WTTA in practice: what more than 100 additional Module WTTA inspections teach us

In collaboration with Flexnieuws , we published the article below for Flexnieuws.

WTTA in practice: what more than 100 additional Module WTTA inspections teach us

More than 100 additional WTTA inspections by Normec VRO show what temporary employment agencies are really up against. What emerges above all is that the biggest challenge rarely lies in one single standard requirement. The complexity of the WTTA standards framework lies in the confluence of existing and tightened regulations.

Since January 1, 2025, we have been performing additional WTTA module inspections on top of regular SNA inspections. In 2025 we conducted more than 100 additional inspections and in 2026 this number will increase further. This will create an increasingly sharp and representative picture of how the temporary employment industry is preparing for the WTTA(Posting of Workers Admission Act).

In a previous article we shared the initial findings. Based on the current numbers, clear structural patterns can now be named. Not incidental and not organization-specific, but chain-wide.

WTTA: not a sum of separate requirements, but one coherent system

What emerges above all from the inspections is that the biggest challenge rarely lies in one individual standards requirement. The complexity of the WTTA standards framework lies in the concurrence of existing and tightened regulations: labor law, remuneration regulations, administrative assurance, chain responsibility and demonstrability come together in one admission system.

Many temporary employment agencies already comply with parts of these regulations. What is often missing is the integral design and structural assurance. Processes exist, but are not clearly defined. Controls take place, but are not demonstrable. Information is present, but not complete and traceable.

"WTTA is not just asking for more rules, but for demonstrable control of what is already there," argues Fereijra-Phelipa. "That is another level of professionalism."

Employment contracts: content present, demonstrability lacking

A recurring concern relates to the demonstrable provision of the employment contract. In many cases, the content of the employment contract is present, but evidence that it was actually provided to the worker is lacking.

Within the WTTA standards framework, a qualified electronic signature is equivalent to demonstrable provision of the employment contract. However, this is not an obligation. Companies that do not use a qualified signature must demonstrate in some other way that the contract was actually provided to the employee.

In practice, proving just that is often complex. WTTA inspections are conducted as administrative checks, with no physical checks. This means that demonstrable provision can only be established on the basis of available administrative records.

When companies do not work with a qualified electronic signature, this requires additional and unambiguous proof within the administration. We see that this is often insufficiently conclusively set up, as a result of which it cannot always be conclusively established afterwards that the employment contract was provided to the worker in a timely manner.

Interesting in this regard is that the Tax Authorities recently indicated that when signing, for example, the Statement of Data for Payroll Taxes, an advanced electronic signature is sufficient, where previously a qualified signature was required. This raises the question of whether, also within the WTTA framework, an advanced electronic signature can be sufficient to meet the standard requirement of demonstrable provision.

We are discussing this with the Dutch Lending Market Authority (NAU), with the aim of arriving at a standard explanation that is legally tenable as well as practical.

We also regularly see

• unclear or missing commencement dates in subsequent contracts;
• inconsistencies between employment contract and employment confirmation;
• Incorrect or insufficiently specified working hours;
• lack of clarity regarding participation in a pension plan.

Within the WTTA module, one error in a sample already leads to a nonconformity. This requires precision and consistency.

Remuneration information: the structural bottleneck between hirer and borrower

A second structural pattern concerns the hirer's remuneration information. Inspections regularly reveal that it is:

• not demonstrably confirmed or provided and thus not traceable to the hirer;
• incomplete (not all remuneration elements);
• insufficiently specific (no clear function or job group) and thus not traceable to the worker;
• outdated;
• inconsistent (in a negative sense) with the applicable collective bargaining agreement.

We also see that the confirmation to the labor force does not always correspond to the information from the hirer, or that it cannot be shown that all remuneration elements were actually remunerated. This is precisely where it becomes apparent that WTTA enforces chain cooperation.

"This is the point where theory and practice meet," says Fereijra-Phelipa. "Without proper input from the hirer, the lender simply cannot comply."

All-in wage: requires further interpretation within WTTA

A specific practice finding that deserves attention in this context concerns the use of all-in wage. Within the SNA seal of approval, the application of all-in wage is not permitted. The WTTA has a different approach here. Because the WTTA, unlike SNA, is a public law legal framework, all-in wage is allowed under conditions. The condition is that the all-in wage is shown transparently and itemized on the payslip.

However, we can see that this issue is more complex than it may seem at first glance. Indeed, recent case law emphasizes that the right to enjoy (statutory) vacation days is an independent legal right. In those rulings, all-in pay is not seen as a substitute for that right, but as an advance payment on vacation days that have yet to actually be enjoyed in the future.

This means that the mere fact that vacation days are financially factored into wages does not automatically imply that the legal requirement of vacation enjoyment has been met. Precisely that aspect, the actual enjoyment of days off, is currently not explicitly and fully reflected in the current WTTA standard requirement.

The NAU recognizes this issue. We are in discussion with the NAU about this, precisely to arrive at a standard explanation that is not only legally correct, but also feasible and unambiguous for practice. This development shows that the WTTA is not a static framework, but a system that continues to develop partly on the basis of practical experience and case law.

Nonconformities: what do the figures say?

What provides additional insight into the extent of these challenges is the number of nonconformities identified within the supplementary WTTA module. Of the 37 inspections that have currently been formally completed and reported to SNA, a total of 655 nonconformities have been identified. This amounts to an average of about 18 nonconformities per inspection. These figures provide a representative picture of the nature and extent of the findings we encounter in the inspections, with the remaining inspections still in the process of being finalized. In addition, we see 31 non-conformities specifically related to hiring and on-lending workers.

This confirms that WTTA preparation rarely revolves around one isolated concern. In almost all cases, it involves multiple, related findings that touch on documentation, demonstrability and assurance within the organization. At the same time it becomes visible that WTTA is not exclusively a broadcast issue, but touches directly on cooperation and responsibilities within the chain.

Cooperation in the chain: necessary condition and bottleneck

A recurring area of tension that emerges from the inspections is the dependence of temporary employment agencies on their hirers. For crucial parts of the WTTA standards framework, hirers depend on timely and correct information from the hirer, such as:

• confirmation of remuneration information;
• correct recording of start and end times in time records;
• current data for application of the pay ratio rule.

This dependency is also evident in hiring and on-lending arrangements. In a substantial number of inspections we find that essential chain information is missing. For example, a statement from the formal employer of the borrowed employee is regularly missing, and we see that the transmission of employment conditions to the hirer is missing or incomplete. Without this information, the hirer cannot determine whether the correct working conditions are applied and the chain responsibility cannot be demonstrably fulfilled.

At the same time, we regularly receive feedback that hirers do not cooperate or cooperate only to a limited extent with this request for information. This puts temporary employment agencies in an awkward position: they are responsible for compliance, but do not fully own all the required information.

"WTTA makes painfully visible that compliance is not a solo issue," said Fereijra-Phelipa, "Without active involvement of the hirer, the chain comes to a standstill."

Awareness among hirers: necessary and effective

This is why we at Normec VRO pay explicit attention to the role of hirers within the WTTA. We do this by, among other things:

• targeted publications on the responsibilities of hiring parties.
• contributions to supplier and industry events, where hirers are directly addressed;
• carrying out WTTA-oriented chain audits at user organizations.

Read also: Temporary workers and the WTTA: what does it mean for you as a hirer?

We see that awareness among hirers increases rapidly as soon as it becomes clear that not picking up this role poses direct continuity risks. After all, if a hirer is not admitted, the hirer can no longer use these workers.

"The moment hirers feel this effect, the conversation changes," says Fereijra-Phelipa. "Then WTTA no longer becomes a compliance issue, but a business continuity issue."

WTTA is doable, if started on time

The additional WTTA module shows that the standards framework is feasible. At the same time, practice shows that underestimating coherence, demonstrability and duration are the biggest pitfalls.

Experience shows that organizations entering SNA for the first time, possibly in combination with the additional WTTA module, in most cases do not fully comply at once. Implementing and securing recovery and management measures takes time, an average of one to one and a half years.

"Those who only start now are gambling on everything going right at once," said Fereijra-Phelipa. "Our practical experience shows that this is rarely realistic."

WTTA preparation is thus not an administrative exercise, but a process in which governance, processes and chain cooperation are structurally reviewed. Organizations that start this now in a controlled manner retain control. Organizations that wait run the risk of being overtaken by legislation, chain partners and financiers. It is also visible from the financial sector that financiers are actively preparing for the consequences of the WTTA and adjusting their risk frameworks accordingly.

The WTTA is not unexpected. Practice shows that starting now makes all the difference.

Webinar on WTTA inspections by Normec VRO

Want to know more about additional WTTA inspections in practice? During Webinar Week, Normec VRO shares the key structural patterns emerging from these inspections in a webinar on March 12. In addition, Flexpedia talks openly about its practical experiences with the WTTA inspection by Normec VRO. What came out of it and what lessons are directly applicable for other organizations?

Click here for more information and to register.

Webinar Week: every day a different theme

During Webinar Week from March 9 to 12, each day will focus on a different theme:

• Monday, March 9: Contagious Employership || HRMorgen
• Tuesday, March 10: Recruitment and labor market communication || Werf&
• Wednesday, March 11: Professional hiring || ZiPconomy
• Thursday, March 12: Flexbureau 4.0 || FlexNieuws

The full program can be found here.