End of Transition Year: Full Enforcement on Self-Employed Contractor Arrangements from 2026

As of 1 January 2026, the Dutch Tax Administration will resume full enforcement of the rules governing the employment relationship between clients and self-employed contractors. The government has decided not to extend the so-called “soft landing,” despite a motion from the House of Representatives requesting this. As of that date, companies working with self-employed professionals will once again be subject to the tax authorities’ regular supervision and penalties.

The “soft landing” explained

Since 2025, the Tax Administration has been actively checking whether self-employed arrangements constitute disguised employment. Because enforcement had been paused for several years (the enforcement moratorium), a transitional year was introduced for 2025, the so-called “soft landing”. During this year, tax inspections generally began with a company visit, focused only on the most recent reporting periods, and no fines were imposed. This lenient approach was intended to give organizations time to adjust their working practices to comply with the Employment Relationships (Deregulation) Act (Wet DBA).

The “soft landing” followed the enforcement moratorium that had been in place since 2016, during which the Tax Administration did not act against disguised-employment except in cases of malicious intent or failure to follow prior instructions.

The motion and the government’s response

On 2 October 2025, the House of Representatives adopted a motion requesting a one-year extension of the soft landing until the end of 2026. However, in letters to Parliament dated October 2 and October 6, 2025, State Secretary for Finance Heijnen announced that the government would not implement this motion.

Government’s reasoning

According to Heijnen, an extension would undermine the strengthening of enforcement against disguised employment. Many organizations have already adjusted their procedures; postponement would slow that progress and make compliance less appealing. The government aims to maintain consistency and avoid renewed uncertainty.

Moreover, the end of the moratorium as of 1 January 2025, was set as a European milestone. Extending the transition could breach that agreement and potentially lead to a reduction in EU funding.

Supervision and enforcement from 2026 onward

Starting 1 January 2026, the soft landing will officially end and the Tax Administration will regain full enforcement powers. This means that if the authorities determine that a self-employed worker is effectively an employee, the client will have to pay retroactive payroll taxes and may also face a fine.

Inspections will no longer be required to start with a company visit and may also cover earlier reporting periods. For periods before 1 January 2025, enforcement will remain limited to cases involving malicious intent or failure to comply with instructions.

The State Secretary emphasized that the Tax Administration will continue to act with a human touch, focusing mainly on systematic abuse and vulnerable situations. In a progress report expected later this year, the government will outline how future supervision will be structured. We will continue to monitor developments and share updates as new information becomes available.