wet VBAR / ZZP rules: where things stand in may 2026
been getting questions about this alot lately so dropping the current state here for everyone.
quick context first: belastingdienst started full enforcement of the contractor (ZZP) rules from jan 1 2026, retroactive to jan 1 2025. that part is done. no more 'soft-enforcement' window. if you've been operating in the gray zone with a single client and full-time hours, you're already on the books.
then it gets messier:
march 2026: minister aartsen scrapped the clarification piece of wet VBAR after the market basically went into chaos. alot of folks read the headline as 'wet VBAR is dead' but no, only the explanatory framework got pulled. enforcement is still on.
august 2026 (by the 31st): the rechtsvermoeden bit (presumption of employment at the €38/hour gross threshold) has to be in the staatsblad. that piece is moving on its own track. if you're freelancing under €38/hr you should know this is coming.
what this actually means if you're a ZZPer right now:
- single-client setups are the highest risk. one client + full-time hours + employer-style oversight = belastingdienst sees employment regardless of what the contract calls it.
- the model overeenkomst from the old DBA era is not a get-out-of-jail card anymore. courts and tax inspectors are weighing the actual working relationship, not just paperwork.
- bridge constructions through staffing/payrolling agencies are getting more attention. some intermediaries are tightening their own contracts because they don't want the audit either.
stuff people keep getting wrong:
- the €38/hour threshold is GROSS not net
- it's not just a tax thing. employment law follows the same logic. one 'rebrand' as employee and whatever leave, sick pay and dismissal protection comes with that lands on you too
- KvK registration alone doesnt make you a ZZPer in the eyes of the law. it just makes you a business
- if you've been running single-client for 6+ months, get your contracts looked at before december. waiting until tax time gets expensive
if anyone has a specific setup or a 'should i be worried' situation, drop it below. not a lawyer, just someone who reads the kabinet circulars enough to know when the goalposts are moving.
this is the may 2026 picture. if you're reading this later, check that the august rechtsvermoeden deadline actually landed in the staatsblad before relying on the €38/hour number.
(mod hat off, this is just me sharing what i keep explaining over and over to candidates and freelancers this week.)