The IND is actively checking whether recognised sponsors who are assigning employees to other companies have the required SNA registration

Recognised sponsors who are or will be assigning personnel to other companies for payment, must be listed in the register of the Labour Standards Foundation (Stichting Normering Arbeid or SNA). This is stipulated in article 1.14 of the Aliens Regulations (Voorschrift Vreemdelingen or VV), which was revised in October 2021. It now states that any company that is payrolling or assigning personnel to other companies, as defined by article 1, under c and d, of the Workers Allocation by Intermediaries Act (Wet allocatie arbeidskrachten door intermediairs or Waadi ), must have an SNA registration certificate.

Business activities for which this SNA registration is required, are listed in the Dutch Chamber of Commerce’s register with the following SBI codes:

• 78201 (uitzendbureaus)
• 78202 (uitleenbureaus)
• 78203 (banenpools)
• 7830 (payrolling)

The activities include job pooling, payrolling and employment agency activities. The provision of personnel can be commercial or non-commercial. The Waadi does provide a few exemptions. SNA registration is not required, for example, when employees are assigned to another company for the delivery of goods or services, or in case of a secondment within the same corporate group.

In their newsletters from May and June 2023 , the IND warned recognised sponsors about the SNA registration requirement. They are now actively checking whether the above-mentioned SBI codes are mentioned in recognised sponsors’ Chamber of Commerce abstracts. If one of these SBI codes is mentioned in a recognised sponsor’s Chamber of Commerce abstract, and this recognised sponsor is not registered in the SNA register, the IND can revoke the recognised sponsorship status. This can have serious implications, as an employer can no longer employ highly skilled migrants without the recognised sponsorship status.

Before the IND revoke the recognised sponsorship status, they generally send a letter to the recognised sponsor about their intention to revoke it, giving the recognised sponsor a chance to provide a reaction. The IND will also check whether the recognised sponsor is on the list of companies that applied for the SNA registration and are waiting to receive the SNA certificate.

If your company is a recognised sponsor, and you assign employees to other companies, you must have the SNA certificate and make sure that it remains valid. If you do not assign employees to others, but one of the above-mentioned SBI codes is mentioned in your Chamber of Commerce abstract, the SBI code may need to be revised. If you receive a letter from the IND about it, it is important to take action as soon as possible. The SNA registration or having the SBI codes revised in the Chamber of Commerce register can take some time.

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