Relevant for: buyers and contract managers of contingent labour and agency work (temporary employment agencies, secondment firms, payroll companies), particularly in logistics/DC, manufacturing, agrifood and facilities.
On 1 November the registration window for the Wtta transitional scheme opens; labour lenders have until 31 December 2026. A lender that does not register cannot use the transitional scheme and, if the admission requirement applies to it, must be admitted or hold an exemption by 1 January 2028 to keep lending workers. Meanwhile, reports of victims of labour exploitation rose by 13% in 2025, while prosecutions lag behind. The key question: which lenders will still be allowed to supply workers to you lawfully on 1 January 2028, and for which suppliers do you need an alternative before that date?
The week in one sentence
2027 is a transition year: from 1 January 2028, a lender without admission, an exemption or valid transitional status may no longer lend workers, and screening your agency supply chain remains your responsibility as the hirer.
The signals
Wtta registration window opens 1 November
The Wtta, the Dutch act introducing an admission system for labour lenders, enters into force on 1 January 2027. The first step for lenders is registering for the transitional scheme. According to the Nederlandse Autoriteit Uitleenmarkt (NAU), the new admission authority, no certificate of conduct (VOG) is required for that registration; it belongs to the later admission application. That application runs from 1 May to 30 June 2027. From 1 January 2028, only lenders that have been admitted or hold an exemption, or that fall under the transitional scheme while the NAU has not yet decided, may lend workers. From that date, hirers may only work with lenders that are admitted, hold an exemption or are validly covered by the transitional scheme; according to the ABU (the Dutch association of temporary employment agencies), a hirer that does not can be fined. The Netherlands Labour Authority enforces from that moment.
According to the NAU, admission requires, among other things, a certificate of conduct and a guarantee deposit: €100,000 for existing lenders, €50,000 for start-up lenders on their first application. According to the Netherlands Chamber of Commerce (KVK), the lender gets the deposit back after four years of good conduct, and a waiver of the deposit applies in some cases, for example four years of KVK registration plus a clean statement from the Dutch Tax Administration. Lenders holding an SNA quality mark on 30 June 2027 do not need to register for the transitional scheme, but must still apply for admission. According to the Dutch government, a bill adding equal or equivalent pay as an extra admission requirement is also in public consultation; if adopted, that requirement is expected to apply from 1 July 2027.
This signal carries the common thread: the deadline sits with your supplier, the supply risk with you.
More exploitation identified, little prosecution
According to the National Rapporteur on Trafficking in Human Beings, reports of victims of labour exploitation rose by 13% in 2025, from 356 to 401. Rapporteur Conny Rijken sees exploitation mainly in hospitality and agriculture. In hospitality, the number of reports doubled. According to the rapporteur, the Netherlands Labour Authority opened 57 criminal investigations; 10 cases were referred to the Public Prosecution Service. Rijken calls that "dramatically low".
Orbecta analysis: the increase counts cases that have come to light, so better detection may explain part of it. There is no sector figure for logistics, DC or manufacturing; do not apply the 13% to those sectors. What does matter: the figures cover labour exploitation in general, not only lenders, and criminal enforcement does not replace your own supply-chain checks. That matches the purpose of the Wtta. According to the KVK, the act targets abuses affecting labour migrants: underpayment, excessive hours and poor housing.
The common thread
Both signals show that hirers need their own view of their agency supply chain. The government is building an admission system; enforcement of the ban on lending and hiring without admission starts on 1 January 2028. Prosecution remains rare. Use 2027 to establish which lenders are admitted, exempt or validly covered by the transitional scheme before enforcement starts.
According to the KVK, the Waadi check remains available until 1 January 2028 and then disappears from the KVK website. According to the NAU, the public NAU register is expected to be added from 1 July 2027, showing whether a lender is admitted, holds an exemption or falls under the transitional scheme.
Orbecta analysis: if a lender has no admission, exemption or valid transitional status when enforcement starts, you can no longer lawfully use that supplier from that moment. You would then prepare the replacement in the second half of 2027.
Dutch procurement impact
Direct: framework agreements and hiring orders with temporary employment agencies, secondment firms and payroll companies that run into 2028. For each lender, you need to know whether it has registered and whether it will apply for admission in May-June 2027. That determines your 2028 hiring plan.
Indirect: onward-lending chains. A lender that passes work on to a smaller party brings that party onto your site. That link is not in your own supplier base.
If a lender cannot raise the deposit and has no waiver (Orbecta analysis): it may get stuck at the admission application in 2027, ask for a higher rate or exit the market. How many lenders this affects is not known. A fixed-rate agreement does not protect you against the loss of the capacity itself. Whether the lender may pass on a rate increase mid-contract depends on the price-review clause in your contract.
Less affected: organisations with no hiring through lenders, using only their own staff. Orbecta analysis: if a contractor or service provider effectively places staff with you, the Wtta may still apply; have legal assess this at your next tender.
Company exposure: not yet calculated. Connect spend and supplier data.
What is certain and what is still uncertain
What is certain
- Registration for the transitional scheme: 1 November to 31 December 2026.
- Wtta in force from 1 January 2027; 2027 is the transition year.
- Admission application: 1 May to 30 June 2027.
- From 1 January 2028: lending only with admission, an exemption or transitional status, and enforcement.
What is still uncertain
- How many lenders will register and obtain admission.
- Whether the deposit will raise rates or push lenders out of the market.
- The level of fines for hirers.
What to watch
- Share of lenders with proof of registration, from 1 November.
- Which lenders apply for admission in May-June 2027.
- Rate requests that refer to the deposit or the Wtta.
- Onward lenders on your sites without Waadi registration.
What you can do now
- This month, ask every lender in your supplier base in writing whether and when it will register, or which SNA route it is following. After 1 November, request proof of registration. Discuss any lender without registration and without an SNA route before 31 December; that is not yet a reason to phase it out, but it is a reason to explore an alternative.
- Before 30 November, ask your agencies which subcontractors or onward lenders they use on your sites, and run the Waadi check on the KVK website for each of them.
- Before 31 December, ask your largest lenders which application route they are following and, if the deposit applies to them, how they will finance it or which waiver they expect to use. At the next renewal, record that they must demonstrate their route to admission or exemption, a timely application and their current status, and report any loss of that status immediately.
How Orbecta helps
With Contract Intelligence, you upload a hiring contract and see which clauses on price review, term and liability it contains. That supports the renewal agreement in action 3. Warroom Prep prepares the conversation with a lender that submits a rate request.
Sources
Legal source: Staatsblad 2026, 159 — Besluit over de inwerkingtreding van de Wtta — 24 June 2026, published 29 June 2026
Primary source: Nederlandse Autoriteit Uitleenmarkt — Aanmelden voor de overgangsregeling — date not specified
Primary source: Nederlandse Autoriteit Uitleenmarkt — Hoe controleert u of een uitlener is toegelaten? — date not specified
Primary source: Nederlandse Autoriteit Uitleenmarkt — Lending workers in the Netherlands from abroad — date not specified
Primary source: Nederlandse Autoriteit Uitleenmarkt — Wat kost een aanvraag en toelating? — date not specified
Primary source: Nederlandse Autoriteit Uitleenmarkt — Moet u toelating aanvragen? — date not specified
Primary source: Nationaal Rapporteur — Jaarcijfers mensenhandel: meer slachtoffers arbeidsuitbuiting, aanpak van plegers blijft achter — 16 October 2026
Primary source: Rijksoverheid — Internetconsultatie wijziging eisen wanneer bedrijven personeel mogen uitlenen — 8 October 2026
Primary source: KVK — Wtta: strengere regels voor uitzendbureaus en andere uitleners — last updated 8 September 2026
Operational confirmation: ABU — Toelatingsstelsel (Wtta) — date not specified
Independent main source: NOS — Meer meldingen van arbeidsuitbuiting en te weinig daders gestraft, zegt rapporteur — 16 October 2026
Additional context: HP/De Tijd — Arbeidsuitbuiting neemt toe, vervolging blijft uit — 16 October 2026
Additional context: SRA — Gefaseerde inwerkingtreding Wet toelating ter beschikking stelling arbeidskrachten (Wtta) — July 2026
Orbecta analysis based on the sources above.