The Netherlands Clarifies Duty to Keep Records

Key Point  

• To support compliance, the Immigration and Naturalisation Service (IND) has clarified the record‑keeping obligation, effective 1 January 2026

Administration Requirements for Recognised Sponsors   

Beginning 1 January 2026, recognised sponsors in the Netherlands will need to maintain documentation records demonstrating that highly skilled foreign nationals or European Blue Card holders have received their salaries. 

Currently, sponsors maintain pays slips. Pay slips alone do not prove that an employer paid wages to an employee. Under the more clearly defined requirements, sponsors must provide evidence that they deposited salary payments into a payment account in the employee’s name. Acceptable documentation includes: 

• Monthly statements from the company’s business bank account  
• Monthly overview of batch payments 

These documents must clearly demonstrate that the employee has received the salary in their own payment account in their own name.  

Envoy Global Insight 

Mandy Janzen-Westerburgen, Director of Immigration and Managing Director for the Netherlands at Envoy Global, added:  

This is not really news as such, since the Immigration and Naturalisation Service (IND) has already requested this during audits. However, the IND has now clarified that, starting 1 January 2026, this requirement will formally apply. This announcement provides greater definition to the open norm regarding the duty to keep records.

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