company?
  2. Does your organization receive payment for doing so?
  3. Does the employee work under the direction and supervision of that other company?

If all three questions are answered in the affirmative, the arrangement may constitute the supply of workers.

It must then be determined:

  • which entity qualifies as the labor supplier;
  • whether on-supply is involved;
  • whether an authorization or exemption is required;
  • whether a statutory exception applies;
  • and which obligations apply to the hirer.

Direction and supervision must be assessed on the basis of how the parties actually work together.

Relevant factors may include:

  • who gives the day-to-day instructions;
  • who plans the work;
  • who determines working hours and the workplace;
  • who supervises the performance of the work;
  • who evaluates the employee;
  • who approves leave;
  • who determines how the work is carried out;
  • and who is responsible for the result.

The written agreement is important, but day-to-day practice is decisive.

THE TITLE OF THE CONTRACT DOES NOT DETERMINE WHETHER THE WTTA APPLIES

An agreement may be described as:

  • consulting;
  • contracting;
  • managed services;
  • contracting for work;
  • service provision;
  • project support;
  • statement of work;
  • or independent services.

These labels do not prevent an arrangement from qualifying as the supply of workers in practice.

If a worker operates within the client’s organization and is managed by that client, the Wtta may apply.

Do not simply give the arrangement a different name.

Examine how the work is actually performed.

ON-SUPPLY, BROKERS, AND MSP STRUCTURES

Recruitment and staffing organizations regularly operate through chains involving several parties.

For example:

Recruiter → broker → MSP → Dutch end client

Or:

Foreign recruiter → payroll company → Dutch hirer

Or:

Legal employer → on-supplier → end client

The involvement of a broker, MSP, payroll company, back-office organization, or other intermediary does not automatically place a party outside the scope of the Wtta.

For each link in the chain, it must be established:

  • who the legal employer is;
  • who contracts with the worker;
  • who pays the wages;
  • who supplies the worker;
  • who supplies the worker onward;
  • who receives payment;
  • who exercises direction and supervision;
  • and which party requires an authorization or exemption.

An on-supplier does not only have obligations as a hirer. In relation to the next party in the chain, the on-supplier may also qualify as a labor supplier.

Where on-supply is involved, both the legal employer and every on-supplier must hold the required Wtta status.

The ultimate hirer must also be able to establish which company formally employs the worker.

The more links the chain contains, the greater the risk of:

  • unclear employer status;
  • a missing authorization;
  • incorrect terms and conditions of employment;
  • incomplete records;
  • and fines or losses for the hirer.

Keep the chain as short and transparent as possible.

FOREIGN RECRUITMENT FIRMS

The Wtta is not limited to companies established in the Netherlands.

A foreign recruitment or staffing firm may also fall within its scope if it supplies employees who actually work in the Netherlands.

The absence of a Dutch private limited company therefore does not prevent the authorization requirement from applying.

International organizations must assess, among other things:

  • which entity contracts with the client;
  • which entity employs the worker;
  • which entity pays the wages;
  • which entity receives payment;
  • whether cross-border posting is involved;
  • which entity qualifies as the actual labor supplier;
  • whether Dutch payroll administration or payroll registration is required;
  • which social security legislation applies;
  • whether A1 certificates are available;
  • whether notifications through postedworkers.nl are required;
  • which terms and conditions of employment must be applied;
  • and which entity must apply for authorization.

Foreign companies must also maintain verifiable records of their Dutch labor-supply activities and comply with the relevant Dutch employment-law, tax, and administrative obligations.

Certain application requirements are adapted for foreign legal entities. For example, a foreign legal entity cannot apply for a Dutch Certificate of Conduct for Legal Entities. If a Dutch director is active within the foreign company, a Certificate of Conduct for Natural Persons may still be required for that director.

WHEN IS NO AUTHORIZATION REQUIRED?

Recruitment and selection only

In principle, authorization is not required for recruitment and selection only.

This will generally be the case if:

  • the recruiter only introduces a candidate;
  • the candidate enters into employment directly with the client;
  • the recruiter does not become the candidate’s employer;
  • and the recruiter does not supply an employee after the introduction.

A one-off recruitment or introduction fee does not in itself constitute the supply of workers.

Contracting for work

The Wtta may also not apply in the case of genuine contracting or outsourcing of work.

The contractor must remain responsible for:

  • organizing the work;
  • day-to-day management;
  • the manner in which the work is carried out;
  • deployment of employees;
  • and the agreed result.

The client may determine the result to be achieved, but may not in practice exercise direction and supervision over the contractor’s employees.

If actual practice differs from the agreement, the arrangement may still qualify as the supply of workers.

Other exceptions

Specific exceptions also exist for, among others:

  • certain non-profit peer-lending arrangements;
  • certain situations within the same company or group;
  • social development companies that provide adapted work for people with occupational disabilities;
  • certain work-study programs administered through a foundation;
  • and licensed private security organizations and investigation agencies.

These exceptions must be applied cautiously. The precise facts and statutory conditions remain decisive.

SELF-EMPLOYED WORKERS AND FALSE SELF-EMPLOYMENT

Working with self-employed contractors does not automatically place the Wtta outside the scope of consideration.

A self-employed contractor who genuinely works for their own account and risk is, in principle, not an employee supplied by an employer.

However, the labels “self-employed contractor,” “freelancer,” or “contractor” are not decisive.

If the working relationship has the characteristics of an employment contract in practice, employment-law and tax risks may arise. If the worker is then supplied through another company and works under the direction and supervision of the client, the Wtta may also become relevant.

The following questions must therefore be examined separately and in conjunction with one another:

  • is the person genuinely operating as an independent contractor?
  • could an employment contract exist?
  • if so, who is the employer?
  • is the employee supplied by that employer to a third party?
  • who exercises direction and supervision?
  • and which Wtta obligations follow from this?

Do not assume that the Wtta does not apply merely because an agreement uses the term “self-employed” or “contractor.”

Examine the actual working relationship.

EXEMPTION FOR LIMITED LABOR-SUPPLY ACTIVITIES

A company that supplies employees only to a limited extent may apply for an exemption under certain conditions.

In broad terms:

  • less than 10% of total annual revenue must come from the supply of workers;
  • this labor-supply revenue must be below €5 million per year;
  • and the company must have paid wages for at least twelve months before the application.

The figures must be supported by an accountant’s statement covering the year preceding the application.

The relevant information must subsequently be resubmitted to the Dutch Labor Market Authority each year.

Temporary employment agencies and payroll companies cannot use this exemption route.

An exemption only relates to the authorization requirement. Other statutory obligations remain in force, including obligations concerning:

  • record keeping;
  • provision of information;
  • terms and conditions of employment;
  • housing;
  • and registration of migrant workers.

An exemption is therefore not a general exemption from the Wtta.

Are you unsure whether your organization qualifies as a labor supplier, falls under an exception, or is eligible for an exemption?

Have this assessed before registration for the transitional arrangement opens.

WHAT IS REQUIRED FOR AUTHORIZATION?

To obtain and retain authorization, a labor supplier must meet requirements concerning, among other things:

  • correct registration in the Commercial Register;
  • a Certificate of Conduct, where applicable;
  • financial security;
  • compliance with the statutory standards framework;
  • verifiable personnel, payroll, and financial records;
  • and periodic inspections by a designated inspection body.

CERTIFICATE OF CONDUCT FOR LEGAL ENTITIES

In principle, Dutch legal entities must submit a Certificate of Conduct for Legal Entities with their application.

At the time of application, the certificate may not be more than three months old.

The assessment covers not only the legal entity, but also, among others:

  • directors;
  • managers;
  • and other individuals who help determine company policy.

A new Certificate of Conduct must be submitted following a change in the board.

A foreign legal entity cannot apply for a Dutch Certificate of Conduct for Legal Entities. This requirement therefore does not apply to foreign companies in the same way. If the foreign company has a Dutch director, that director may need to apply for a Certificate of Conduct for Natural Persons.

THE SECURITY DEPOSIT

The standard security deposit is €100,000.

A new labor supplier may initially receive provisional authorization for six months. The security deposit for the first application is €50,000.

When applying for definitive authorization, this amount must in principle be increased to €100,000.

The Dutch Labor Market Authority may extend a provisional authorization once, for no more than six months.

The security deposit may be used if a labor supplier fails to meet its financial obligations, for example if:

  • wages are not paid;
  • taxes or social security contributions are not remitted;
  • or imposed fines are not paid.

Repayment after four years

The obligation to maintain the security deposit may end after four years if, throughout that period, the labor supplier:

  • continuously held valid authorization;
  • demonstrably supplied employees;
  • and the security deposit was not used by the Dutch Tax and Customs Administration or the Dutch Labor Inspectorate.

If the company stops supplying workers sooner, the security deposit may be reclaimed under certain conditions after a waiting period.

SECURITY-DEPOSIT WAIVER FOR EXISTING LABOR SUPPLIERS

An existing labor supplier may qualify for a waiver of the security deposit for its first application, subject to certain conditions.

The company must be able to demonstrate that it:

  • had already been registered continuously with the Dutch Chamber of Commerce for at least four years on December 31, 2026, with labor supply recorded as a business activity;
  • actually supplied employees during those four years;
  • and holds a valid statement from the Dutch Tax and Customs Administration confirming that taxes and social security contributions have been paid.

At the time of application, the statement from the Dutch Tax and Customs Administration may not be more than three months old.

The company’s incorporation date alone is therefore not sufficient.

Both the registered business activity and the actual history of labor supply must be substantiated.

Relevant evidence may include:

  • employment contracts;
  • hiring and labor-supply agreements;
  • payroll records;
  • sales invoices;
  • time records;
  • payroll tax returns;
  • wage payments;
  • and other documents demonstrating actual labor-supply activities.

A waiver of the security deposit is different from an exemption from the authorization requirement.

The two arrangements have their own conditions and consequences.

WHAT DOES THE WTTA COST?

The Wtta involves several different costs.

Costs charged by the Dutch Labor Market Authority

The Dutch Labor Market Authority charges fees for:

  • an application for authorization;
  • an application for provisional authorization;
  • an application for an exemption;
  • and annual registration in the public register.

The application fee is the same for every applicant. The annual register fee partly depends on the company’s revenue and the period during which the company is authorized in that year.

The definitive rates for 2027 will be published before January 1, 2027.

The maximum amount that the Dutch Labor Market Authority may charge for 2027 is €3,611.

This amount is not the same as the total investment that may be required for Wtta compliance.

An application is only considered complete when:

  • all required information and documents have been submitted;
  • and the application fee has been paid.

If the application is refused, the application fee will not be refunded.

Other costs

In addition to the fees charged by the Dutch Labor Market Authority, a company should take into account, among other things:

  • the security deposit of, in principle, €100,000;
  • the costs of periodic Wtta inspections;
  • any follow-up inspections;
  • any SNA certification;
  • preparatory reviews;
  • applications for statements and documentation;
  • amendments to agreements;
  • changes to payroll and payroll administration;
  • changes to time recording and invoicing;
  • improvements to internal procedures;
  • and internal and external costs of ongoing compliance.

The actual investment depends on your business model, existing certifications, records, contracts, and position in the chain.

Early preparation prevents duplicated work, remediation costs, and delays to the application.

ANNUAL WTTA INSPECTION

Authorization entails an ongoing inspection obligation.

During the initial phase of the Wtta system, the general inspection frequency is set at once every twelve months.

At this frequency, every periodic inspection is a full inspection of all parts of the standards framework that apply to the company.

It is therefore not merely a limited administrative update.

The inspection may cover, among other things:

  • personnel records;
  • payroll records;
  • financial records;
  • employment contracts;
  • hiring and labor-supply agreements;
  • terms and conditions of employment and remuneration;
  • time records;
  • wage payments;
  • invoicing;
  • payroll taxes;
  • VAT;
  • identification;
  • work permits;
  • housing;
  • and hiring and on-supply arrangements.

The inspection is carried out using a sample of the files of supplied workers.

If deficiencies are identified, a follow-up inspection may be required as part of the inspection process.

The Dutch Labor Market Authority may also require an additional interim inspection report if it receives indications of non-compliance.

The statutory intention is ultimately to increase the inspection frequency. Once sufficient inspection capacity is available, the frequency may be adjusted.

The Wtta is therefore not a one-off permit, but a permanent compliance process.

THE TRANSITIONAL ARRANGEMENT

The transitional arrangement is intended for existing labor suppliers that wish to continue their activities while their application is being assessed.

Two important periods apply in order to make use of this arrangement:

  • registration for the transitional arrangement from November 1 through December 31, 2026;
  • and submission of the application from May 1 through June 30, 2027.

A company that meets the conditions of the transitional arrangement on time may continue supplying employees while the Dutch Labor Market Authority assesses its application.

This also applies if no final decision has been made on the application by January 1, 2028.

If the application is not submitted by June 30, 2027, the transitional arrangement cannot be used.

The company must then actually be authorized by January 1, 2028. Without valid status, it may no longer supply workers from that date.

LABOR SUPPLIERS WITH SNA CERTIFICATION

If a company holds valid SNA certification on June 30, 2027, a simplified route applies to its first application.

For that first application only, the company does not need to submit a separate Wtta inspection report.

The other authorization requirements continue to apply, including, where relevant:

  • the Certificate of Conduct;
  • the security deposit;
  • the other application requirements;
  • the reliability assessment;
  • and compliance with the standards framework.

A company with valid SNA certification on June 30, 2027 is not required to register for the transitional arrangement between November 1 and December 31, 2026.

The Dutch Labor Market Authority nevertheless strongly recommends registration.

If the company loses its SNA certification between January 1 and June 30, 2027 and did not register on time, it may lose its transitional status.

Our practical advice is therefore:

Register for the transitional arrangement on time, even if you hold SNA certification.

SNA certification only replaces the separate Wtta inspection report for the first application. Periodic Wtta inspections remain mandatory after authorization has been granted.

LABOR SUPPLIERS WITHOUT SNA CERTIFICATION

If a company does not hold valid SNA certification on June 30, 2027, a Wtta inspection report will ultimately be required for authorization.

If the company registered for the transitional arrangement on time and submitted its application by June 30, 2027, it may continue supplying workers under certain conditions while awaiting the inspection report and the decision of the Dutch Labor Market Authority.

The company must be able to demonstrate that it is actively working to obtain the required inspection report.

During this period, the company will have a separate transitional status in the public register.

WHAT MUST YOU ARRANGE BEFORE NOVEMBER 1, 2026?

Do not wait until November to begin the practical preparations.

To register for the transitional arrangement, you will need, among other things:

  • eHerkenning Level 3;
  • a Message Box for Businesses linked to the correct Chamber of Commerce registration;
  • the expected total annual revenue for 2026;
  • the expected revenue from the supply of workers for 2026;
  • and a preliminary choice of the type of application you expect to submit in 2027.

Applying for and correctly linking eHerkenning and the Message Box for Businesses may take time.

Before November 1, 2026, also check:

  • which entity supplies employees;
  • whether the correct entity is registered with the Dutch Chamber of Commerce;
  • whether labor supply is correctly recorded as a business activity;
  • which entity must apply for authorization;
  • whether on-supply is involved;
  • whether an SNA certification process is required or desirable;
  • whether a waiver of the security deposit may be available;
  • whether the historical labor-supply activities can be substantiated;
  • whether contracts and terms and conditions of employment are compliant;
  • whether foreign registrations and notifications are correct;
  • and whether the personnel, payroll, time, and financial records are ready for inspection.

Registration is not a substitute for the final application.

After registration, the formal application must be submitted between May 1 and June 30, 2027.

THE WTTA STANDARDS FRAMEWORK

The standards framework is at the heart of the authorization system.

It is not only a matter of submitting an application. A labor supplier must be able to demonstrate continuously that the organization complies with the relevant employment-law, tax, and administrative obligations.

The standards framework largely aligns with existing legislation and parts of NEN 4400 and SNA certification, but it also contains additional requirements.

Inspections may cover, among other things:

  • payroll tax and social security contributions;
  • VAT;
  • the statutory minimum wage;
  • statutory minimum holiday allowance;
  • timely payment of wages;
  • the Working Hours Act;
  • the Foreign Nationals Employment Act;
  • identification;
  • residence and work permits;
  • written terms and conditions of employment;
  • the Waadi;
  • the applicable terms and conditions of employment and remuneration;
  • payroll records;
  • time records;
  • invoicing;
  • hiring and on-supply;
  • housing;
  • registration of migrant workers;
  • and reconciliation between personnel, payroll, and financial records.

Authorization is therefore not a one-off certificate.

Compliance must be structurally embedded within the organization.

A POSITIVE INSPECTION REPORT DOES NOT AUTOMATICALLY RESULT IN AUTHORIZATION

A positive inspection report does not automatically mean that a company will be authorized.

The Dutch Labor Market Authority also considers information from other authorities, including:

  • the Dutch Tax and Customs Administration;
  • the Dutch Labor Inspectorate;
  • and the Dutch Chamber of Commerce.

A reliability assessment is also carried out.

This assessment may consider, among other things:

  • tax debts;
  • previous sanctions;
  • a history of bankruptcy;
  • possible sham arrangements;
  • and the reliability of the company and its policy-makers.

Historical compliance, the corporate structure, and actual business operations may therefore also affect the application.

A technically sound inspection file is essential, but it is only one part of the overall assessment.

TERMS AND CONDITIONS OF EMPLOYMENT AND REMUNERATION

A labor supplier must be able to demonstrate that the applicable terms and conditions of employment and remuneration rules have been correctly identified and applied.

Complete and up-to-date information from the hirer is required for this purpose.

The basic salary is not the only relevant element. Depending on the applicable legislation, collective labor agreement, and employment-conditions scheme, other elements may also be relevant, including:

  • salary scales;
  • classification within the salary scale;
  • periodic increments;
  • pay increases;
  • working hours;
  • overtime;
  • shift allowances;
  • irregular-hours allowances;
  • holiday allowance;
  • leave;
  • reduced working hours arrangements;
  • bonuses;
  • a thirteenth-month payment;
  • expense allowances;
  • pension;
  • and benefits in cash or in kind.

The hirer must provide the relevant information on terms and conditions of employment.

The labor supplier must:

  • assess this information;
  • process it correctly;
  • provide it to the employee in writing;
  • and be able to substantiate it through its records.

NOTIFICATION AND RECORD-KEEPING OBLIGATIONS

Before the supply of a worker begins, the labor supplier must notify the hirer in writing or electronically which employee will be supplied.

The labor supplier’s records must show, among other things:

  • which employee is supplied;
  • to which hirer the employee is supplied;
  • the start date;
  • the expected end date, if known;
  • the position;
  • the contact person;
  • the work location;
  • and the hours worked.

Before the work begins, the hirer must also record:

  • which employee will be deployed;
  • through which labor supplier the employee will be deployed;
  • and, in the case of on-supply, which company formally employs the worker.

The personnel, time, payroll, and invoicing records must be capable of being reconciled and verified.

This means, among other things, that the following data must correspond:

  • hours worked;
  • hours processed through payroll;
  • hours paid;
  • hours invoiced;
  • leave hours;
  • sickness hours;
  • time-off-in-lieu hours;
  • and any unassigned hours.

Where necessary, time records must include start and end times, unpaid breaks, and the work location.

Invoices must contain sufficient information to trace the worker, the period, and the hours worked.

The relevant records must be retained for at least seven years.

MIGRANT WORKERS, THE BRP, AND HOUSING

Additional obligations apply to migrant workers.

A labor supplier must inform employees about their registration obligations in a way they can understand.

In the designated situations, the labor supplier must satisfy itself that the employee is correctly registered in the Personal Records Database, known as the BRP.

For foreign employees, the following may also be relevant:

  • the right to work in the Netherlands;
  • identity documents;
  • residence permits;
  • work permits;
  • A1 certificates;
  • Dutch payroll taxes;
  • social security contributions;
  • and notifications through postedworkers.nl.

If the labor supplier provides or arranges housing, that housing must meet the applicable quality requirements.

Official implementation information refers, among other things, to housing with SNF certification or housing provided through a housing association.

The arrangements concerning employment and housing must be recorded separately and in writing. Employment and accommodation may not be linked automatically.

These obligations must not only be performed, but must also be demonstrably embedded in procedures and files.

OBLIGATIONS FOR HIRERS

The Wtta does not only affect labor suppliers.

Dutch hirers must also prepare.

A hirer must, among other things:

  • identify all labor suppliers from which personnel are hired;
  • assess whether those suppliers are subject to the authorization requirement;
  • check the supplier’s status in the public register from July 1, 2027;
  • check again when the hiring begins whether the supplier has the correct status;
  • retain evidence of this check in the supplier or hiring file;
  • record before the start which employee is deployed through which labor supplier;
  • provide the applicable terms and conditions of employment;
  • periodically check during the relationship whether the status remains valid;
  • supervise subcontractors and on-supply chains;
  • and appoint an internal person responsible for Wtta checks.

Agreements with labor suppliers should stipulate, among other things:

  • that the required authorization or exemption must remain valid throughout the relationship;
  • that changes to the authorization status must be reported immediately;
  • which subcontractors or on-suppliers may be used;
  • what happens in the event of suspension or revocation;
  • and how existing placements and continuity of service will be handled.

The hirer must train the relevant departments to:

  • recognize the supply of workers;
  • verify authorizations;
  • recognize on-supply;
  • and identify supplier risks.

ON-SUPPLY: CHECK THE ENTIRE CHAIN

In an on-supply arrangement, checking only the direct contracting party is not sufficient.

The hirer must also establish which company formally employs the worker.

Both the legal employer and the company that supplies the worker onward must hold:

  • valid authorization;
  • an exemption;
  • or valid transitional status.

The identity of the legal employer must be passed on to the next party in the chain in a verifiable manner.

Information on terms and conditions of employment must also reach the correct labor supplier through the chain.

When on-supply is involved, check:

  • who the legal employer is;
  • which parties supply the worker onward;
  • whether every labor supplier holds the correct status;
  • whether information on terms and conditions of employment flows correctly through the chain;
  • whether the time records and invoices correspond;
  • and whether the contracts prohibit new links from being added without permission.

THE PUBLIC WTTA REGISTER

From July 1, 2027, hirers will be able to check a labor supplier’s status in the public register maintained by the Dutch Labor Market Authority.

The register may contain information about:

  • an authorization;
  • a provisional authorization;
  • an exemption;
  • valid transitional status;
  • a suspension;
  • or a revocation.

In principle, an authorization is granted for four years. A new application must be made after that period.

Hirers can subscribe to notifications from the register. They will then be informed when a labor supplier’s authorization status changes.

For recruitment and staffing firms, correct registration will not only be a legal requirement.

It will also become a commercial condition for retaining access to clients, brokers, MSPs, and international supply chains.

WHAT HAPPENS IF AN AUTHORIZATION IS SUSPENDED OR REVOKED?

The Dutch Labor Market Authority may suspend or revoke an authorization if a company no longer meets the conditions.

A suspension is temporary and, in principle, gives the labor supplier an opportunity to remedy the deficiencies identified.

During a suspension, the labor supplier may:

  • only continue deploying employees who are already working for their hirer;
  • not supply new employees;
  • and not enter into new hiring relationships.

Following revocation, the labor supplier may no longer supply employees after the effective date.

A decision to suspend or revoke takes effect no later than four weeks after notification. The effective date is recorded in the public register.

Between notification and the effective date, only existing placements may continue under certain conditions. New employees and new hirers are not permitted.

Labor suppliers and hirers should therefore agree contractually in advance:

  • that a change in authorization status must be reported immediately;
  • that new placements can be stopped immediately;
  • what will happen to existing placements;
  • who is responsible for the transfer;
  • how replacement services will be arranged;
  • and who bears any losses, costs, or fines.

An objection to a suspension or revocation does not automatically suspend the decision.

KEY WTTA TIMELINE

Now: preparation

Map your business model, entities, working relationships, agreements, records, and entire chain.

Apply for eHerkenning Level 3 and the Message Box for Businesses in good time.

Assess whether SNA certification is required or desirable.

Check whether your historical labor-supply activities are sufficiently documented.

November 1 through December 31, 2026

Registration for the transitional arrangement.

This registration requires, among other things, eHerkenning, the Message Box for Businesses, and revenue figures for 2026.

January 1, 2027

The Wtta enters into force.

May 1 through June 30, 2027

Applications for authorization, provisional authorization, or an exemption may be submitted.

Existing labor suppliers that wish to use the transitional arrangement must submit their application by June 30, 2027.

June 30, 2027

Reference date for the simplified transitional route based on valid SNA certification.

For the first application, valid SNA certification may replace the separate Wtta inspection report, subject to certain conditions.

The other authorization requirements continue to apply.

July 1, 2027

The Dutch Labor Market Authority starts assessing applications.

The public register becomes available to hirers.

January 1, 2028

The prohibition on supplying workers without the required Wtta status takes effect.

From this date, hirers may only work with labor suppliers that:

• hold valid authorization;

• hold an exemption;

• fall under the transitional arrangement;

• or fall under a statutory exception.

The Dutch Labor Inspectorate may take enforcement action against both labor suppliers and hirers.

WHY YOU SHOULD NOT WAIT

A Wtta process affects several parts of your organization:

  • corporate structure;
  • Dutch and foreign entities;
  • agreements;
  • payroll;
  • payroll tax and social security;
  • terms and conditions of employment;
  • personnel records;
  • time recording;
  • invoicing;
  • financial security;
  • SNA certification;
  • client acceptance;
  • supplier management;
  • housing;
  • and internal controls.

The Wtta therefore cannot be addressed by legal, payroll, finance, or compliance in isolation.

The different parts must work together.

Applying for eHerkenning, collecting information from clients, amending agreements, and building verifiable records also take time.

Late preparation may:

  • jeopardize your transitional status;
  • delay the authorization application;
  • result in additional remediation and inspection costs;
  • and block access to clients from January 1, 2028.

Waiting until May or June 2027 is therefore not a sensible strategy.

AAME WTTA QUICKSCAN

Would you like to know whether the Wtta applies to your organization and which steps are required?

As part of the AAme WTTA Quickscan, we assess, among other things:

  • your Dutch and international corporate structure;
  • your contractual chain;
  • the roles of recruiters, employers, payroll companies, brokers, and MSPs;
  • who qualifies as the labor supplier, on-supplier, and hirer;
  • whether the arrangement constitutes the supply of workers;
  • where direction and supervision lie in practice;
  • whether a statutory exception may apply;
  • whether an exemption is available;
  • whether provisional authorization is required;
  • whether a waiver of the security deposit may be available;
  • whether your SNA route and transitional status are adequately secured;
  • which standards-framework obligations are relevant;
  • which contracts must be amended;
  • which administrative processes are missing;
  • and which actions are required before November 1, 2026 and June 30, 2027.

You will receive a practical assessment covering:

  • the classification of your business model;
  • the classification of the parties in your chain;
  • the main legal and operational risks;
  • specific areas requiring attention;
  • and a prioritized action plan with deadlines.

Not a generic checklist, but an assessment of your actual organization, contracts, and chain.

HOW AAME CAN SUPPORT YOU

AAme Adviseurs works every day for Dutch and international recruitment firms, secondment firms, temporary employment agencies, brokers, MSPs, and payroll companies.

Our services combine:

  • employment law;
  • contract management;
  • Dutch and international payroll;
  • accountancy;
  • Dutch and international taxation;
  • social security;
  • support with SNA and standards-framework processes;
  • assessment of terms and conditions of employment;
  • support with authorization applications;
  • and guidance on international staffing and secondment structures.

We can support you with, among other things:

  • the legal classification of your business model;
  • mapping the entire chain;
  • identifying the correct applicant entity;
  • assessing foreign structures;
  • preparing for the transitional arrangement;
  • assessing the security deposit and a possible waiver;
  • preparing for SNA and Wtta inspections;
  • amending employment, hiring, and service agreements;
  • setting up procedures for terms and conditions of employment;
  • checking payroll, time recording, and invoicing;
  • drafting internal procedures;
  • and preparing and guiding the authorization application.

As a result, we do not only assess what is legally required.

We also assess whether your structure is:

  • practical to operate;
  • administratively verifiable;
  • correct from a tax perspective;
  • and commercially workable.

One assessment. One action plan. One team with a complete view of the connections.

FREQUENTLY ASKED QUESTIONS ABOUT THE WTTA

CONCLUSION

The greatest mistake is to assume, based on a name, agreement, or existing working method, that the Wtta does not apply.

The correct question is:

“Who actually supplies the employee, and who exercises direction and supervision?”

Is the answer not immediately clear?

Have your position assessed before your client, inspection body, or the Dutch Labor Inspectorate asks the question.

DISCLAIMER

This page contains general information and does not constitute individual legal, tax, employment-law, or accountancy advice.

Whether the Wtta applies to your organization depends on your actual business model, agreements, working relationships, business activities, and position in the chain.

Legislation, implementing rules, the standards framework, rates, and implementation practice may change. Have your specific situation assessed separately and on the basis of the most current rules.

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