Prepare your company for the Wtta in time

What is the Wtta?

The Wtta introduces a mandatory admission system for companies that make workers available to third parties. This is relevant for companies like temporary employment agencies, secondment companies and payroll companies, but the new law has also impact on the hirers of personnel (the clients). Within this system, labour suppliers may only operate on the Dutch market if they have been admitted in advance by the Netherlands Authority for the Labour Supply Market (in Dutch: Nederlandse Autoriteit Uitleenmarkt, NAU).

The purpose of the law is to improve the reliability and transparency of the labour leasing market. As a result, supplied workers will be better protected and able to work and live under better conditions. The Wtta also aims to reduce unfair competition between labour suppliers.

By means of prior admission and structural supervision of the labour leasing market, only companies that have their obligations in order will be permitted to supply labour. The NAU assesses admission applications and maintains a public register of admitted suppliers.

Under the Wtta, hirers may only hire workers from suppliers with a valid admission. If workers are hired from a party without valid admission, the Labour Inspectorate may impose a fine. Both the supplier and the hirer of personnel can be fined.

When does it apply?

In principle, the Wtta applies to all companies that make workers available within the meaning of the Waadi (Dutch Workers Allocation by Intermediaries Act). This occurs when employees perform work under the supervision and control of a third party. This criterion is decisive for determining whether a company falls under the admission system. This includes temporary employment agencies, secondment companies, payroll companies, hirers and subcontractors, and companies that supply workers as a secondary activity. The law also applies to foreign companies.

Certain companies may, under conditions, be exempted from the Wtta. This specifically concerns companies that only supply workers for a small part of their activities. In such cases, an exemption can be requested. A company may qualify for exemption if less than 10% of its turnover is derived from labour supply and this turnover does not exceed five million euros. An accountant’s statement is also required for this exemption.

Additionally, a company that solely performs “(sub)contracting” work does not fall under the Wtta, because in such situations the client does not exercise supervision and control. In practice, the distinction between temporary staffing and contracting can be unclear and depends on the actual execution of work. It is advisable to assess this carefully.

Timeline towards Wtta and transitional arrangements

The implementation of the Wtta will take place in phases and consists of the following steps:

• Present: Start of preparation for the admission requirement. Companies assess whether they fall under the Wtta regulations and begin preparations, such as organising administration and preparing for an SNA inspection or Wtta-module inspection.
   
• 1 November 2026 – 31 December 2026: Period during which companies can register for the transitional arrangement. Timely registration is necessary in order to continue supplying labour after 1 January 2028 while the application is under review.
   
• 1 January 2027: The Wtta formally enters into force. From this date, inspection reports for admission can be prepared or the SNA certification can be obtained or renewed.
   
• 1 May 2027 – 30 June 2027: Admission can be requested from the NAU during this period. This can be done:
  
  o   With an inspection report.
  o   With an SNA certificate that is valid on 30 June 2027.
  o   Without an SNA certificate, in which case an inspection report must still be provided.
   
• From 1 July 2027: The NAU starts assessing admission applications. If necessary, additional information or an (additional) inspection report may be requested.
   
• Assessment outcome: The company will be admitted, not admitted, or — if registered in time for the transitional arrangement — temporarily not admitted but still allowed to supply labour while the application is being processed.
   
• 1 January 2028: Start of enforcement of the admission requirement. From this date, labour suppliers may only supply workers if they have NAU admission, and hirers may only cooperate with admitted suppliers. The Dutch Labour Inspectorate will supervise compliance.

What is required?

Companies wishing to apply for admission must prepare themselves in time. The focus lies on properly organising administration, processes and internal controls.

Labour suppliers are expected to maintain proper payroll administration, including accurate payslips, time registrations and employment contracts. They must also comply with obligations relating to social security and pensions. Companies that supply workers from abroad must arrange appropriate housing.

The admission procedure includes inspections by accredited inspection bodies. A valid Certificate of Good Conduct (VOG) for the legal entity and possibly for managing directors is also required.

A security deposit must also be considered. The standard security deposit is € 100,000. For start-up companies, a reduced security deposit of € 50,000 applies initially. Six months after their provisional admission, start-ups must apply for a standard admission, at which point they must supplement the security deposit to € 100,000 and transfer it to the NAU.

Existing companies may be eligible for a transitional arrangement in which no security deposit is required. This applies to companies that:

• Have been registered with the Chamber of Commerce (KvK) for four consecutive years with labour supply as a business activity;
• Have actually supplied workers during those four years;
• Can provide a recent payment behaviour statement.

NEN 4400-1 or 2 vs. Wtta

The existing NEN 4400 standard, which forms the basis for the SNA-certification, plays an important role within the admission system. The Wtta aligns with this but adds additional requirements.

Where the NEN 4400 standard primarily focuses on the presence and structure of processes and administration, the Wtta explicitly examines their actual implementation. This means that not only the existence of procedures is assessed, but also whether they are applied correctly in practice (e.g., regarding payment of the correct (collective labour agreement) wage).

The Wtta standard was temporarily amended at the beginning of 2026, postponing certain remuneration-related components to allow for a workable and verifiable implementation. These components will be reinstated before the introduction of the law, but no later than 1 July 2026.

Want to know more?

The introduction of the Wtta will have a lot of impact and will take place in phases: a transitional arrangement in 2026, an application and assessment phase in 2027, and enforcement from 1 January 2028. It is advisable to start preparations now and not wait too long. We would, of course, be happy to assist you with this.