Dutch DBA rules & hiring an independent — without the worry

Hiring an independent interim Product Owner or Product Manager in the Netherlands in 2026 raises the same question at most organisations: how does this sit with the Dutch DBA rules on false self-employment (schijnzelfstandigheid)? A fair question — and exactly why it deserves an honest, concrete answer instead of small print. This page covers where the rules stand right now, why an interim engagement the way I run it holds up well against them, and how we set it up properly together.

To be clear up front: this is general information, not legal advice. I'm happy to think through the exact contract form with you and your procurement or legal team, so it's properly arranged for both sides.

Where the DBA rules stand (as of June 2026)

• Since 1 January 2025 the Dutch tax authority (Belastingdienst) enforces against false self-employment again; since 1 January 2026 full enforcement formally applies.
• The cabinet has extended the "soft landing" through 2026: enforcement is risk-driven and as a rule starts with a company visit and a warning. Fines for false self-employment generally stay out in 2026, except in cases of evident bad faith.
• What decides the matter is not the label on the contract but the day-to-day reality: the actual working relationship is assessed as a whole (along the criteria from the Deliveroo ruling). A model agreement (modelovereenkomst) helps, but is no guarantee; approved model agreements remain valid until 2029 at the latest.
• The clarification part of the VBAR bill was scrapped in March 2026; a new Self-Employment Act (Zelfstandigenwet) is in the works (2027 at the earliest). The legal presumption of employment at a low hourly rate (around €38) continues as separate legislation.

In short: the rules have tightened, but working with independents is perfectly possible — provided the engagement is genuinely set up as an independent assignment. Which is exactly how I work.

Why an engagement with me scores well on the criteria that matter

• A real business, multiple clients. I work through Venema Consulting & Innovatie (KVK 42066462), with my own tools, my own methods and my own entrepreneurial risk — typically for several clients.
• A rate far above the legal presumption. My rate sits around €95–150 per hour — well above the threshold below which employment is presumed.
• Temporary by design. An interim engagement has a defined period (1–12 months), a clear scope and an end date. I work on the handover from day one — my goal is to make myself redundant. That is more or less the opposite of being embedded as a disguised employee.
• Outcome, not capacity. You hire me for a result — roadmap back on course, team back up to speed, product launched — not as an extra pair of hands on the roster.
• Own way of working. How I get to that result — approach, method, planning — I decide in consultation, but independently.

In all honesty: some of this sits with you as the client too. Don't treat an interim professional as a regular employee on a different contract — no performance reviews, no fixed spot in the org chart, but genuine room to do the work by their own professional judgement. I'd rather have that conversation up front than afterwards.

How we arrange it in practice

1. A clear contractor agreement — scope, outcome, duration and rate on paper. Working with a model agreement is no problem.
2. Paper = practice. We set up the engagement so that what's written matches how we actually work — and re-check it mid-way if the assignment shifts.
3. Your legal team on board. Procurement, legal or a broker involved? Fine — I also work through framework agreements and hiring desks.

Frequently asked questions

Is a model agreement mandatory?

No. A model agreement is a tool, not an obligation — and since enforcement resumed, what counts most is whether the practice matches. If your organisation prefers to use one, that's no problem at all.

What if the tax authority still judges the relationship to be employment?

That's exactly why we set the engagement up properly at the front: defined, outcome-driven, with room for independent judgement. On top of that, 2026 runs under the soft landing: the Belastingdienst as a rule starts with a company visit and a warning, not a fine. Nobody can give guarantees — distrust anyone who does — but we can make the risk small and discussable.

Do you also work through a broker or hiring desk?

Yes. Hiring directly is simplest, but working through a broker, framework agreement or hiring desk works fine too. Little changes for you; I take care of my side.

Does the duration of the engagement matter?

The law sets no hard maximum, but temporariness helps: an engagement with a clear end date and a handover points to independence. My engagements run one to twelve months — and I actively work toward the moment you no longer need me.

Rather talk it through?

Not sure how this plays out for your organisation? Book a no-obligation 30-minute intro call — we'll walk through your situation together. Get in touch or find me on LinkedIn.