The Dutch Highly Skilled Migrant landscape is changing. Are you ready?

Recent Dutch policy work signals tighter rules around hiring and placing kennismigranten (highly skilled migrants or knowledge migrants).

Dutch Highly Skilled Migrant landscape

The Dutch government is tightening its approach to highly skilled migrants, staffing companies, and Employers of Record (EORs). From stricter rules around secondment constructions (“uitleenconstructies”) to a completely new licensing system for staffing providers, the compliance landscape is changing rapidly.

For companies that hire international talent, this is not something to ignore. Whether you are a recognized sponsor yourself or work with an EOR, the expectations around compliance, transparency, and financial reliability are becoming significantly stricter.

At Rock Payroll, we closely monitor these developments and help companies stay compliant while continuing to attract international talent. Our compliance-first approach is built around long-term stability, clear processes, and up-to-date knowledge of Dutch immigration, employment, and tax regulations

Why is the Dutch government tightening the rules?

The Dutch government continues to recognize the importance of highly skilled migrants for the economy. At the same time, it has raised concerns about misuse of lending and secondment constructions involving recognized sponsors.

On November 8, 2024, the government informed Parliament about supervision findings involving recognized sponsors that facilitated residence permits for highly skilled migrants without actual employment activities taking place. According to the government, these situations increase the risk of abuse and reduce oversight on the actual working conditions of migrants.

As a result, the government is now working on measures to:

  • Reduce fraud risks
  • Strengthen sponsor responsibilities
  • Increase oversight on recognized sponsors
  • Tighten screening procedures
  • Clarify when lending highly skilled migrants is allowed

For employers and EOR providers, this means compliance requirements will likely become much stricter in the coming years.

Changes to secondment and lending constructions (“uitleenconstructies”)

One of the biggest proposed changes focuses on limiting the use of lending and secondment constructions for highly skilled migrants. The current policy direction suggests that recognized sponsors may no longer freely employ highly skilled migrants and then place them at another company as a standard business model.

What exceptions may still apply?

The government proposal includes several limited exceptions where temporary lending could still be permitted, including:

  • When a host company is waiting for approval of its own recognized sponsor application
  • During mergers and acquisitions where a new legal employer needs sponsor approval
  • For innovative startups or scale-ups that are not yet eligible to become recognized sponsors themselves

Under the proposal, these exceptions would likely come with:

  • A non-extendable permit of up to two years
  • Additional reporting duties for the sponsor
  • Increased verification obligations regarding recruitment practices
  • More detailed notifications to the IND

These changes are not yet in force, and it remains unclear when the final rules will be implemented. However, the direction from the government is becoming increasingly clear: long-term lending structures will face stricter limitations.

Recognized sponsor requirements are becoming stricter

Becoming a recognized sponsor already requires companies to demonstrate reliability, continuity, and financial stability. These requirements are expected to become even more important moving forward.

The Dutch government is working on additional measures related to:

  • National security concerns
  • Fraud prevention
  • Financial solvency
  • Reliability of directors and shareholders
  • Proper financial reporting

For companies that already hold recognized sponsor status, compliance does not stop after approval. Businesses must continue to maintain strong financial health and proper administration to avoid risks related to suspension or revocation.

The government also plans to shorten the inactivity period for recognized sponsors.

Existing inactivity rules

There is often confusion around the proposed “new” inactivity rule. In reality, the IND has already been able to revoke sponsor recognition since 2016 if:

  • No residence permits have been granted for three years
  • No migrants remain registered under the sponsor

The current proposal would reduce this period from three years to two years.

Salary requirements for highly skilled migrants may change

The salary criteria for highly skilled migrants are also expected to change. The proposed adjustments include:

  • Higher salary thresholds
  • Restrictions on how long reduced salary thresholds apply
  • Clearer rules regarding salary calculations and eligibility

Because the salary requirement is one of the most important parts of the Highly Skilled Migrant Scheme, employers should closely monitor future IND updates.

New licensing rules for staffing companies and EORs from 2027

In addition to immigration changes, the Dutch staffing market is preparing for the Wet toelating terbeschikkingstelling van arbeidskrachten (Wtta). This new law introduces a mandatory licensing system for companies that supply workers, including:

  • Staffing agencies
  • Payroll companies
  • Employers of Record (EORs)
  • Secondment agencies

The bill passed the Dutch House of Representatives on April 15, 2025, and currently aims to take effect on January 1, 2027.

What will change under the Wtta?

The proposed legislation includes:

  • A mandatory admission and licensing system
  • A €100,000 security deposit (“waarborgsom”)
  • Additional compliance and administrative obligations
  • A transition arrangement for companies with valid SNA certification

This means the market will likely become more regulated, and not every staffing provider may be able to meet the new requirements.

At Rock Payroll, we are well-positioned for these upcoming changes thanks to our long-standing SNA certification, proven track record, and strong compliance standards.

Changes to the 30% ruling

The Dutch 30% ruling has also faced several changes in recent years. Initially, the government introduced a phased structure where the tax benefit decreases during the five-year period:

  • 30%
  • 20%
  • 10%

However, during the 2025 Tax Plan discussions, the government decided to replace this phased model with a fixed 27% ruling starting January 1, 2027. At the same time, political discussions around the expat scheme continue. Additional changes or further restrictions cannot be ruled out in the future.

For employers hiring international professionals, it is becoming increasingly important to regularly review compensation structures and tax optimization strategies.

Fewer highly skilled migrants are coming to the Netherlands

The tightening political and regulatory climate is already impacting migration numbers. According to Statistics Netherlands (CBS), the number of non-EU highly skilled migrants dropped significantly in 2024:

  • 16,000 non-EU highly skilled migrants entered the Netherlands
  • 26% fewer compared to 2023
  • 39% fewer compared to 2022

This decline follows years of strong growth in highly skilled migration to the Netherlands.

Why these changes matter for employers

For companies hiring international talent, the message is clear: compliance and long-term planning are becoming more important than ever. Businesses should prepare for:

  • Stricter rules around lending and secondment constructions
  • Increased sponsor responsibilities
  • More financial and administrative oversight
  • Licensing requirements for staffing providers and EORs
  • Ongoing changes to tax benefits and salary requirements

Companies should also carefully evaluate the partners they work with. Not every EOR or staffing provider may be prepared for the upcoming regulatory environment.

How Rock Payroll and Dutchtaxadvice.nl can help

At Rock Payroll, we help companies navigate the changing Dutch immigration and employment landscape with a compliance-first approach. Together with Dutchtaxadvice.nl, we support businesses with:

  • Immigration compliance
  • IND sponsor obligations
  • Payroll and employment structures
  • Tax advice and 30% ruling support
  • EOR services
  • International onboarding
  • Monitoring legislative developments

Whether you are already a recognized sponsor or still exploring international hiring options, we help you create a structure that is compliant, future-proof, and practical for your business.

Future-proof your international hiring strategy

The Dutch highly skilled migrant landscape is changing quickly, and companies that prepare early will be in the strongest position moving forward. If you want to review your current structure, assess compliance risks, or explore alternative hiring solutions, our team is here to help.

Contact Rock Payroll for tailored advice on international hiring, EOR services, immigration compliance, and tax support in the Netherlands.