CBS and DNB: the fall in self-employment is mainly a shift — what does it mean for your hiring chain ?

The Netherlands had roughly 131,000 fewer freelancers in mid-2026 than at the end of 2024, according to the DNB analysis. CBS reports a fall of 99,000 in assignments in the second quarter of 2026 compared with a year earlier; the total number of assignments stood at 2.353 million. 

More important than the absolute figure is where these people go. DNB finds that more than half of those who stop being self-employed have other work within a quarter. Around a third find a permanent job or a job with the prospect of a permanent contract. Almost half move to a different sector, relatively often to healthcare and welfare, government, education, trade, transport and hospitality. Almost 40 per cent are working in a different sector three months later. Only 7 per cent become unemployed, a percentage comparable with other years. DNB therefore concludes that stopping as freelancer is mainly a shift within the labour market, not a larger outflow into unemployment. 

For clients, this means a departing freelancer does not automatically remain available through another contract form. The same professional often reappears in a different sector or occupational category. Given the persistent tightness of the labour market, mobility in this group is high. 

On the basis of the figures, DNB cannot definitively establish what the main cause of the decline is. The data contain no information about the reasons why freelancers stop. The central bank does see indications. There is relatively a lot of movement between self-employment and employment in sectors where false self-employment is regularly a subject of debate, such as healthcare, construction, facility services and business services. 

The legal context has in any event become stricter. Since 1 January 2025, the Belastingdienst (Dutch Tax and Customs Administration) has been actively enforcing the Wet DBA (Assessment of Employment Relationships (Deregulation) Act). In 2025 a so-called soft landing applied: additional assessments were possible with retroactive effect to 1 January 2025, but default penalties were in principle not imposed. In 2026 that soft landing has been partially extended: default penalties remain suspended, but deliberate or grossly negligent penalties are possible. From 2027 the soft landing ends and default penalties also become possible. 

At the same time, there is a new reality on the work floor. Part of the demand for flexibility is now being met through secondment and temporary contracts, while clients struggle with the question of how they can continue to engage freelancers without falling into the trap of false self-employment. The absence of a standardised instrument that both facilitates the hiring of freelancers and tests actual practice against the assessment framework contributes to that shift.

In assessing employment relationships, the Belastingdienst applies the Beslis- en afwegingskader Beoordeling Arbeidsrelaties (Decision and assessment framework for the assessment of employment relationships), the updated version of which dates from April 2026. In addition, the Ministry of Social Affairs and Employment published a derived Toetsingskader Beoordeling arbeidsrelaties (Assessment framework for employment relationships) in July 2026, explicitly based on the Belastingdienst framework. Both frameworks centre on the principle that all facts and circumstances are weighed in their mutual coherence. No single contractual clause is decisive in itself. 

The Belastingdienst relies on the nine points of view from the Deliveroo judgment, as clarified in the Supreme Court's Uber judgment of 21 February 2025. In the Uber judgment, the Supreme Court emphasised that there is no ranking among the points of view and that the contractor's entrepreneurship outside the specific assignment is also relevant. The points of view include, among others: 

• Direction and working hours: to what extent does the freelancer determine their own working method, hours and location? 

• Organisational embedding: does the freelancer take part in regular shift schedules, team meetings or company outings? 

• Entrepreneurship outside the assignment: does the freelancer have multiple clients, actively acquire new assignments and genuinely bear commercial risk? 

If a freelancer gradually receives management instructions and becomes structurally embedded in your core team, the Belastingdienst may classify the assignment as a (fictitious) employment contract. That can lead to additional assessments of payroll taxes. Changing the label on the contract is therefore no guarantee. 

Responsibility for correct classification remains with the client. The Belastingdienst itself offers instruments to give shape to that responsibility. The Webmodule Beoordeling Arbeidsrelatie (Web module for assessing employment relationships) of the Ministry of Social Affairs and Employment helps to assess a specific assignment in advance. In addition, vooroverleg (preliminary consultation) with the Belastingdienst is possible where classification remains unclear. 

For existing assignments, periodic reassessment is necessary. An assignment that could be classified as self-employment at the outset may gradually take on a different character through changes in duration, direction or embedding. 

There is also a legislative development that may become relevant in due course. The Verduidelijking Beoordeling Arbeidsrelaties en Rechtsvermoeden (VBAR) bill (Clarification of the Assessment of Employment Relationships and Legal Presumption Bill) aimed to introduce a legal presumption of an employment contract at an hourly rate of up to €36 (reference date 1 January 2025). The clarification part of this proposal lapsed in March 2026; the legal presumption is being dealt with separately. The date of entry into force and exact scope remain uncertain for the time being. 

Traditional procurement models fall short when it comes to making actual practice visible. A Freelance Management System (FMS) such as Zooly is designed to offer support on that point: 

• Direct B2B contracting and transparent chains: Zooly supports direct contracting between client and freelancer and makes hiring chains more transparent. This helps to reduce WKA (Chain Liability (Labour Relations) Act) risks, without eliminating them. 

• Milestone-driven assignments: Payments can be linked through the platform to predefined deliverables and project milestones, rather than to fixed time registration. This can serve as a factual point of reference in substantiating that the collaboration is not organised on an hourly basis, but it remains part of the overall weighing by the Belastingdienst. 

• Signalling for periodic reassessment: Zooly can support periodic reassessment by flagging when the duration or character of an assignment changes. The final classification remains bespoke work and the responsibility of the client. 

The fall in self-employment is not evidence that flexibility is disappearing, but a signal that the form in which that flexibility is organised is shifting. Clients who wish to continue engaging freelancers would do well to put actual practice centre stage, to use the Belastingdienst's official instruments, and where possible to use systems that make execution transparent. However, the classification of an employment relationship always remains a legal judgment that must be assessed case by case, on the basis of all facts and circumstances in their mutual coherence.