Enforcement of the rules separating genuine freelancing from disguised employment restarted in 2025 after years of a moratorium, and 2026 added penalties on top. Much of the fallout reaches freelancers indirectly, through clients shortening engagements and rewriting contracts, which is why the timeline matters even to people nobody is auditing.
Wet DBA is the law governing whether a freelance engagement is genuinely self-employed or actually disguised employment, and the honest answer is moderately worried, trending upward. The enforcement moratorium ended in January 2025; through 2026 the Belastingdienst is running what it calls a soft landing — it can already claw back unpaid payroll tax retroactively from 2025 onward, and as of 2026 it can fine for intentional or grossly negligent sham self-employment, though it's still holding back on routine delay fines. What actually draws scrutiny is working like an employee in practice regardless of what the contract says: fixed hours, using the client's tools and systems, one client for a long stretch, someone at the client directing how and when you work. The financial risk mostly sits with your client, since they owe the back taxes, which is why more of them are pushing shorter engagements now. If you genuinely run a business — multiple clients, your own equipment, control over your own working method — this isn't something to lose sleep over yet.