New licensing system for employment agencies approved

14 November 2025 2 min read

By Johan Zwemmer and Thomas Boot

At a glance

  • On 11 November 2025, the Dutch Senate approved the Admission for Allocation of Workers Act (Act).
  • The Act introduces a licensing system for companies that post workers to hirer companies.
  • The law amends the Workers Allocation by Intermediaries Act and will enter into force on 1 January 2027.
  • The license requirement becomes mandatory from 1 January 2028.

The Act establishes a licensing system for employment agencies and other companies that post workers to hirer companies. When the law comes into force, companies must obtain a license from the Minister of Social Affairs and Employment before posting workers. Hirer companies can only hire workers from licensed companies, which can be verified on a public register. A license is valid for four years.

To obtain the license from the Minister of Social Affairs and Employment, a company that wants to post workers must:

  • Submit a Certificate of Conduct (Verklaring omtrent gedrag).
  • Pay a deposit of EUR100,000.
  • Demonstrate compliance with existing employment laws. 

The obligation to comply with employment laws includes confirming compliance with the Minimum Wage Act, that all taxes have been correctly paid, that the workers have the right to work in the Netherlands and that the workers receive the same wage as employees of the hirer company in similar positions. The requirement applies to all companies that post workers under the management and supervision of another company, including staffing agencies, payrolling companies (Employer of Record), and similar service providers.

Companies that supply workers only to a very limited extent can apply for an exemption if:

  • Wages have been paid for at least 12 months.
  • Fees for posted workers represent less than 10% of turnover,
  • Fees for posted workers do not exceed EUR5 million.

Certain industries may also be exempt, currently limited to private security providers, with potential for expansion.

The Netherlands Labour Authority will continue to monitor compliance with employment laws and will also enforce the licensing requirement. Companies must regularly confirm compliance through inspection reports from private institutions. Failure to meet requirements or violations of employment laws can lead to suspension or revocation of the license. Decisions can be contested via administrative law proceedings.