Home › Knowledge base

Hirer liability and the Wtta: what changes from 2027?

If you hire workers through a staffing agency in the Netherlands, you can be held liable for taxes the agency fails to pay. The Wtta makes this regime stricter. Here is how it works.

Updated 25 October 2026

New to Dutch rules? The Wtta (Wet toelating terbeschikkingstelling van arbeidskrachten, the Placement of Personnel Admission Act) is a Dutch law that requires every business that supplies workers to other companies in the Netherlands to hold an admission from the Dutch Labour Market Admission Authority (NAU). Official sources are mostly in Dutch, so we link to them and summarise them in English.

What is hirer liability?

An agency that supplies workers must pay payroll taxes and VAT on those workers. If it does not, the Dutch Tax Administration (Belastingdienst) can hold the hiring company liable. Anyone who passes workers on can be liable too; it applies to the whole chain. This is called hirer liability (inlenersaansprakelijkheid).

According to the Tax Administration, a hiring company can limit the risk by, for example, asking the agency for a statement of payment history, keeping its own records in order and paying part of the invoice into the agency's G account.

The G account

A G account (g-rekening) is a blocked bank account of the agency that can only be used to pay payroll taxes and VAT to the Tax Administration. The hiring company pays the estimated share of payroll taxes and VAT into that account. If the agency then fails to pay, the Tax Administration cannot hold the hiring company liable for the amount paid into the G account under the conditions. The agency and the hiring company agree together whether to use a G account.

What changes with the Wtta?

The Wtta enters into force on 1 January 2027, and hirer liability changes at the same time. According to explanations of the new rules by, among others, the professional body SRA:

• Flat-rate liability of 35%: the Tax Administration may assume liability of up to 35% of the invoice amount without first investigating the actual debt. The hiring company may provide counter-evidence from its own records. This applies to tax periods from the entry into force.
• The register counts as proof of supply: if a company is listed as an admitted agency in the public register, the Tax Administration may assume that workers were supplied. The hiring company can still show that it was actually a contract for work.
• Indemnity: if the hiring company pays 35% of the invoice amount into the G account of an admitted agency and meets the administrative requirements, it is indemnified.

In addition, from 1 January 2028 a hiring company may only work with agencies that have admission or an exemption from the NAU or fall under the transitional arrangement. Otherwise the Netherlands Labour Authority can impose a fine.

What does this mean for staffing agencies?

For a small agency it becomes more important to show clients that everything is in order: registration for the transitional arrangement, admission later on, a G account and timely tax payments. Clients will ask about this more often, because their own risk depends on it.

What can you do now?

Frequently asked questions

What is hirer liability?

The Dutch Tax Administration can hold a hiring company liable for payroll taxes and VAT that the agency supplying the workers fails to pay.

What changes in 2027?

Under the Wtta, the Tax Administration may assume liability of up to 35% of the invoice amount. If you pay 35% into the G account of an admitted agency and your records are in order, you are indemnified.

Do I need a G account as a staffing agency?

It is not a legal requirement, but clients may ask for one. You decide together with the client whether to use a G account.

Read next

• Is my staffing agency admitted?
• Wtta timeline 2026–2028
• Applying for admission as a staffing agency (2027)