A daily briefing on European HR, labour law and compliance developments for SME HR teams across the EU, UK, Switzerland and the Nordics.
Top story: Netherlands’ worker classification deadline looms as €38/hour legal presumption must hit the Staatsblad by 31 August
The Dutch government faces a self-imposed deadline of 31 August 2026 to publish the rechtsvermoeden (legal presumption of employment) in the Staatsblad, the final step before the rule takes effect on 1 January 2027. The provision creates a rebuttable presumption that any worker paid below €38 per hour is an employee, not a self-employed contractor. If a worker earns below that threshold and claims employee status, the burden shifts to the hiring organisation to prove the relationship is genuinely self-employed.
The legal presumption was originally part of the broader Wet VBAR (Wet verduidelijking beoordeling arbeidsrelaties), but Minister Aartsen scrapped the VBAR’s “clarification” component in March 2026 after sustained pushback from freelancers and clients. The rechtsvermoeden was detached as standalone legislation. The €38 threshold is indexed to the statutory minimum wage as of 1 January 2026 and will be updated annually.
This matters for SMEs right now because enforcement is already live. Since 1 January 2025 the Belastingdienst (Dutch Tax Authority) has been enforcing the existing DBA rules in full. Since 1 January 2026 it can also impose vergrijpboeten (serious-fault penalties) of up to 100% of the back-tax assessment for deliberate misclassification. Failing a substance test in 2026 exposes the client to back-taxes from 2025, plus the penalty. Once the rechtsvermoeden takes effect in January 2027, it will give workers below the threshold a powerful new tool to challenge their status, adding civil liability on top of the existing tax enforcement.
What to do: If you engage freelancers or ZZP contractors in the Netherlands, review each arrangement now against the €38/hour threshold. For relationships below that rate, assess whether the working reality supports genuine self-employment under existing case law (degree of control, entrepreneurial risk, substitution rights). Do not wait for the Staatsblad publication: the enforcement infrastructure is already active, and the financial exposure for misclassification is substantial.
Also developing
Belgium: A comprehensive employment law package took effect on 1 July, touching working schedules, night work, notice periods and temporary work. Three changes stand out for SMEs. First, employers may now choose between maintaining detailed working schedules or replacing them with a general framework indicating when employees can perform work, reducing administrative burden. Second, for contracts starting from 1 July, the statutory notice period on employer-initiated dismissal is capped at 52 weeks regardless of seniority. Third, night work premium rules have changed for the distribution and logistics sector: new hires from 1 July onward receive the premium only for hours worked between 23:00 and 06:00 (previously 20:00 to 06:00), with a transitional regime preserving existing entitlements for current staff. The formality requiring written confirmation of intent to conclude a temporary agency contract has also been abolished. What to do: Belgian employers should update employment contract templates and payroll configurations to reflect the new notice period cap and night work premium rules. HR teams in distribution and logistics should brief line managers on the two-tier premium structure for existing versus new staff.
Sweden: The minimum salary for non-EU/EEA work permit holders rose to SEK 33,390 per month on 1 June, up from SEK 29,680 (an increase of roughly 12.5%). The new threshold ties eligibility to 90% of the Swedish median wage, replacing the previous 80% benchmark. First-time applications decided on or after 1 June are assessed under the new rules. A transitional period applies to extension cases: existing permit holders who file before 1 December 2026 may still use the old salary requirements. The 152 shortage occupations (including healthcare, IT and skilled trades) benefit from a lower 75% threshold. What to do: Employers sponsoring non-EU/EEA workers in Sweden should check that current and planned salaries meet the new SEK 33,390 floor. For staff on existing permits, note the 1 December extension deadline and file early if the current salary falls between the old and new thresholds.
EU: The Council of the EU and the European Parliament reached agreement on 23 June on the sixth revision of the Carcinogens, Mutagens and Reprotoxic Substances Directive (CMRD). The text introduces new occupational exposure limits for cobalt and its inorganic compounds (relevant to battery production), polycyclic aromatic hydrocarbons (steel, iron and aluminium), 1,4-dioxane (chemicals and textiles) and isoprene (chemicals and rubber). Welding fumes have been added to the list of covered processes for the first time. The European Commission estimates the revision will prevent around 1,700 lung cancer cases and 19,000 other occupational illnesses over the next 40 years. What to do: Employers in manufacturing, construction, chemicals and battery production should begin reviewing workplace exposure assessments against the forthcoming limits. The formal adoption and transposition timeline will follow, but early preparation, particularly for welding operations, will smooth the transition.
On the radar
EU-OSHA, October 2026: The official launch of the Healthy Workplaces Campaign 2026 to 2028, “Together for mental health at work,” is scheduled for October. The campaign will spotlight psychosocial risks across all sectors, with early resources already available in English at healthy-workplaces.osha.europa.eu.
UK zero-hours contracts consultation (previously covered): Closes 25 August 2026.
UK pay transparency consultation (previously covered): Closes 27 October 2026.
EU Platform Workers Directive (previously covered): Member states must transpose by 2 December 2026.
Germany digital payroll deadline (previously covered): All employers must keep social-insurance payroll documents in digital, GoBD-compliant form by 31 December 2026.
Sources
- Asanify: Netherlands VBAR worker classification update (June 2026)
- ZZP Pulse: False self-employment in the Netherlands 2026, DBA enforcement guide
- Smarter Search: The Dutch Wet DBA in 2026, enforcement and VBAR update
- Octagon People: Wet VBAR Law, how inbound employers should react in 2026
- Baker McKenzie: Belgium, new legislation on various Belgian employment law provisions (May 2026)
- Liedekerke: Belgium’s new labour rules explained (2026)
- Zalaris: New salary thresholds for Swedish work permits in 2026
- Newland Chase: Sweden work permit reform in force from 1 June 2026
- Council of the EU: Council and Parliament agree on measures to protect workers from exposure to hazardous substances (23 June 2026)
- EU-OSHA: EU Directive revision to better protect workers from hazardous substances
- EU-OSHA: Healthy Workplaces Campaign 2026 to 2028, Together for mental health at work
Europe HR Compliance Pulse is an informational summary of publicly reported legal and regulatory developments. It is not legal advice. Always confirm obligations for your specific situation and market with a qualified adviser.
