Dutch ZZP clients and the new "schijnzelfstandigheid" enforcement — how are you preparing?
Starting 1 January 2026, the Belastingdienst is actively enforcing the rules on schijnzelfstandigheid (false self-employment). This has been postponed for years but it's real now.
I have about 15 ZZP clients who work primarily for one opdrachtgever. Some of them are clearly fine (multiple clients, own tools, substitution clauses). A few are in the grey zone.
For those in the grey zone, I'm recommending they:
- Get a formal beoordeling from the Belastingdienst (costs nothing, takes 8 weeks)
- Diversify their client base before year-end
- Make sure their contracts explicitly cover substitution rights
But honestly I'm not confident the beoordeling process will keep up with demand. Every ZZP'er in the country is going to request one.
How are other Dutch practitioners handling this?
2 replies
Germany went through a similar wave of Scheinselbständigkeit enforcement 5+ years ago. The key lesson: restructuring the contract on paper while keeping the working relationship identical does NOT work. Auditors look at the actual facts on the ground, not the paperwork. If your client works 40hrs/week at one company's office using their laptop, no contract clause will save them.
Just to add — the new web module on the Belastingdienst site (Webmodule Beoordeling Arbeidsrelatie) is actually quite good now. I ran three of my grey-zone clients through it last week. Two came back as "indicatie dienstbetrekking" which means we need to restructure those arrangements before enforcement kicks in.
Create an accountant account to reply. Already verified? Sign in.