WTTA compliance & transition advisory 

Provisional EU agreement changes the rules on the posting of workers

The Dutch labour market is undergoing a structural overhaul, under the WTTA (Wet toelating terbeschikkingstelling van arbeidskrachten). Any company supplying labour in the Netherlands must hold official licence from the Dutch Labour Supply Authority (NAU).

Starting January 1, 2028, staffing agencies, payroll providers and foreign workforce suppliers are legally prohibited from operating in the Netherlands. Hirers face severe financial penalties when contracting unadmitted suppliers.

Whether you operate locally or supply foreign personnel to the Dutch market, our specialists handle your full WTTA admission process. From SNA/NEN 4400 certification to deposit structures and formal NAU registration.

The 4 mandatory WTTA admission requirements

To obtain official admission from the NAU, workforce suppliers must satisfy four statutory requirements:

  1. Approved Inspection Report (SNA Mark / NEN 4400)

Demonstrate full compliance with Dutch labour law, payroll accuracy and correct tax/social security remittances via an approved NEN 4400 inspection (NEN 4400-1 for Dutch entities, NEN 4400-2 for non-resident suppliers).

  1. Certificate of Conduct (VOG RP)

Obtain an official Certificate of Conduct for Legal Entities (Verklaring Omtrent het Gedrag voor Rechtspersonen) proving executive integrity. For foreign companies an exemption might be applicable.

  1. Financial Guarantee Bond (Security Deposit)

Provide a financial security deposit to the Dutch government:

  • Existing suppliers: € 100,000 security deposit.
  • New market entrants: € 50,000 upon application, followed by the remaining € 50,000 within 6 months.

(Note: Deposits are refundable after 4 years of continuous, fully compliant operations. Exemptions apply for incidental labor supply under the de minimis threshold. Less than 10% of total revenue and under € 5M or for qualifying bona fide suppliers with an established compliant track record).

  1. Dutch Chamber of Commerce (KvK) & Labour Norm Alignment

Proper registration in the Dutch Trade Register, adherence to Dutch equal pay standards (Loonverhoudingsnorm) and certified housing standards (where applicable).

Critical WTTA timeline & key dates

To maintain your licence to operate without business interruption, organizations must align with the official statutory timeline:

  • 1 November – 31 December 2026: Registration window for the transitional regime opens. Existing workforce suppliers must pre-register to claim temporary operating rights.
  • 1 January 2027: The WTTA legislation officially enters into force.
  • 1 May – 30 June 2027: Primary submission period for formal licence applications to the NAU.
  • From 1 July 2027: Licensed labour providers and organisations operating under the transitional regime are officially listed in the public NAU register (Nederlandse Autoriteit Uitleenmarkt).
  • 1 January 2028: Active enforcement by the Dutch Labour Inspectorate commences. Unlicensed labour supply becomes illegal and subject to severe statutory fines.

WTTA application routes

To prevent business disruption, companies must choose the correct application route based on their current compliance status. The NAU distinguishes three application routes:

  • Route 1: Application with Inspection Report (Pre-May 1, 2027)

Companies that complete a WTTA-aligned inspection early can include the inspection report with their application. This route allows proactive suppliers to prepare their admission before the new licensing requirements take full effect.

  • Route 2: Application with Valid SNA Mark (Pre-June 30, 2027)

Companies with a valid SNA certification based on NEN 4400 can use a streamlined transition route. The SNA certification must remain valid through 30 June 2027.

  • Route 3: Application without SNA Mark (Pre-June 30, 2027)

For suppliers without an SNA certification, early action is critical. Companies must register for the transitional arrangements before November 1, 2026. This allows them to continue operating during the transition while working towards the required NEN 4400 certification.

Companies that do not register before November 1, 2026 may no longer be able to supply workers until the required NEN 4400 certification has been obtained.

What this means for employers

The route that applies depends on the organisation’s current certification status and when it starts the WTTA admission process. Non-SNA-certified suppliers should therefore start preparing well in advance of the 1 November 2026 deadline.

NEN 4400 & WTTA Readiness Checklist

Tailored certification pathways

NEN 4400 certification serves as the primary building block for WTTA compliance. The required certification standard depends on where your company is legally established:

1. NEN 4400-1: For Dutch Entities

Designed for companies established in the Netherlands supplying labour or performing contracting activities (staffing agencies, payroll firms, secondment providers, and contractors).

  • Inspection Focus: Wage tax and social security contributions, Dutch minimum wage laws, identity verification procedures, personnel administration, and financial controls.
  • Target Group: Dutch staffing agencies, temporary employment agencies, payroll providers, and secondment firms.

2. NEN 4400-2: For Foreign & Cross-Border Suppliers

Specific for organizations established outside the Netherlands providing workers to Dutch clients.

  • Inspection Focus: Cross-border employment structures, worker identification procedures, social security coordination (A1 certificates), international tax compliance, and contract management.
  • Target Group: Foreign staffing agencies, EU-based labour providers, cross-border contractors, and international recruitment firms.

Our WTTA support services

We provide end-to-end advisory and execution for workforce suppliers (lenders) and hirers (inleners):

  • WTTA Readiness & Gap Analysis: Evaluating payroll administration, identity verification procedures, housing alignment, and contractual setups against the WTTA framework.
  • NEN 4400-1 & NEN 4400-2 Audit Preparation: Pre-audit reviews to secure SNA certification without administrative delays.
  • VOG RP & Financial Guarantee Setup: Direct support with security deposit structures (€ 50k / € 100k) and legal integrity filings.
  • NAU Application Management: Managing formal filings and direct communications with the Dutch authorities.
  • Hirer Advisory (Inlenersadvies): Structuring compliance checks for clients and hirers to eliminate joint liability and avoid statutory fines.

Need support?

The 2027 application deadlines are approaching fast. Whether you need NEN 4400-1, NEN 4400-2, or full WTTA guidance. We help you choose the right route, structure your financial deposit and complete your NAU admission on time.

Book a brief call with our compliance specialists to assess your current setup and map out your next steps.

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