From 1 January 2026, new legislation will take effect which mandates that Dutch companies that employ highly skilled migrants or EU Blue Card holders will have to prove in their administration that salary payments have not only been paid out but also deposited to the employees’ bank account. This development is in line with increasing enforcement of recognised sponsors in recent years.
Currently, the relevant legislation in respect of the salary threshold states that payslips or salary specifications are sufficient to prove salary payments by recognised sponsors. However, this does not guarantee that the salary payments are actually deposited into the bank accounts of the Highly Skilled Migrants or EU Blue Card holders. To bridge this gap and to prevent misuse, the IND has introduced an additional requirement as part of recognised sponsors’ administrative duty. While the IND acknowledges that this measure places an additional burden on the recognised sponsors, it considers the need for enforcement to outweigh this burden.
In respect of the administration duty, recognised sponsors are required to keep records of complying with this duty. Therefore, evidence showing the actual payments on top of the general key documentation related to the sponsorship and employment will be required from 1 January 2026. Documentation that can prove the actual salary payments, such as statements from the company’s bank account (afschrift zakelijke bankrekening), summary of batch payments (overzicht van een batchbetaling), or any other documents regarding bank transfers as proof of salary payments and receipts of salary payments by the foreign nationals can be used.
In practice the IND has already been requesting documentation proving deposits of employees’ salary when auditing compliance with recognised sponsor duties. This change therefore updates the legal requirements to bring them in line with enforcement practice. Vialto will continue to monitor the rollout of this measure and the developments on the stricter enforcement of recognised sponsors.
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
Hugo Vijge
Director
Nini Braken-Zheng
Manager
Marijan Vrhovac
Senior Associate
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