An umbrella company in the Netherlands employs a worker on paper so that another business can use their services. The worker gets a Dutch payslip and employee protections, the client gets the work, and the umbrella holds the employment relationship in between.
Most writing on this is aimed at contractors. This page is for the business doing the hiring, because that is where the exposure is growing. Two dates matter and both are close: 31 December 2026, when a new presumption of employment based on hourly pay takes effect, and 1 January 2028, when it becomes an offence to hire from a personnel supplier that has not been admitted.
What an umbrella company is under Dutch law
“Umbrella company” is a market term, not a Dutch legal category. What matters is whether the arrangement meets the statutory description: a business making a worker available to another business, for payment, to work under that other business’s supervision and direction. Where it does, the Dutch personnel-supply rules apply, and the label on the contract does not change that.
Where it does not, they may not. Genuinely contracted-out work where the supplier keeps direction of the work, certain intra-group arrangements and several statutory exceptions can fall outside the admission requirement. Scope is a question of fact and should be checked against the actual arrangement rather than assumed either way.
Operationally the model is familiar: the umbrella employs the worker, the client contracts with the umbrella, timesheets go in, and the umbrella runs payroll, withholds wage tax and social contributions and issues the payslip.
The three regimes that can apply
| Regime | What it requires | What it means for you as the hirer |
|---|---|---|
| Waadi registration In force, until 1 Jan 2028 | An in-scope supplier must record the labour-supply activity in the KVK Business Register | You can check this free on the KVK site today. Both sides can be fined for non-compliance. The Waadi register and check move to the NAU register on 1 January 2028 |
| False self-employment Enforced since 1 Jan 2025 | The relationship must genuinely not be employment. The Tax Administration assesses substance, not the contract label | Where a direct engagement is reclassified as employment, the client pays the wage levies, with exposure under employment and pension law too |
| Wtta admission In force 1 Jan 2027, restriction from 1 Jan 2028 | Suppliers need admission or exemption from the Netherlands Authority for the Labour Supply Market. Conditions include correct wages, proper tax filing and records, work-authorisation checks, a certificate of conduct, compliant housing where the supplier provides housing, and a security deposit | From 1 January 2028 you may hire only from suppliers with admission, exemption or valid transitional status, and you can be fined and required to stop the arrangement if you do not |
On the deposit: €100,000 is the standard figure, but a start-up seeking provisional admission begins at €50,000 and tops up later, and the guidance provides for exemptions in some cases. Treat it as a serious barrier rather than a universal one.
The dates that matter
| When | What happens |
|---|---|
| 1 January 2025 | Full enforcement against false self-employment resumes. Corrections and payroll-tax assessments run from this date, or five years back where there is malicious intent or a failure to follow a pre-2025 instruction |
| Calendar 2025 | No default or culpability fines imposed, though corrections and assessments still applied |
| 1 January 2026 | The Tax Administration can impose culpability fines again. It has said it will still not impose default fines during 2026 |
| 10 March 2026 | The clarification part of the bill, intended to define when someone is genuinely self-employed, is removed by amendment. A replacement is to be drafted |
| 1 Nov to 31 Dec 2026 | Registration window for the Wtta transition scheme |
| 31 December 2026 | The hourly-rate presumption of employment takes effect. A worker paid at or below the applicable threshold may invoke it, and the business receiving the work must then rebut it |
| 1 January 2027 | The Wtta enters into force and a transition year begins. The hiring restriction does not apply yet |
| 1 May to 30 June 2027 | Suppliers apply for admission or exemption |
| 1 July 2027 | The NAU public register opens. Hirers can check whether a supplier is admitted, exempt or covered by the transition scheme |
| 1 January 2028 | The admission requirement and the hiring restriction begin. The Labour Inspectorate can fine suppliers and hirers. The KVK Waadi register and check transfer to the NAU register |
On the hourly-rate presumption, the number needs checking on the day. The Act works from a base figure of €36 an hour and provides for adjustment. Government materials have referred to €38 at a 1 January 2026 reference date. The operative amount is set by ministerial regulation.
It is also not a minimum freelance rate. It is an evidential presumption: below the threshold the burden shifts to you, above it nothing is proved either way.
Sources: the Netherlands Authority for the Labour Supply Market on obligations for hirers, the Netherlands Labour Inspectorate on the Wtta, the Tax Administration on enforcement, the KVK on hiring out and provision of workers, and the Eerste Kamer record for the hourly-rate presumption.
What an umbrella does not do for you
A genuine umbrella or payroll arrangement makes the provider the worker’s contractual employer. That is real and it matters. What it does not do is remove your exposure automatically.
Three things survive the intermediary:
- Hirer liability for unpaid taxes. Where the intermediary fails to pay payroll taxes or VAT, the hirer can be held liable for them. This is a long-standing feature of Dutch law and it is not affected by how well the employment relationship is documented
- The Wtta hiring restriction from 2028. The duty lands on you as well as on the supplier, and you cannot contract out of it
- The facts of how the work is actually done. Classification outcomes turn on the real three-party arrangement, not on the label. An intermediary does not by itself resolve a misclassification question, and equally, a genuine supply arrangement can make the provider the employer even though you direct the work day to day
The practical implication is that engaging an umbrella is the start of a due-diligence exercise rather than the end of one.
Provider due-diligence checklist
Here are eleven questions to ask before you sign:
- Is the labour-supply activity recorded in the KVK Business Register? Check it now. From 1 January 2028 this moves to the NAU register and you check there instead
- Does the registration name the entity that will actually employ your worker? Groups often contract through one company and employ through another
- Which route to admission will they use? Ordinary admission, provisional admission, the SNA certification route, an exemption, or a statutory exception. “We are looking into it” is an answer worth noting
- Will they register in the transition window between 1 November and 31 December 2026? Providers on the SNA route have a simplified path, but registering is still recommended
- Can they meet the security deposit? €100,000 as standard, or €50,000 initially for a start-up on provisional admission
- Who is the legal employer, in writing? Not who runs payroll. Who holds the employment contract
- How do they assess whether the arrangement is genuine, given the presumption taking effect on 31 December 2026? A provider with no view on this is leaving the question with you
- What is your exposure if they fail to pay payroll taxes or VAT? Ask directly, and ask what evidence of payment you will receive
- What happens to your worker if they lose or fail to obtain admission? Continuity, transfer, notice
- Which collective agreement applies, and how is it reflected in pay? Supplying personnel often brings a sector agreement with it
- What are the fees, on what base, and what sits outside them? Whether employer contributions and holiday allowance are inside or outside the quoted rate
Two duties fall on you rather than the provider from 1 January 2028, and they are worth building into procurement now: record which supplier is used before work starts, including where the worker is on-hired through a chain, and provide the applicable employment conditions to the supplier.
Umbrella, contractor or EOR
These are commercial models rather than Dutch statutory categories, and they get treated as interchangeable when they are not.
Engaging a contractor directly often has the lowest headline cost and, since January 2025, the most enforcement attention. If the Tax Administration concludes the relationship is employment, the client pays the wage levies. From 31 December 2026 a worker paid at or below the threshold can put the burden of disproving employment on you.
An umbrella places a Dutch employer between you and the worker. It suits defined assignments, workers who would rather be employed than self-employed, and situations where you want one contract rather than several.
An Employer of Record does something similar for an ongoing role rather than an assignment, with a full employment package attached. Where the work is indefinite and the person is effectively part of your team, an EOR is generally the closer fit.
Whichever you choose, the structure should describe what is actually happening. Documenting one thing and doing another is the position that fails under scrutiny.
Cost and timing
Fees are usually a percentage of invoice value or a fixed monthly amount per worker. The figure that matters is the loaded cost rather than the fee, because employer social contributions, holiday allowance and any applicable collective agreement sit on top of gross pay and are sometimes quoted separately. Statutory holiday allowance is generally at least 8% of gross salary, subject to exceptions.
Onboarding can be quick where the position is simple: identity checks, contracts and payroll registration. It takes longer where residence or work authorisation is involved, where a cross-border social security position needs establishing, or where someone currently engaged as a contractor is being restructured. Ask the provider for their own typical timeline rather than relying on a general figure.
Where employers get this wrong
Assuming the provider absorbs everything.
Hirer liability for unpaid payroll taxes and VAT, and the Wtta restriction from 2028, both sit with you regardless of what the service agreement says.
Relying on the contract wording.
Classification is assessed on how the work is actually performed. A well-drafted agreement describing something that does not match practice will not hold.
Reading the withdrawn clarification as a relaxation.
Removing that part of the bill in March 2026 did not remove the enforcement, and the remainder of the bill went on to pass. Culpability fines have been available since January 2026.
Waiting for 2028 to look at the supplier.
The transition window closes on 31 December 2026 and applications run from May 2027. A provider that misses both has a problem that becomes yours a year later.
Treating the hourly threshold as a rate card.
Paying above it proves nothing. It shifts the burden of proof, it does not settle the classification.
How NNRoad supports this
NNRoad provides Employer of Record and on-demand talent arrangements for companies engaging people in the Netherlands without a local entity. Where we act as the employer, we hold the employment contract, run payroll, and handle the withholding and reporting attached to it.
We are not a Dutch tax adviser and we do not opine on whether a particular arrangement is genuine self-employment. Where that question is live, or where hirer liability is in play, it belongs with Dutch counsel or a tax adviser.
Engaging people in the Netherlands?
Tell us how they are engaged today, how long the work runs, and whether you have a Dutch entity. We will tell you which model fits and what to check before December.
Quick FAQs
What is an umbrella company in the Netherlands?
A business that employs a worker so another business can use their services. It is a market term rather than a legal one. Where the worker is made available for payment to work under the client’s supervision and direction, the Dutch personnel-supply rules generally apply.
Is using an umbrella company legal in the Netherlands?
Yes. Today the supplier should have the labour-supply activity recorded in the KVK Business Register. From 1 January 2028 you may hire only from suppliers with admission, exemption or valid transitional status, and hiring outside that can be fined.
What changes on 31 December 2026?
A presumption of employment based on hourly pay takes effect. A worker paid at or below the applicable threshold can invoke it, and the business receiving the work then has to show there is no employment relationship. The Act works from €36 an hour with provision for adjustment, and the operative figure is set by ministerial regulation, so confirm the current amount before relying on it.
Does an umbrella protect me from false self-employment claims?
It changes the question rather than closing it. If the worker is genuinely employed by the umbrella, the self-employment issue does not arise in the same form. It does not remove hirer liability for unpaid payroll taxes or VAT, and it does not make an arrangement compliant if the facts point elsewhere.
How do I check a Dutch umbrella provider?
Start with the KVK Business Register today, and from 1 July 2027 the NAU public register, which shows admission, exemption or transitional status. Ask which admission route they intend to use and whether they will register in the window between 1 November and 31 December 2026.
Umbrella or Employer of Record?
An umbrella generally suits a defined assignment; an EOR generally suits an ongoing role with a full employment package. Both are commercial models rather than Dutch legal categories, so the test is which one describes what is actually happening.
What happens if my provider does not obtain admission?
From 1 January 2028 they may not lawfully supply workers where admission is required, you may not lawfully hire from them, and you would have to end the arrangement. Ask now what their plan is and what happens to your people if it does not work out.