Does a broker need Wtta admission?

The Wet toelating terbeschikkingstelling van arbeidskrachten (Wtta) introduces an admission system for businesses that supply workers. Its scope centres on terbeschikkingstelling (making workers available under another party’s supervision and control), for remuneration. 

Temporary employment agencies, secondment businesses and payroll companies are familiar examples. But the business name is not decisive: other businesses can also perform this activity. The official explanation of the Wtta describes the activity that brings a business within the system. 

This is why “we work with freelancers” is not enough to settle the question. The arrangements and working relationship need to support that description. 

With mediation (bemiddeling), the broker introduces the parties. The client and freelancer enter into their own service agreement, and the freelancer performs the assignment independently. The broker may also provide administrative support. 

With intermediary contracting (tussenkomst), the business contracts separately with the client and the freelancer. That makes it a contracting party on both sides. It does not, on its own, establish that workers are being supplied. 

These are the arrangements distinguished in the SNA standard for freelance services. Whether a particular arrangement amounts to worker supply still requires its own assessment. 

The important question is therefore what happens during the assignment. A direct contract does not settle every legal issue, and separate contracts do not automatically create an admission obligation.

Only once the business has established that it needs admission. 

The SNA scheme distinguishes module 2 for worker supply, module 4 for mediation and module 5 for intermediary contracting. These cover different activities and are not interchangeable. 

For the temporary admission route based on an SNA certificate, the certificate must cover worker supply and be valid on 30 June 2027. Applications run from 1 May to 30 June 2027. This route removes the need to submit a separate inspection report for that application; the other admission conditions remain. 

A mediation-only certificate does not meet that condition. Equally, a business that only mediates does not need to obtain module 2 simply because this route exists. 

Start with a real assignment. Who contracts with whom? What service does the broker undertake to provide? Who decides how the work is carried out, and do the written agreements reflect daily practice? 

The DeepSeek draft’s distinction is useful here, but one point needs care: a broker remaining in the background does not prove that the arrangement is mediation. The client’s supervision and control must also be considered. 

A business offering both mediation and worker supply should examine those activities separately. An admission obligation arising from worker supply should not be confused with the position of its mediation service. 

The Wtta takes effect on 1 January 2027, with enforcement of the admission requirement starting on 1 January 2028. Existing worker-supply businesses can register for the transition arrangements between 1 November and 31 December 2026, followed by an application in May–June 2027, subject to the applicable conditions. The government timetable sets out these stages. 

For a broker providing mediation alone, the starting point remains simpler: establish and explain what the business actually does. If it does not perform terbeschikkingstelling, it does not need Wtta admission for its mediation activity.