Upcoming changes for Highly Skilled Migrants  

From 1 January 2026, important changes will come into effect regarding the administration of Highly Skilled Migrants (HSMs) and EU Blue Card holders by recognized sponsors. These changes include expanded administrative obligations and revised application fees. It is essential for companies to understand these changes and ensure compliance.

Expanded administrative obligations

Companies that are recognised by the Immigration and Naturalisation Service (IND) as sponsors are subject to an administration obligation. This status allows employers to hire Highly Skilled Migrants (HSMs) and EU Blue Card holders, but it also comes with legal responsibilities.

Until now, recognised sponsors were only required to keep pay slips as proof of compliance with the salary requirements. However, pay slips alone do not demonstrate that the salary has actually been paid to the employee. A condition that is essential for maintaining a valid residence permit under these schemes.

From 1 January 2026, this obligation will be expanded. Recognised sponsors must also maintain additional documentation proving that the salary has actually been transferred to the employee.

Required documents include:

1. Bank statements from the company’s business account showing salary payments made directly to the employee’s bank account

2. Batch payment summaries for monthly salary transfers.

These documents must clearly show that the salary was transferred to a bank account registered in the employee’s name.

With this change, the IND aims to strengthen compliance and prevent misuse within the highly skilled migration framework by ensuring that the actual payment of salary can be verified. Employers must maintain these records for a minimum period (currently at least five years after the employee’s employment ends or the sponsor status is withdrawn) and be able to provide them upon request during audits or inspections.

Why this matters for your organization

This change is more than an administrative update, it raises the bar for compliance. From 1 January 2026, recognized sponsors must prove actual salary payment, not just keep payslips. Missing or incomplete records may lead to IND audits, fines or even loss of recognized sponsor status. Effectively blocking your ability to hire highly skilled migrants.

The IND strictly assesses reliability, proper salary payments and sound administration. Companies failing to meet these standards risk delays, reputational damage or withdrawal of their sponsor licence.

In short: ensure your payroll and HR processes are aligned, payments are traceable, and documentation is complete. Being proactive protects your compliance position and your access to international talent.

Application fees as of 1 January 2026

The costs of applications (application fees) of the IND will change as of 1 January. The expected fees are:

• Application for recognition as a sponsor regular fee: €5,080

• Application for recognition as a sponsor reduced fee: €2,539

• Application for a Highly Skilled Migrant residence permit, European Blue Card: €423

Need help preparing?

Our specialists at Crowe Peak can help you understand the impact of these changes and ensure your organisation remains fully compliant. We provide administration audits or 0-measure assessments, offer expert advice on process and system implementation and guide you through IND processes.

Contact us for a no-obligation consultation. We are happy to support you and discuss the necessary steps to prepare your organisation for 2026, helping you stay compliant with immigration processes in the Netherlands.