Netherlands Updates Salary Payment Documentation Requirements for Recognised Sponsors Starting 2026

The Dutch government is strengthening compliance requirements for employers that sponsor highly skilled foreign workers. As of 1 January 2026, recognised sponsors, including Employer of Record (EOR) partners, must do more than retain payslips as evidence of salary payments. They must also keep proof that salaries were actually paid into the employee’s bank account.

For employers using an EOR to hire talent in the Netherlands, this change affects payroll, HR recordkeeping, immigration compliance, and risk management. Getting documentation right is essential for supporting work permit approvals and maintaining sponsor status.

What Exactly Is Changing

Current Practice

Until now, recognised sponsors could rely largely on payslips to demonstrate compliance with salary requirements when hiring highly skilled migrants or EU Blue Card holders. Payslips show what salary an employee is owed but not that it was actually paid.

New Requirement as of 1 January 2026

Recognised sponsors must also keep evidence that salary payments were deposited into the employee’s personal bank account. Payslips alone are no longer sufficient.

Acceptable documentation includes:

• Statements from the employer’s business bank account showing actual salary transfers
• Batch payment overviews clearly linked to employee bank accounts
• Other verifiable records showing the salary was received by the employee in a bank account in their name

The IND introduced this requirement to ensure real compliance and transparency, preventing situations where salaries might be recorded on paper but not actually paid.

Why This Change Matters

Stronger Evidence Required by the IND

The IND’s expanded administrative duty means employers must be ready to produce proof of payment when requested. This provides legal clarity on what constitutes adequate documentation.

Misuse and Abuse Prevention

Payslips alone could be created without actual deposits. The stricter requirement ensures that the highly skilled migrant and EU Blue Card schemes are used legitimately and that sponsored workers receive what they are owed.

Administrative Burden for Employers

This updates the duty to keep and retain records for sponsors. It is not just a formality. Sponsors must now manage additional payroll records to meet compliance obligations.

What Employers Should Do Now

For companies planning to hire or retain international talent through an EOR in the Netherlands:

Adjust Payroll Documentation Systems

Ensure your payroll system can store and link bank payment evidence with individual employee records. Batch payment overviews must align with payslips.

Align HR and Finance Teams

Both HR and finance must understand the documentation requirements. Payroll processes should produce traceable bank statements or batch summaries for each salary cycle.

Keep Records for Inspection

All relevant documents should be retained for the period prescribed and be readily accessible when the IND conducts compliance checks.

Compliance Risks for Sponsors

Failing to meet these documentation obligations could have negative consequences, including:

• Delays or refusals in work permit processing
• Sanctions by the IND for incomplete recordkeeping
• Reputational damage or more frequent audits
• Loss of recognised sponsor status in case of repeated violations

For foreign employers using an EOR, ensuring the partner understands and manages these risks is essential.

Recognised Sponsor vs Employer of Record

A recognised sponsor is a company approved by the IND to hire foreign employees under schemes like Highly Skilled Migrants or EU Blue Card. The sponsor is responsible for compliance with IND rules, including payroll and recordkeeping.

When you hire through an EOR like Tarmack, the EOR itself is the recognised sponsor, not your company. This means the EOR manages all compliance obligations, including the new salary proof documentation requirements. This allows your business to hire internationally without registering as a sponsor while remaining fully compliant.

How This Affects Employers Using an EOR

An EOR in the Netherlands typically acts as the recognised sponsor for immigration purposes. This means the EOR is legally responsible for meeting IND recordkeeping requirements, including the new salary documentation standards.

Using a knowledgeable EOR partner like Tarmack ensures that:

• Salary payments are documented correctly
• Records are compliant and retrievable
• IND inspections are handled smoothly
• Sponsor obligations are fulfilled without burdening the client employer

The result is reduced administrative risk while enabling foreign employers to focus on core business activities.

Final Thoughts

The expanded salary payment documentation requirement is a significant update to the Netherlands’ immigration compliance framework for recognised sponsors. It reflects a broader effort to increase transparency and protect foreign workers while strengthening employer accountability.

For employers hiring internationally, particularly through EOR arrangements, ensuring payroll systems and recordkeeping practices meet these new requirements is essential. Proactive preparation now will help avoid compliance issues and support successful hiring and retention of top global talent.

How Tarmack Supports Employers With the New Salary Documentation Requirements

Ensuring compliance with IND rules for recognised sponsors can be challenging, particularly for foreign employers hiring in the Netherlands. Tarmack provides Netherlands Employer of Record services that help:

• Maintain accurate payroll records linking salaries to employee bank accounts
• Ensure all documentation meets IND requirements for Highly Skilled Migrants and EU Blue Card holders
• Streamline HR and finance processes to reduce administrative burden
• Manage IND inspections and respond to documentation requests efficiently
• Provide guidance on compliance obligations, avoiding fines or delays in work permit processing

With an experienced EOR partner like Tarmack, your organisation can hire and manage international talent confidently while staying fully compliant with Dutch immigration and payroll regulations.