Netherlands: New Measures for Addressing Notification Non-Compliance

Effective November 1, 2026, the Dutch Immigration and Naturalisation Service (IND) will adopt three new measures for addressing certain instances of non-compliance: 

• • Contacting recognized sponsor via phone, email or letter;  
  • Conducting targeted information sessions for groups of recognized sponsors; or 
  • Inviting recognized sponsors to a formal enforcement meeting at an IND office. 

These new measures – which will function as alternatives to traditional enforcement measures, such as warnings and fines – will only apply to violations relating to the obligation to keep and retain records (duty of administration) and the information obligation (duty to inform). 

Contacting recognized sponsors or conducting targeted information sessions may be conducted for the following acts of non-compliance: 

• • a failure to notify a change of the location where the information on the foreign nationals in the records is kept and retained; 
  • a failure to notify  
    • when an employee transfers within the same corporate group and the receiving entity is also a recognized sponsor;
    • where the employment contract or course of study ends simultaneously with the residence permit; 
    • where the residence permit has already expired or will within four weeks; or 
    • where the foreign national has already been granted a residence permit under a different restriction or residence purpose.  

Meanwhile, a formal enforcement meeting may occur for infringements not addressed above, or where the above infringements occur more than twice a year. 

If the recognized sponsor does not demonstrate a willingness to rectify the non-compliance, the IND will apply its standard fine policy. Additionally, very serious transgressions, including fraud, abuse and breach of duty of care, will continue to be addressed solely via the traditional enforcement measures.  

These new measures will be in place for one year as a pilot. After that time, the IND will assess the situation to determine whether this program should continue and, if so, whether any modifications are necessary.  

This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen.