“Soft Landing” in the 2025 Employment Relations Enforcement Plan

The Tax Administration will fully enforce rules again from January 1, 2025, for organizations employing individuals who, according to the law, should actually be considered employees. No fines will be imposed for the 2025 calendar year. This applies to both failure-to-comply fines and penalty fines. Organizations may first receive a warning from the Tax Administration before so-called audits (inspections) are conducted. Additionally, all approved model agreements will be automatically extended until December 31, 2029. These measures implement the Dutch Parliament's request for a gradual transition in enforcing regulations on false self-employment. More information can be found in the 2025 Employment Relations Enforcement Plan.

The resumption of enforcement means that the Tax Administration can impose retrospective payroll tax assessments if there is evidence of false self-employment within an organization, but not for periods prior to January 1, 2025. During a company visit, a discussion will take place with the organization to gain insight into their use of self-employed contractors and potential false self-employment practices. The Tax Administration may advise the organization to avoid working with false self-employed individuals. The organization will then be warned and given the opportunity to improve its operations. During a follow-up visit, the Tax Administration may conduct an audit, which could result in payroll tax assessments.