Full enforcement of the Dutch DBA Act in 2026: what false self-employment means for clients
Since 1 January 2026 the Dutch tax authority enforces fully on false self-employment again. For companies hiring freelancers that can mean back payments and penalty fines.
From 1 January 2026, the Dutch tax authority enforces fully on false self-employment again. That is the situation where someone works as a freelancer on paper, but is in practice effectively an employee.
How enforcement works
Enforcement has been softened in part: in 2026 no default fines are imposed for objective mistakes made without intent. But the tax authority can once again impose penalty fines in cases of intent or gross negligence. Those can run from 25 to 100 percent of the additional assessment.
Consequences
For the freelancer, entitlement to entrepreneur tax benefits such as the self-employed deduction can lapse, resulting in an additional assessment. The client feels it too: on reclassification, they still have to pay payroll tax and pension contributions.
What else is in play
On 6 March 2026 the minister dropped the clarification section of the VBAR bill following unrest. The announced Self-Employment Act is expected in 2027 at the earliest.
Hiring with care
For clients, a careful assessment of the working relationship now matters more than ever. FORZ helps hire specialists compliantly and carefully, so client and professional can both rest easy.