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With the first WTTA registration period opening on November 1, 2026, the implementation of the new admission system is entering an important preparatory phase. Organizations that supply personnel, and those that engage external workers, should use the coming months to assess how the new framework may affect their workforce arrangements, supplier relationships and internal processes.

The Wet toelating terbeschikkingstelling van arbeidskrachten (WTTA) was enacted in 2025 and will enter into force on January 1, 2027. It introduces a mandatory admission system for businesses that supply workers to perform work in the Netherlands under another party’s supervision or direction, including temporary employment agencies, secondment providers, payroll companies and other labor suppliers. Certain limited statutory exclusions and an individual exemption route apply.

However, the potential scope extends beyond traditional temporary employment agencies. Depending on how an arrangement operates in practice, Employer of Record (EoR) arrangements and certain consultancy or service agreements may also require assessment.

The legislation aims to strengthen the protection of workers, particularly labor migrants, and promote fair working conditions.

Timeline

Although enforcement of the admission requirement will not begin until 2028, the first important deadline is approaching. The WTTA will be implemented in several stages:

• November 1 to December 31, 2026: Eligible existing labor suppliers can register for the transitional arrangement.
• January 1, 2027: The WTTA enters into force.
• By June 30, 2027: Suppliers relying on the transitional arrangement must submit their application for admission within the first six months after entry into force. The NAU will announce when the application portal opens.
• During 2027: The Nederlandse Autoriteit Uitleenmarkt (NAU) handles applications for admission and exemption and maintains the public register, whose legal basis has applied since July 1, 2026.
• From January 1, 2028: The prohibitions on supplying and hiring workers without the required admission take effect, and the Netherlands Labor Authority (Nederlandse Arbeidsinspectie) begins enforcing them.

The transitional arrangement is intended for existing labor suppliers that meet the relevant conditions. Eligible suppliers that register within the designated period and submit the required application on time may continue supplying personnel while their application is assessed.

For many organizations, this means that most preparation will need to take place in 2026 and 2027, rather than in 2028.

Who may be affected?

The WTTA is not only relevant to traditional temporary employment agencies. Secondment providers, payroll companies and other businesses supplying personnel may fall within the new framework.

Certain EoR, consultancy and service arrangements may also need to be assessed. This assessment depends on how the arrangement operates in practice. For example, an arrangement may require closer assessment where external personnel work as part of a client's team and the client organizes the work process, even if the client does not direct the content of the work.

The contractual description of an arrangement is therefore not decisive. Organizations should look at how personnel are supplied and how the work is actually performed.

Responsibilities for labor suppliers and hirers

The WTTA creates responsibilities on both sides of the labor supply relationship.

From January 1, 2028, labor suppliers must hold an admission, a provisional admission or an exemption, or qualify under the transitional arrangement, to continue supplying personnel. Already from January 1, 2027, suppliers must notify the hirer in writing or electronically before a placement starts that the worker is a supplied worker, and must record the placement in their own records.

Hiring companies also need to prepare for the new framework. From January 1, 2027, hirers must record, no later than the day a placement starts, which worker has been supplied by which supplier, and keep this information for seven years. The NAU's public register will allow hirers to check a supplier's status.

From January 1, 2028, hirers are prohibited from having work performed by workers supplied by a supplier that lacks the required admission, and hirers that breach this prohibition can be fined.

This means that preparation is not only a matter for labor suppliers. Organizations using external personnel should also consider how supplier verification fits into their existing procurement, onboarding and contract management processes.

How does the WTTA relate to the WAADI?

The WTTA builds on the existing framework under the Wet allocatie arbeidskrachten door intermediairs (WAADI), which remains relevant when determining whether an arrangement qualifies as the supply of labor.

Organizations should therefore consider how their workforce arrangements operate in practice rather than relying solely on the contractual description of a service.

This is particularly relevant where external personnel work as part of a client's team and the client organizes the work process. Case law interprets supervision and direction broadly, so an arrangement may qualify even if the client lacks the expertise to direct the content of the work. Depending on the specific circumstances, arrangements described as consultancy or service agreements may also need to be assessed.

What should organizations do now?

The first step is not necessarily to prepare an admission application. Organizations should first understand which parts of their workforce model and supply chain may fall within the scope of the WAADI and WTTA.

This includes:

• reviewing existing workforce arrangements and identifying where personnel are supplied or engaged;
• identifying relevant suppliers, intermediaries and external personnel arrangements;
• assessing which workforce models may fall within scope;
• considering who exercises supervision and direction in practice;
• determining which registration, admission or exemption requirements may apply; and
• reviewing contracts, supplier checks and internal processes where necessary.

For organizations supplying personnel, the opening of the transitional registration period on November 1, 2026 makes this assessment particularly timely. Organizations engaging external personnel should likewise use the period ahead to understand which suppliers may be affected and how their status will be verified once the public register becomes available.

Preparing for the WTTA

The WTTA will not affect every organization in the same way. What matters is how personnel are supplied, engaged and managed in practice.

With the first registration period opening shortly, now is a practical time for organizations to identify potentially relevant arrangements, review supplier relationships and establish which requirements may apply. This provides time to put the 2027 notification and record keeping duties in place and to address any necessary changes before the supply and hiring prohibitions take effect in 2028.

Would you like to understand how the WTTA may affect your organization? Briddge's Employment Law team can assess the potential legal and practical implications for your business.

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