False self-employment: where does your engagement stand?
Since 1 January 2025 the Dutch tax authority enforces against false self-employment again. The payroll-tax assessment lands with your client, not with you — which is precisely why it affects you: a client in doubt would rather not renew. Below you walk your own engagement through the four questions that drive the conversation, with the reason each signal counts. You get an indication, not a verdict.
What changed in 2025
The enforcement moratorium ended on 1 January 2025. Since then the tax authority can levy payroll taxes on clients who hire someone as a freelancer while the working relationship is in fact employment.
That assessment goes to your client, not to you: it is payroll tax he should have withheld. For you the consequence sits elsewhere. A client who does not want that risk ends the engagement or does not extend it — and if something is established at his end, your own tax return can be revisited too, because the entrepreneur deductions hinge on whether you are an entrepreneur.
No fines were imposed in 2025. From 2026 the tax authority can impose culpability fines in cases of intent or gross negligence; default fines on an additional assessment are still withheld.
Model agreements are no longer reviewed. Approved agreements remain valid through 31 December 2029, but only if the work is actually done that way. An agreement that does not match practice is not evidence: the facts outrank the paper.
The four questions you answer yourself
These four are about your contract and about how the work actually goes — exactly what no system can read out of your time records. Nothing is asked of you in return: nothing is sent and nothing is stored, your answers stay in your own browser.
What your answers show
Answer the four questions above.
This is not a result. Four questions are not the test — they are the four points the conversation usually turns on. One “no” does not make you falsely self-employed, and four times “yes” does not clear you.
And what your time records say about it
The questions above are about paper. Alongside them are signals you do not have to fill in, because they already sit in your records. Freeliq reads five of them and puts them next to your answers, per engagement.
| Signal | What it says | Where Freeliq draws the line |
|---|---|---|
| Share of hours at your largest client | The more dependent you are on one client, the more it looks like employment. | Below 40% no signal, from 90% the strongest |
| Number of active clients | Puts that share in proportion: 100% at one client weighs differently if you have no others. | Shown alongside the share |
| Duration of the engagement | Long, uninterrupted relationships point towards being embedded in the organisation. | From roughly 36 months the strongest |
| Average hours per week | A steady, high commitment looks like a job with a rota. | From roughly 40 hours the strongest |
| Your hourly rate on this engagement | In the pending Dutch bills a low rate counts as an indication of employment. | Below € 36 the strongest, above € 72 none |
Note what those lines are: thresholds Freeliq sets itself, not standards from the tax authority. They are written into the calculation and can be adjusted per tax year, because the legislation is still moving. The € 36 comes from the hourly rate circulating in the Dutch VBAR proposals — a signal value, not a statutory limit.
In the weighting, client dependency counts heaviest (25%), followed by duration, regularity and rate (15% each). The four questions above together make up the remaining 30%, with substitution and setting your own schedule each counting twice as heavily as own equipment and entrepreneurial risk.
What this is and is not
Freeliq gives an indication. The screen in the app says so in as many words: a risk signal based on your hours, rate, client and the questionnaire — not a confirmation of false self-employment, and not legal or tax advice.
Two things go with that. As long as the questionnaire is unanswered the outcome is no more than a pre-screen: the decisive signals live in your contract, and no system can read those out of your hours. And the calculation is deliberately dull — fixed weights, fixed thresholds and a plain-language explanation per signal, so you can retrace where an outcome came from.
A real assessment is made by the tax authority, or by your own adviser on the basis of your contract and your practice. What is here helps you prepare that conversation; it does not replace it.
What you can do about it
- Spread your revenue. Client dependency weighs heaviest and is the only signal you change yourself, by finding work.
- Record what you decide yourself. When you work, with which means, and who may do the work when you are away.
- Work the way your agreement says. A model agreement only helps as long as practice resembles it; either way it runs until the end of 2029.
- Keep the engagement bounded. An engagement with a start, an end and a deliverable is something other than a permanent slot in the rota.
- Make agreements and deliveries demonstrable. Showing per engagement what was agreed and what was delivered visibly sells work rather than time — see getting hours signed off (in Dutch).
Frequently asked questions
Can I tell from this whether I am falsely self-employed?
No. You see how your engagement stands on the signals the conversation usually turns on, and nothing more. Whether a working relationship is employment depends on the whole set of facts and circumstances, and that judgement is made by the tax authority or a court.
Who gets the assessment if it goes wrong?
The client. He should have withheld and remitted payroll taxes, so that is where the assessment lands. For you the consequence can be that your own return is revisited: if you were not an entrepreneur, the entrepreneur deductions do not apply either.
Does a model agreement still help?
An approved model agreement can be used through 31 December 2029; new ones are no longer reviewed. It only helps if you also work the way it describes — an agreement that does not cover your practice is no evidence in an audit.
Does this apply if I work through an agency?
Yes, and then there is one more link in the chain. In practice the end client often determines what you do, while your contract sits with the agency. How to deliver and get your hours signed off in that setup is on working through an agency (in Dutch).
Is this the same test as the Dutch hours criterion?
No, they are two separate tests. The hours criterion is about how many hours you spend on your business; this is about whether you make those hours as an entrepreneur. You can clear the 1,225 hours easily and still sit at a single client — see the hours criterion (in Dutch).