That is the stark warning from Marcel Reijmers (FlexKnowledge), Julisa Fereijra-Phelipa (Normec VRO), Hendarin Mouselli (De Voort Advocaten || Mediators), and artra. From their respective fields, they see on a daily basis how organizations are preparing for the Wtta, where the biggest bottlenecks arise, and which decisions now will determine companies’ positions in the market. Their message is unanimous and urgent: the Wtta is not an administrative formality that can be addressed later, but a strategic tipping point that demands attention now. Not only to ensure future compliance with the law, but above all to maintain control over compliance, business continuity, and future-proof operations.
The Wtta is intended to create a fairer labor market
The Wtta was introduced with the aim of making the market for the provision of labor more transparent, fairer, and more easily monitored. The law is intended to curb fraudulent arrangements and contribute to a more level playing field, in which organizations that invest in compliance with laws and regulations are no longer at a disadvantage compared to parties that do not. The core of the law is clear: organizations that provide workers or manage payroll will soon be permitted to do so only if they have been licensed to do so. At the same time, clients may work exclusively with organizations that have obtained this license. According to the three experts, this is an important step toward a more professional labor market.
“The ultimate goal of the Wtta is not just compliance, but creating a fairer, more transparent, and more professional playing field. Organizations that provide workers must be able to demonstrate that their processes, administration, and compliance are in order. At the same time, this also places demands on clients: they must consciously choose who they do business with and take responsibility for the quality and reliability of their supply chain,” said Julisa Fereijra-Phelipa. Yet in practice, they observe that many organizations still underestimate the impact of this change.”
“We’re not covered by this, are we?”
The biggest misconception experts encounter in practice is that organizations are too quick to place themselves outside the scope of the Wtta. Those who aren’t traditional staffing agencies often assume at first that the law won’t apply to them. According to Marcel Reijmers, this is precisely where things often go wrong: “For example, many consulting firms only discover during an initial meeting that part of their services legally falls under the category of temporary staffing. Then you’re suddenly faced with fundamental questions about your business operations.”
This is because the law does not look at the label an organization gives itself, but at the actual work being performed. As a result, staffing agencies, consulting firms, payroll organizations, and other service providers are subject to the licensing requirement.
According to Julisa Fereijra-Phelipa, inspections regularly reveal that organizations place themselves outside the scope of the Wtta, while the underlying service agreements indicate otherwise: “What we often see in practice is that organizations believe they are not subject to the Wtta, but the contractual agreements clearly reveal elements of temporary staffing. That is precisely why it is important for organizations to look not only at how they describe their services, but also at what they agree to in writing. In administrative audits, we follow the trail of the documented agreements. If these do not align with the actual intent or structure of the collaboration, this can lead to fundamental discussions about whether or not an organization is subject to the licensing requirement.” This makes raising awareness the necessary first step in the preparation process.
Preparation begins with insight, not with paperwork
When organizations realize that the Wtta may also have implications for them, the same reflex often kicks in: adjusting procedures, gathering documents, and drafting policies. According to Marcel Reijmers, this is understandable, but not the most effective approach. He explains: “Many organizations think their entire business needs an overhaul. Whereas it’s much smarter to gain insight first. If you’re already NEN 4400 certified, have a Wtta pre-audit conducted, and you’ll know exactly where the areas for improvement are. Then you can make targeted improvements, rather than tackling everything at once. If you aren’t certified at all yet, you do the same thing, but first for the existing SNA certification and then the pre-audit for the Wtta.”
According to Reijmers, a thorough baseline assessment prevents organizations from spending valuable time on measures that ultimately add little value.
The Wtta Requires a Different Approach to Organization
Many organizations still approach compliance as a collection of separate obligations: a contract here, a procedure there, a check at the right time. The Wtta mandates a different approach. The law brings existing and new obligations together into a single system, in which what matters is not just whether individual requirements are met, but above all whether the organization as a whole is demonstrably in control.
According to Julisa Fereijra-Phelipa, this requires more than just getting documents in order: “The Wtta isn’t about checking off individual standards. Organizations must be able to demonstrate that their processes, records, and responsibilities are logically aligned. It is precisely this coherence that will ultimately determine whether you have demonstrable control over your operations and your position in the supply chain.”
This shifts the focus from individual supporting documents to the structure and management of the organization as a whole.
For companies already accustomed to inspections, certification marks, and standards frameworks, this transition will be less of a challenge. For organizations dealing with this for the first time, this requires timely preparation: they must not only collect documents but first lay the foundation for a verifiable and future-proof way of working. Clients will also assume much greater responsibility.
The Wtta does not only change the position of organizations that provide personnel. Clients will also face new obligations. They will soon be permitted to work exclusively with authorized parties and will also have to demonstrate that their administrative systems are set up accordingly. This makes compliance a shared responsibility.
According to Hendarin Mouselli, this may well be one of the biggest changes brought about by the Wtta. Mouselli explains: “Compliance is no longer solely the responsibility of the staffing agency. Clients will also have to reorganize their hiring policies. This requires different choices than many organizations are currently making.” In addition, the temporary employment regime is also undergoing changes in other areas, as the Act on Greater Security for Flexible Workers was recently passed. This law is expected to take effect on January 1, 2028, but a number of changes affecting the temporary employment sector will take effect earlier. It is precisely these rules, in combination with the Wtta, that both client companies and staffing agencies must incorporate into their compliance procedures. These changes will significantly increase the liability risks for both client companies and staffing agencies."
According to Mouselli, this means that management, HR, procurement, and compliance will have to collaborate much more closely than is often the case today. Julisa Fereijra-Phelipa also sees collaboration within the supply chain as a key success factor: “The Wtta makes it clear that compliance does not end with one’s own organization. A staffing agency can only demonstrate compliance if clients also fulfill their role: by clearly documenting agreements, sharing information in a timely and complete manner, and taking their responsibility within the supply chain seriously. Without that collaboration, compliance becomes vulnerable, no matter how well-organized a staffing agency is internally.” Why start now?
Although the Wtta “doesn’t” take effect until 2027, preparations actually begin much earlier. Organizations must assess their processes, address shortcomings, and prepare in a timely manner for the transitional arrangement. According to the three experts , the required lead time in particular is still often underestimated. “Anyone starting today is actually already late,” says Julisa Fereijra-Phelipa. “In practice, we see that getting the basics in order, addressing shortcomings, and demonstrably ensuring processes are in place often takes much more time than organizations initially estimate. This isn’t a process you can just organize at the last minute before the deadline.” That is precisely why the three experts advise organizations not to wait until the law officially takes effect.
Key Milestones Leading Up to 2027
Those who don’t have a clear plan in place on time run the risk of falling behind. The three experts therefore advise taking the key milestones into account now.
| Period | What’s happening? |
| November 1 through December 31, 2026 | Register for the transition program |
| January 1, 2027 | The Wtta officially takes effect |
| May 1 through June 30, 2027 | Application period for final authorization |
| Starting in 2028 | Full enforcement of the licensing requirement |
According to Hendarin Mouselli, there is still a great deal of uncertainty surrounding this: “Many organizations believe that participating in the transitional arrangement is sufficient. That is not the case. The transitional arrangement is distinct from the application for final authorization. You must take both steps in a timely manner.”
That is precisely why Mouselli emphasizes that, in the coming months, organizations must not only determine whether they fall under the Wtta but also which steps they need to take and when. Proper planning prevents unnecessary time pressure and increases the likelihood of a smooth admission process.
Noncompliance Is More Than Just a Financial Risk
The Wtta entails more than just organizational changes. The financial consequences of non-compliance can also be significant. Although the final enforcement regulations are still being finalized, experts expect them to align with the existing penalty system under labor market regulations. The current standard fine amounts applicable for not having a Waadi registration are, per worker: €8,000.00 if you have made fewer than 10 workers available, €16,000.00 for 10 but fewer than 30 workers, and €32,000.00 for 30 or more workers. Do the math—or rather, calculate your loss. This means that the financial consequences for both the hirer and the staffing agency can be substantial. “If the expected system is implemented, fines may be imposed per worker made available. In that case, the financial consequences can escalate very quickly,” says Hendarin Mouselli.
According to Mouselli, however, it doesn’t stop there. Organizations that lose their license or consistently fail to meet legal requirements will also suffer reputational damage. After all, clients will increasingly opt for partners who can demonstrate that their affairs are in order. Marcel Reijmers also points out that responsibility will no longer lie solely with the staffing agency: “The beauty of the new system is that clients and staffing agencies share responsibility. Ultimately, you want to prevent unscrupulous parties from having a place in the market.”
According to Reijmers, the Wtta thus contributes to the law’s original goal: a fair labor market in which quality becomes the norm.
The Wtta Also Offers Opportunities
While many organizations focus primarily on the additional obligations imposed by the Wtta, the three experts see opportunities as well. Organizations that have their processes well in order will soon be able to clearly distinguish themselves from those that do not. This offers benefits to clients, employees, and regulators alike.
“Compliance will no longer be a standalone USP, but a prerequisite for differentiation. The Wtta highlights which organizations have demonstrable control over their processes, administration, and supply chain agreements. Those who have these aspects well in order demonstrate that they are reliable, transparent, and professionally organized. This gives clients greater certainty and makes quality visible in a market where trust is becoming increasingly important,” explains Julisa Fereijra-Phelipa. According to Hendarin Mouselli, that may well be the greatest benefit of the new law. She explains: “Companies that have been investing in quality for years are finally getting the chance to truly distinguish themselves from organizations that take the rules less seriously. Ultimately, this contributes to the more level playing field that the Wtta is intended to create.” The Wtta should therefore not only be viewed as a legal obligation, but as an opportunity to further professionalize processes, demonstrate quality, and structurally strengthen trust in the sector.
Four areas of expertise, one comprehensive view
The Wtta touches on legal issues, business processes, and day-to-day practice. That is precisely why FlexKnowledge, Normec VRO, De Voort Advocaten || Mediators, and artra are pooling their expertise in a joint seminar series. During the sessions, participants will gain insight into the underlying legislation, but above all, they will learn what the Wtta means for their own organization going forward.
Among other things, the following topics will be covered:
- When does the provision of labor apply?
- Which organizations fall under the Wtta?
- What does the authorization procedure entail?
- What additional requirements does the Wtta standards framework impose?
- What key inspection findings do we see in practice? How do you set up processes to ensure demonstrable compliance?
According to the four organizations, the combination of legal knowledge, inspection practice, and practical implementation makes this seminar series unique. As Hendarin Mouselli aptly summarized during the roundtable discussion: “This isn’t a topic you can just check off a checklist. It requires substance, insight, and preparation.”
The joint seminar series organized by FlexKnowledge, Normec VRO, De Voort Advocaten || Mediators, and artra helps organizations with legal interpretation, insights from inspection practice, and practical tools they can use right away.
About this article
This article is based on a roundtable discussion organized by artra, featuring Marcel Reijmers (FlexKnowledge), Julisa Fereijra-Phelipa (Normec VRO), and Hendarin Mouselli (De Voort Advocaten || Mediators). Drawing on their respective fields of expertise, the experts share their perspectives on the impact of the Wtta and preparations for the mandatory licensing requirement in 2027.
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