Effective January 1, 2026, the method used within the SNA certification program to verify compliance with relevant (collective bargaining agreement) wages will change. This change is a direct result of the transition from equal pay to equivalent pay for temporary workers effective January 1, 2026.
Effective January 1, 2026, the method used within the SNA certification program to verify compliance with relevant (collective bargaining agreement) wages will change. This change stems directly from the transition from equal pay to equivalent pay for temporary workers effective January 1, 2026.
This has implications for the interpretation and assessment of SNA Standard Requirement 5.8 (Requirements Regarding Collective Bargaining Agreement Wages). In this article, you’ll learn how inspection agencies will assess Standard Requirement 5.8 starting in 2026 and what you need to keep in mind.
The change described here specifically applies to the random inspections to be conducted in 2026 and thus covers an audit period in 2026.
SNA Standard Requirement 5.8: The Core of the Obligation
Standard Requirement 5.8 stipulates that your company must ensure that a procedure has been established, implemented, and is maintained to apply relevant (collective bargaining agreement) wages.
Inspectors assess three interrelated components:
We explain these components below.
In the initial phase, the SNA audit focuses primarily on the information-gathering process between the company and the client. This process forms the basis for ensuring that temporary workers are compensated at least equally or—where applicable—equivalently. Effective 2026, the process will be formally enshrined in the SNA Standards Manual through an interpretation report.
The procedure must ensure that the client is required to provide at least the following information:
1. The job classification and pay grade according to the client’s compensation plan
2. The applicable period wage within the scale
3. The applicable reduction in working hours (to be compensated in cash, if applicable)
4. The normal working hours at the hiring company
5. All allowances for irregular work or (physically) demanding conditions
6. Initial pay increases: timing and amount equal to those at the hiring company
7. Expense reimbursements, to the extent that they can be paid net
8. Periodic pay increases: amount and timing as determined by the hiring company
9. Compensation for travel hours and travel time (unless already classified as hours worked)
10. One-time payments, regardless of purpose or reason
11. Work-from-home allowances, with the portion not exempt under the law paid gross
This information must be traceable to the hirer and recorded in the company’s records.
With this request for information, the SNA audit explicitly aligns with the regulatory framework of the Wtta. The NAU (Dutch Temporary Employment Market Authority) is currently investigating whether the year-end bonus, vacation days, and vacation allowance should be added to the above eleven elements. It is likely that the work-from-home allowance will be removed. An update to this article will follow as soon as clarity on this matter is available.
After reviewing the data request process, the inspector verifies whether the established procedure works in practice.
The introduction of equivalent pay changes the interpretation of standard requirement 5.8. In the sample audit, the audit specifically examines two wage components within this standard requirement:
1. Gross pay
2. The initial wage increase
The inspector verifies whether the temporary worker’s gross hourly wage and initial wage increase correspond to the information requested from the client company. If this is the case, this aspect of the standard requirement is deemed to have been sufficiently demonstrated. The actual payment is always assessed under standard requirement 5.3.b.
Deviation within Equivalent Pay
Does the company opt for a different gross wage or a different wage increase? This is permitted within the framework of equivalent pay, but in that case, the inspector will assess the compensation received by the temporary worker. The following applies:
A perfectly precise calculation is not required
However, it must be demonstrated that the compensation:
- actually exists;
- is applicable;
- works in practice;
- reasonably reflects the difference from equal pay.
When claims that cannot be objectively valued are used, a plausibility test applies. The company must then demonstrate that this compensation is demonstrably guaranteed and is actually granted to the temporary worker.
Finally, it is assessed whether the temporary worker is informed in a timely and accurate manner. The procedure must stipulate that, prior to the start of each assignment (to the extent applicable), the employer must confirm the following information to the employee:
1. The expected start date
2. The name and contact information of the user company, including any contact person and work address (to the extent possible)
3. The job title and—if available—the job title as defined in the client’s compensation plan
4. If applicable, the expected end date of the assignment
These requirements are also consistent with the existing regulatory framework of the Wtta.
The change effective January 1, 2026, requires:
Companies that anticipate these changes in a timely manner significantly reduce the risk of non-compliance during the SNA audit.
Leniency?
It is currently being investigated whether leniency will be applied from early 2026 through May 1, 2026, at the latest, for any non-conformities that may be identified. In that case, a non-conformity with standard requirement 5.8 will not result in an additional follow-up inspection after three months; instead, the corrective action will be assessed during the next regular inspection after six months. At the time of writing this article, no final decision has yet been made on this matter.
Do you have questions or want to make sure your procedures comply with the new requirements? We’re here to help. Contact us and find out how we can support your organization with SNA inspections and WTTA-related issues. Together, we’ll ensure you’re fully prepared for 2026.
In January 2026 we informed you about the possible application of leniency for deviations from standard point 5.8 within the SNA standard. Meanwhile a final decision has been made about this: No coulance will be applied.
As of January 1, 2026, several changes within the SNA scheme came into effect simultaneously. We can well imagine that it is not always easy to keep an overview, due to the amount of changes and the many reports about them. For that reason, we have listed the most important changes in the SNA schedule for you below.
With the introduction of the Law on the Admission of Workers made Available (WTTA), the playing field for suppliers of labor changes fundamentally. From 2027, organizations that make labor available may only do so with a valid authorization. Without authorization, the right to perform these activities will expire.
From January 1, 2026, the SNA hallmark will be expanded with two new modules: Mediation and Intervention. This expansion has been developed in cooperation with NBBU, ABU and Bovib, among others, and gives clients more security when employing self-employed workers through intermediaries. This development should contribute to a professional and transparent market.
Following the successful revision of NEN 4400-1 in 2023, NEN 4400-2 has now also been updated. This standard is intended for foreign companies that provide personnel or hire work in the Netherlands. The revised version was published on Sept. 9, 2025, and will take effect on Jan. 1, 2026.
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