Insights
Update of UWV Implementation rules as of July 2025: Chapter on “Transfer of undertaking” added
The revised UWV implementation rules for dismissal on economic grounds replace the previous version from April 2023 and, for the first time since introducing the Wwz (in 2015), include a separate chapter 6 on the transfer of undertaking.
Why this addition?
- Since the Wwz (2025), this subject was missing from the implementation roles, while the UWV did include a chapter on it in its policy rules.
- With the new chapter in the implementation rules, a clear guideline is provided for dismissal applications in which a transfer of undertaking plays a role. With chapter 6, UWV aims to contribute to a uniform approach to decision making in such dismissal cases.
- The chapter offers more clarity on whether and how dismissals in the event of a transfer of undertaking are assessed. Important reference dates include the date of the dismissal application, the date of the transfer and the party submitting the application (transferor or transferee).
In practice:
A transfer of undertaking does not automatically rule out dismissal: dismissal for business economic reasons (so-called ETO reasons: economic, technological, and organisational) can still be valid, provided it is properly substantiated.
- The timing of the application and the involvement of both the transferee and the transferor are now clearly defined.
- The implementation rules specify who must provide which information: including details about the transfer itself, the consequences for staff, and possibilities for redeployment by the transferee.
