What does invoicing reveal about a freelancer’s working relationship?

No. Under Article 7:610 of the Dutch Civil Code, the relationship must be assessed as a whole. In Deliveroo, the Supreme Court upheld employment status despite the contractual description of the arrangement. Uber subsequently confirmed that the relevant circumstances have no fixed hierarchy and that entrepreneurship outside the particular assignment can matter. 

Invoicing can help document payment arrangements and business activity. However, neither an invoice nor a VAT identification number settles employment status. Equally, outsourcing administration does not itself establish employment. 

For an ordinary Dutch invoice subject to the full requirements, include: 

• The service provider’s and client’s full names and addresses. 

• The service provider’s VAT identification number and, if registered, KVK number. 

• The invoice date and a unique sequential invoice number. 

• The nature and extent of the service, with its delivery date or relevant advance-payment date. 

• The amount excluding VAT, applicable rate and VAT amount, with the required breakdown. 

One or more numbering series may be used. A year prefix such as “2026-001” is optional. Separate broker or self-billing series can be practical: agree their allocation and reconciliation with the freelancer’s records. For self-billing, the Tax Administration permits recording the client’s number or assigning a sequential number in the freelancer’s administration. 

A logo or house style is optional. The business identity must be clear, but branding is not a statutory test of independence. Special rules apply to exemptions, the KOR, simplified invoices and international transactions. 

A broker can prepare and issue invoices in the freelancer’s name and on their behalf under an agreed arrangement. Responsibility for correctness remains with the freelancer. 

For a workflow in which the freelancer approves and sends each invoice, record that requirement expressly. It is a sensible control choice, rather than a general legal requirement to send invoices personally. 

The mandate should specify: 

• The contracts and services it covers. 

• Who checks service descriptions, prices, VAT and numbering. 

• Whether approval is required before issue, and who may transmit the invoice. 

• How errors, objections, corrections and access to records are handled. 

• Whether the broker may collect payments and how these are allocated. 

An administrative mandate does not automatically authorise the broker to change commercial terms. 

Yes. Self-billing means that the client prepares the invoice for the freelancer’s service. Agree this beforehand and provide a procedure for accepting each invoice. Dutch guidance requires the wording “factuur uitgereikt door afnemer”. The freelancer must be identified as the service provider, with the client as recipient. 

The freelancer remains responsible for accuracy and, ordinarily, payment of the invoiced VAT. Objections must be raised promptly. 

Self-billing is different from VAT reverse charging. Under an applicable reverse-charge rule, the client accounts for VAT and the invoice states “btw verlegd”. Self-billing alone does not transfer that liability.

Yes, but first identify the arrangement: 

• Payment overview: separate freelancer invoices are accompanied by one reconciliation statement. 

• Joint invoice: the 2025 decree permits one document for several businesses if it contains everything required on their separate invoices. Each business retains its applicable VAT responsibilities. 

• Broker’s own invoice: where the broker contracts to provide the service itself, its invoice reflects that contractual chain. Assess the freelancer–broker relationship separately. 

Consolidation is not automatically evidence of employment. Avoid obscuring who supplied each service or treating a payment overview as an additional VAT invoice. 

For Zooly, a suitable workflow could link the mandate, relevant invoice, acceptance or objection, correction and payment allocation. Confirm the available functionality before promising automated controls. Preserve invoices for the applicable period: normally seven years, with ten-year rules for property invoices and certain one-stop-shop transactions. 

Position on 3 November 2026: the Zelfstandigenwet remains a proposal. Its explanatory memorandum expressly allows outsourced invoicing and client self-billing while the freelancer retains responsibility. January 2028 is the intended commencement, subject to legislation.