What should clients check before engaging freelancers in 2027?

Start with the person commissioning the services and the freelancer. What is being delivered? Who decides how the work is performed? What happens if the scope changes or the work needs correcting? 

For existing assignments, compare today’s responsibilities with the original description. A specialist hired to complete a project may now be handling continuing operational duties. 

Next step: update the factual description and assess the relationship against those facts. Changing the wording alone will not change how the work operates. 

The Belastingdienst recommends regular reassessment because working arrangements can develop over time. 

A former employee may provide independent services. But if the work, instructions and responsibilities remain substantially unchanged, replacing a payslip with an invoice raises an obvious question. 

Compare the previous employment with the proposed assignment. What freedom does the professional now have? What obligations have changed? Who bears the financial risk if the services are not delivered as agreed? 

Next step: record the substantive differences and examine whether they support freelance work. A new title or a break between engagements is not, by itself, an explanation. 

Employment classification requires the circumstances to be considered together under the Deliveroo framework, with relevant entrepreneurship also considered following Uber.

If a broker is involved, establish its role before assuming it has taken over the client’s responsibilities. 

Zooly uses broker for a mediator who brings clients and freelancers together. In mediation, the client and freelancer enter into their service agreement directly. Under tussenkomst (intermediary contracting), the intermediary contracts separately with each party. 

Next step: identify the contracting parties, their obligations and who directs the work. Establish which party has any payroll obligations under the applicable arrangement. 

The Belastingdienst’s guidance on intermediary contracting also addresses possible deemed employment for payroll-tax purposes. An intermediary’s involvement does not settle classification. 

An invoice from a besloten vennootschap (BV, a Dutch private limited company) identifies the contracting business. It does not answer every question about the individual performing management services. 

Check the contractual chain, the person’s duties and authority, and any shareholding or director position. Employment classification, payroll treatment and employee-insurance status may require distinct assessments. 

Next step: obtain a specific review where the arrangement relies on company ownership or director status. Avoid applying an ordinary freelancer checklist without considering those additional rules. 

Keep an agreement that describes the services accurately, relevant evidence of how the assignment operates and a short explanation of the classification decision. 

An approved model agreement provides assurance only within its conditions and where the parties actually work accordingly. 

For lower-paid assignments, also check the hourly-rate employment presumption, which takes effect on 31 December 2026. Use the applicable indexed threshold. This affects the burden of proof; a higher rate does not establish independence. 

Next step: list missing information and assign someone to obtain it before approving the arrangement. 

Use the preparation period to make decisions, rather than simply collect documents: 

• Identify assignments with changed duties or unclear responsibilities. 

• Resolve questions with the freelancer and relevant intermediary. 

• Record why freelance engagement is appropriate. 

• Where employment is indicated, arrange the appropriate engagement model and assess any necessary corrections. 

The Belastingdienst can already impose payroll corrections and additional assessments. These checks are practical preparation for 2027, not a reason to postpone an issue that needs addressing now.