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2026-01-12 · Taxua

Soft Transition Period for Bogus ZZP Partly Extended to 2026

The Netherlands has long faced the problem of schijnzelfstandigheid — a situation where people formally work as ZZP but are effectively employees. From the government's perspective, this creates difficulties:

  • unfair competition between companies with employed staff and those saving on taxes
  • lower tax revenue for the state budget
  • lack of social protection for these "self-employed" workers

The Belastingdienst barely enforced these situations for a long time — there was effectively a handhavingsmoratorium, a temporary suspension / significant limitation of enforcement and fines. From 2016 until early 2025, the rules existed but were hardly applied:

  • The Belastingdienst barely checked employment relationships,
  • did not impose fines for schijnzelfstandigheid,
  • did not conduct active investigations,
  • effectively "turned a blind eye" to many situations where ZZP workers were employees.

In 2025, the moratorium was lifted, but to avoid chaos, a "zachte landing" (soft landing) was introduced — a gentle transition period without fines, focusing on guidance and allowing time to correct mistakes. Handhaving (enforcement) was strengthened:

  • company visits (bedrijfsbezoeken),
  • analysis of contracts and actual employment relationships,
  • retroactive tax assessments (naheffingen),
  • fines (boetes),
  • requirement to correct violations.

However, by 2025 it became clear that stricter enforcement was not improving the situation:

  • many companies had not yet restructured their contracts
  • ZZP workers feared losing their jobs
  • an abrupt change could create panic and staff shortages in an already tight labor market

On the other hand, a full extension of the soft regime is also not possible, because:

  • it undermines trust among those who have already brought their relationships into compliance,
  • it encourages violators who did nothing,
  • unions demand real action against bogus self-employment,
  • the EU expects effective enforcement, not merely formal,
  • the Belastingdienst has already invested in a new enforcement system.

Therefore, the government chose a middle path — a partial extension of the soft regime in 2026:

  • if a company made a mistake but not intentionally — no fine, only recommendations
  • if a company deliberately disguises employees as ZZP — fines + retroactive assessments
  • the Belastingdienst continues visits and consultations