DBA Act
Since January 1, 2025, the enforcement moratorium on the DBA Act has been lifted. A transition period — the "soft landing" — is in place and continues into 2026. Many organisations are wondering what this means for their collaboration with independent contractors. Can I still work with freelancers? How does enforcement work in practice? And what impact does the new cabinet's governing programme and the proposal of the zzp-wet have on the assessment of employment relationships? In the articles below, we answer these and other key questions to guide you through the current rules and upcoming changes.
Labour Relations Enforcement Plan 2026
Enforcement Plan for Labour Relations, update 2026. This plan clarifies the Tax and Customs Administration's strategy against bogus self-employment and clarifies misunderstandings in the market. Read a summary of the most important points here, with direct quotes from the plan.
End of the enforcement moratorium: risk-based enforcement strategy
The enforcement moratorium on the DBA Act expired in 2025, which at the time raised concerns among many clients. The new government's 2026 plans for a Self-Employed Act (Zelfstandigenwet) are once again causing some unease in the market. However, the Self-Employed Act has not yet been adopted and must still pass through both chambers of Parliament (read more). Until then, existing legislation and case law — the holistic assessment based on the nine Deliveroo criteria — continue to govern in determining employment relationships.
What is false self-employment and how can organisations prevent fictitious and hidden employment relationships?
False self-employment is when someone is officially working as a self-employed individual (a sole trader), but should actually be classified as an employee. In this article, we’ll explore what false self-employment means, its implications for your organisation, and how to ensure a self-employed individual doesn’t inadvertently end up in a hidden employment relationship.
Assessing employment relationships: What businesses can learn from Temper's legal victory
On 10 July 2024, the Amsterdam District Court ruled in the proceedings brought by trade unions FNV and CNV against Temper that Temper is an online platform for work and not a temporary employment agency, as the unions had claimed. All claims submitted by the trade unions were rejected. This ruling may also be useful to you as a client in assessing various employment relationships within your organisation. This is a topic that has gained more weight with the 2025 lifting of the enforcement moratorium, even in 2026.
The VBAR bill: what it entailed and why the direction has changed
The VBAR bill (Clarification of Employment Relations Assessment and Presumption of Employment) long played a central role in the debate surrounding self-employment legislation in the Netherlands. In this article, we explain what the VBAR entailed, why it was abandoned, what is taking its place, and what this means for clients working with self-employed professionals.
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Enforcement of bogus self-employment rules sparks unrest: one in five freelancers considers quitting
The renewed enforcement of rules around bogus self-employment caused unrest among freelancers in the Netherlands in 2025. No less than 19 percent said they are considering quitting self-employment altogether. This was one of the findings from recent research conducted among 2,297 freelancers by Bovib, HeadFirst Group, NBBU, PZO, RIM, SoloPartners, Temper, and YoungOnes.
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How to determine the right employment relationship with workers in your organisation
Establishing the correct employment relationship has always been important, but with the enforcement moratorium on the DBA Act last year, and the proposals for the new Self-Employed Act (Zelfstandigenwet), it carries even more weight. The employment relationship defines the legal standing between a business and the individual performing the work, helping to avoid false self-employment. In this article, we explain what an employment relationship entails and how to determine the right form together with your contractor.
What does the DBA legislation mean for clients?
The DBA Act (Deregulation of Employment Relations Assessment) was back in the spotlight due to the lifting of the enforcement moratorium in 2025 and now again with the new government and the proposal of the Self-Employed Act (Zelfstandigenwet) in 20256. This raised many questions for clients working with freelancers. But what exactly changed? And how should businesses handle this enforcement? In this article, we discuss the key points of the DBA Act, what it meant for clients, and how you can ensure compliance with the legislation.
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New self-employed rules 2026 according to the government agreement
In this article, we outline the current situation: what rules apply today, the potential direction of new legislation, and what this means for you if you work with self-employed professionals.
What does the DBA Act entail, and what should I be aware of as a client?
The DBA Act (Deregulation of Employment Relationships Act) was receiving renewed attention following the lifting of the enforcement moratorium on January 1, 2025, and now with the new cabinet's governing programme, which proposes a Self-Employed Act (Zelfstandigenwet) to replace the existing framework. This has led to many questions from clients working with freelancers. But what exactly does the DBA Act involve, and what applies to companies now that enforcement is underway? In our articles, we explain the DBA Act, what it means for you as a client, and how you can ensure your working relationships are correctly structured.
What is false self-employment, and how can I prevent it as a company?
False self-employment occurs when someone is officially working as a freelancer (zzp'er) but is, in reality, in an employment relationship that should be classified as an employee role. This is also known as a "fictitious employment relationship" or "disguised employment." But what exactly is false self-employment, and what are the risks for your company?
In our article, we explain how you, as a client, can avoid accidentally placing a freelancer in a disguised employment relationship. We also discuss the consequences of a fictitious employment relationship for your organization. Additionally, we provide insight into the criteria you can use to determine if there is a case of false self-employment.
What are the freelance (zzp) rules in 2026?
Since January 1, 2025, the enforcement moratorium on the DBA Act has been lifted, which caused considerable concern in the market. Some companies became hesitant to work with freelancers as a result. The Dutch Tax Authority started with a "soft landing" approach and a risk-based enforcement strategy, which continues into 2026.
The Tax Authority focuses on high-risk cases, such as forced self-employment and clear instances of false self-employment. Meanwhile, the new cabinet's governing programme proposes a Self-Employed Act (Zelfstandigenwet) to replace the existing framework — though this legislation has not yet been adopted. Until then, the current rules remain in force, and the soft landing remains the guiding principle for enforcement.
How can I determine the right employment relationship with workers in my organisation?
Defining the right employment relationship has always been essential, and with active enforcement of the DBA Act now underway, it's more critical than ever. The new cabinet has presented its governing programme in 2026, which outlines a positive stance on working with independent contractors and proposes a new Self-Employed Act (Zelfstandigenwet). However, this legislation has not yet been adopted and must still pass both chambers of Parliament. Until then, the current assessment framework — including the holistic assessment based on the nine Deliveroo criteria — remains in force, and the Dutch Tax Administration continues to follow a risk-based enforcement strategy based on these principles.
In this article, we outline what an employment relationship is and how to work with your contractor to choose the appropriate structure.
What are the new zzp-rules for 2026?
With the new government in 2026, there are proposals to introduce a new Self-Employed Act. This act has not yet been adopted and must still pass both chambers of parliament. Until then, existing legislation and case law – including the holistic assessment based on the nine Deliveroo criteria – remain decisive in determining employment relationships while the Dutch Tax Administration follows a risk-based enforcement strategy.
What does the DBA legislation mean for me as a client?
The DBA Act was introduced to actively assess whether a relationship with a freelancer constitutes genuine self-employment or disguised employment. There are government plans to replace or reform the current framework with a new self-employment law to simplify and clarify the rules. Until then, the current assessment framework — including the holistic assessment based on the nine Deliveroo criteria — remains in force, and the Dutch Tax Administration continues to follow a risk-based enforcement strategy based on these principles.
What is false self-employment?
False self-employment occurs when an individual is officially classified as a freelancer or self-employed, but their working conditions actually align more with those of an employee.
In this article, we discuss this issue in greater detail, explore the potential impacts on your organisation, and provide guidance on how to prevent a freelancer from unintentionally falling into a hidden employment relationship.