Freelance dossier

NOBTRA, the trade association for the training sector in the Netherlands, working closely with the Ministry of Social Affairs and Employment (SZW) and the tax authorities, established sector guidelines for its own membership on 17 November 2025. These guidelines are intended for trainers, instructors and clients and provide practical tools for carefully framing assignments in light of the DBA legislation.

For the first time, there is a guideline that clearly sets out how training professionals, as a sector, can work in a transparent manner without the relationship with the client being deemed as one of employment. The initiative has been welcomed by the Ministry of Social Affairs (SZW) and the tax authorities because it shows that the sector itself is taking responsibility for preventing pseudo self-employment.

The guidelines help with establishing the nature of the working relationship and its administration, to be able to work as a self-employed person within this framework. The Tax and Customs Administration has confirmed that it supports the use of these guidelines and expects them to be widely applied. When enforcing the law to combat bogus self-employment in the future, the tax authorities will first check whether a trainer is working in accordance with the sector guidelines and is also a member of NOBTRA. This does not guarantee that there will be no audit, but is a clear sign of confidence on the part of the Tax and Customs Administration. These sector guidelines may offer a practical tool for more than just this sector: they imply that other sectors could agree on similar guidelines for their own field. 

By following the sector guidelines you demonstrate, as a training professional, that you are aware and act with care. Conversely, however, they offer no certainty in terms of requalification. We will monitor developments in other sectors and should there be any changes there we will, of course, include them in this newsletter.