For years, the Dutch temporary employment sector struggled with rogue agencies exploiting migrant workers, underpaying wages, and evading taxes. The new Admission of Workers Act (Wtta) marks the most sweeping reform of the temporary agency branch in decades. Passed by the Senate on 11 November 2025, this legislation fundamentally changes how businesses hire and lend personnel in the Netherlands. The clock is ticking, and the impact extends far beyond just the agencies themselves. Clients and hirers must also prepare for strict new compliance rules. This comprehensive guide explains exactly what the Wtta entails, who falls under its scope, and the crucial steps your organisation must take to avoid severe penalties.
What is the Wtta and why was this law introduced?
The foundation for the Wtta lies in the 2020 Roemer report, which highlighted severe abuses regarding the treatment and housing of labour migrants. Rogue temporary employment agencies were frequently found to be violating labour laws, leading to unfair competition against compliant businesses. To combat these structural issues, the Dutch government designed the Wtta to replace the existing, relatively passive Waadi registration with a strict, active admission system.
The primary goal of the Wtta is to ban rogue lenders from the market. By enforcing a rigorous admission process, the government aims to protect employees from exploitation and create a level playing field for all companies operating in the lending sector. The new system ensures that only thoroughly vetted and financially stable organisations can legally supply personnel to third parties.
Who does the Wtta apply to?
The scope of the Wtta is exceptionally broad. It naturally applies to traditional temporary employment agencies, secondment firms, and payroll companies. However, the legislation also encompasses small and regional players. Furthermore, foreign lenders who deploy personnel to work in the Netherlands must comply with the new rules.
Many organisations do not realise that the law legally classifies them as a “lender. If your business model involves placing your employees under the supervision and direction of a third party, the Wtta likely applies to you. For example, an IT consultancy firm that seconds programmers to work on-site at a client’s office under the client’s management falls under the Wtta. Similarly, a cleaning company that provides staff to work at various client locations may also be subject to these new admission requirements. It is crucial to assess your specific operational structures to determine if you meet the legal definition of a lender.
The timeline: when do you need to arrange what?
Understanding the implementation timeline is vital for ensuring your business remains compliant. The legislative process reached a major milestone when the Senate passed the law on 11 November 2025. Following this, a transitional period begins to allow the market to prepare.
Between 1 November and 31 December 2026, lenders must report to the newly established Dutch Authority for the Lending Market (NAU) for the initial registration phase. The Wtta officially enters into force on 1 January 2027. Following this, the formal application period for official admission runs from 1 May to 30 June 2027. Finally, strict enforcement by the Dutch Labour Inspectorate will commence on 1 January 2028. Organisations that fail to meet these deadlines risk significant operational disruptions and financial penalties.
What must lenders do to be admitted?
To obtain official admission, lenders must submit an application to the NAU and meet a comprehensive set of requirements. First, the organisation must provide a Certificate of Good Conduct (VOG) for the legal entity and its directors. Additionally, a financial deposit is mandatory. This deposit is provisionally set at €50,000, which must later be supplemented to a definitive amount of €100,000.
Applicants must also undergo a thorough inspection by a recognised inspection body. This audit verifies compliance with a strict normative framework. Key elements of this framework include guaranteeing equal pay for temporary workers, ensuring adequate housing standards for labour migrants, and maintaining proper registration in the Personal Records Database (BRP).
Once granted, the admission is valid for four years, subject to periodic compliance checks. Obtaining a NEN 4400 certification serves as a practical alternative or foundation for the required inspection report, as it already covers many of the Wtta’s financial and administrative criteria. Foreign lenders face largely the same requirements, with specific adjusted rules applied where cross-border practicalities necessitate them.
What does the Wtta mean for clients (hirers)?
The impact of the Wtta on clients and hirers is a highly underestimated aspect of the new legislation. Starting in 2028, hirers are legally prohibited from sourcing personnel from unadmitted lenders. As a client, you are legally obligated to verify the admission status of your suppliers by checking the public register maintained by the NAU before any hiring takes place.
The risks of non-compliance are severe. A hirer can receive a substantial fine from the Dutch Labour Inspectorate if they engage personnel from a non-admitted agency. Ignorance of the supplier’s status is not a valid legal defence. Therefore, it is highly advisable to begin a comprehensive audit of your current supplier base immediately to ensure all your lending partners are preparing for the Wtta.
Enforcement and sanctions
The Dutch Labour Inspectorate is responsible for enforcing the Wtta. The Inspectorate holds the authority to issue significant administrative fines to both lenders operating without admission and hirers engaging unadmitted agencies. Beyond direct financial penalties, non-compliance carries a massive reputational risk. Being publicly associated with illegal labour lending can severely damage a company’s standing with clients, investors, and the public.
The urgency of this enforcement can be compared to the ongoing crackdown on false self-employment. The Dutch authorities are demonstrating a clear commitment to strictly regulating the labour market, and the Wtta will be enforced with similar rigour.
Practical action plan: what should you do right now?
Waiting until 2027 to address the Wtta will almost certainly lead to compliance failures. Both lenders and hirers must take proactive steps today.
For lenders, the immediate priority is to pursue or maintain NEN 4400 certification, as this forms the backbone of the future admission requirements. Map out the new normative framework against your current operations, paying special attention to equal pay and housing standards. Furthermore, ensure you reserve the necessary capital for the mandatory €50,000 to €100,000 deposit.
For hirers, the first step is to inventory all current temporary employment agencies, secondment firms, and payroll providers you use. Ask these suppliers to demonstrate their SNA (NEN 4400) certification and inquire about their specific roadmap for Wtta compliance. Finally, update your procurement policies and standard contracts to include strict clauses regarding Wtta adherence.
FAQ — Frequently asked questions about the Wtta
Does the Wtta apply to small temp agencies with fewer than 10 employees?
Yes. The Wtta applies to all lenders operating in the Dutch market, regardless of their size or the number of employees they have. Small and regional agencies must meet the exact same admission requirements and provide the same financial deposits as large multinational firms.
What happens if my current lender does not apply for admission?
If your lender fails to obtain admission, they will be legally prohibited from supplying personnel as of 1 January 2028. If you continue to hire staff from them after this date, your organisation will be operating illegally and will face significant fines from the Dutch Labour Inspectorate.
Can I, as a hirer, be held liable for wage claims of temporary workers?
Under existing chain liability laws, hirers can already be held liable for unpaid wages and taxes. The Wtta strengthens this framework. Hiring from an unadmitted lender significantly increases your legal exposure and liability risks regarding the temporary workers stationed at your company.
Does payrolling also fall under the Wtta?
Absolutely. Payroll companies explicitly fall under the legal definition of making personnel available to third parties. They must go through the full NAU admission process to continue operating in the Netherlands.
What is the difference between the Wtta and the current Waadi registration?
The Waadi requires a simple, passive registration in the commercial register of the Chamber of Commerce. The Wtta introduces an active admission system. Under the Wtta, agencies must prove their compliance through independent audits, financial deposits, and background checks before they are permitted to operate.
Does the law also apply to foreign employment agencies sending staff to the Netherlands?
Yes. Any foreign agency posting workers to a client in the Netherlands must comply with the Wtta. They will face largely the same requirements as Dutch agencies, ensuring a level playing field across borders.
What is the role of the NEN 4400 certification?
The NEN 4400 certification (managed by the SNA) demonstrates that a lender meets specific administrative and tax obligations. Under the Wtta, holding a valid NEN 4400 certificate will heavily streamline the mandatory inspection process required for NAU admission.
What are the fines for violating the admission requirement?
While exact fine amounts are finalised closer to the enforcement date, the Dutch Labour Inspectorate issues severe penalties for illegal labour provision. Fines will be levied per violation and can quickly accumulate to tens of thousands of euros for both the unadmitted lender and the non-compliant hirer.
How long does the admission process take?
The NAU process involves gathering extensive documentation, undergoing an independent audit, and official review. Organisations should anticipate a lead time of several months from the initial application to final approval.
Are internal secondments within a corporate group exempt?
In certain specific scenarios, seconding personnel within the same corporate group may be exempt from the strict admission requirements, provided it is not done commercially. However, this is a complex legal area, and you should have your corporate structure reviewed by a legal professional to confirm any exemptions.
How do I check if a lender is registered?
The NAU will manage a public online register listing all fully admitted lenders. Hirers will be legally required to consult this specific register before signing any contracts or allowing temporary staff onto their premises.
Preparing your business for the Wtta
The Wtta changes the rules of the Dutch temporary employment sector fundamentally. Organisations that delay their preparations will inevitably encounter severe compliance problems, financial penalties, and operational standstills. Assessing your current supply chain and internal policies is a critical step that must happen now.
Law & More advises both lenders and hirers in preparing for the new admission system. Our legal experts can audit your current contracts, evaluate your compliance readiness, and guide you through the complex regulatory landscape. Contact Law & More today for a dedicated legal consultation regarding the specific consequences of the Wtta for your business.
