IND Inspections: What Dutch Employers Need to Know About Recognised Sponsorship Compliance

A Privilege That Comes With Responsibility

Recognised sponsor status enables companies to fast-track immigration procedures when hiring international talent. This status is granted based on trust: the IND assumes that sponsors will comply with legal obligations and therefore does not conduct exhaustive checks during the application process. Instead, the emphasis is on post-approval monitoring.

To grant recognised sponsorship status, the IND performs in-depth evaluations, including assessments of a company’s financial health and operational continuity. If concerns arise about solvency within the past three years, the IND may consult the Dutch Enterprise Agency (RVO), potentially delaying approval by six months or more.

However, this trust-based model is evolving. Increased scrutiny of the highly skilled migrant scheme, the caretaker government’s intention to reduce migration to the Netherlands, and efforts to prevent misuse of the scheme have led to more frequent IND audits. Compliance requirements are expected to become even stricter. Recently, the IND expanded the administration duty for recognised sponsors, requiring them to retain actual proof of salary payments. You can find our update on this subject in this article.

What Triggers an IND Inspection?

Inspections may be initiated for several reasons, including:

• Complaints or indications of non-compliance
• Random selection
• Inconsistencies in salary payments or documentation
• Concerns about residence status and employment conditions

These inspections are typically announced in advance.

IND Audit Process

When a company is selected for an audit, the IND first requests specific documents for review, such as:

• Proof of salary payments over several months or years
• Pay slips
• Antecedents certificate

After reviewing these materials, the IND conducts an on-site visit, which includes a formal interview with company representatives and additional questions about compliance practices. Following the visit, the IND issues a written report summarising its findings and outlining any potential consequences.

Key Areas of Compliance

To maintain sponsor status and avoid penalties, companies must pay close attention to several critical areas:

1. Documentation and Record Keeping

Sponsors must maintain complete and accurate records for each sponsored employee, including:

• Passport and residence permit copies
• Employment contracts and job descriptions
• Pay slips
• Records of any changes in employment terms
• As of January 2026: Proof of salary payment to the employee’s bank account

These documents must be retained for at least five years after the employee leaves the company.

2. Timely Notifications

Recognised sponsors are required to inform the IND of any significant changes within 28 days, such as

• Termination of employment
• Changes in job role or working hours, or a decrease in salary
• Company-related changes such as liquidation

A change of the recognised sponsor’s administration address must be notified within two weeks.

3. Duty of Care

As a recognised sponsor, you have a duty of care. This means ensuring a thorough and responsible recruitment and selection process for foreign nationals. During an audit, the IND may request evidence of these practices.

In addition, you are required to inform foreign employees about admission and residence requirements, as well as other relevant regulations. We can advise you on how to maintain clear records demonstrating that employees have been properly informed.

4. Special Considerations

• Minimum salary thresholds: Understand which allowances can be counted toward salary thresholds.
• Leave hours: Certain types of leave can cause salaries to fall below the required threshold. While some forms of leave, such as legal parental leave, are permitted to reduce salary, others may lead to non-compliance (e.g., unpaid extra vacation days). Specific types of leave may also trigger a notification requirement, for example, when an employee is legally authorised to take leave, but the salary drops below the minimum threshold.
• Remote work: This can affect residence permits, tax obligations, and social security.

Consequences of Non-Compliance

Failure to meet sponsorship obligations can lead to serious consequences:

• Warning: Valid for 24 months. Repeat violations during this period may result in fines.
• Administrative fines: Up to €1.500 for individuals and €3.000 for legal entities.
• Suspension or revocation of sponsor status: This can impact the residence status of foreign employees and complicate future hiring.
• Criminal prosecution: In extreme cases, violations may be referred to the public prosecutor.

How to Prepare for an IND Inspection

Proactive preparation is key to navigating inspections smoothly. Best practices include:

• Conduct regular internal inspections to ensure all documentation is complete and up to date.
• Centralise your records in a secure digital system for easy access.
• Train HR staff on immigration regulations and requirements.
• Monitor salary thresholds and other updates; adjust compensation and global mobility policies accordingly.
• Implement a notification tracking system to ensure timely reporting of changes.

An IND inspection can be an opportunity to strengthen internal processes. By implementing robust compliance systems and staying up to date with regulatory changes, Dutch employers can continue attracting top international talent while remaining fully aligned with immigration laws.

Would you like to discuss these insights? Get in touch with us.

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