Holiday Park Staffing 2026: New Dutch Labor Laws & What They Cost

Starting January 1, 2026, Dutch holiday parks face two major staffing regulation changes: immediate pension contribution increases and a new mandatory licensing system for temporary employment agencies. Both changes increase operational costs and compliance complexity. Understanding the timeline and requirements now prevents costly mistakes later.

The Immediate Change: Pension Contributions (January 1, 2026)

The new Collective Labour Agreement (CLA) for temporary agency workers takes effect January 1, 2026, fundamentally changing how parks must compensate seasonal staff.

Pension Cost Increase

Employer pension contributions increase to 23.4% of wages (15.9% employer-paid, 7.5% employee-paid). This replaces the previous “10-element hirer’s remuneration” system used for temporary workers.

For a typical 50-unit holiday park with 10 seasonal staff:

• Assumed seasonal wage: €14.77/hour (aligned with Dutch minimum wage expectations)
• 10 staff × 1,040 hours per season = 10,400 total hours
• Total seasonal payroll: ~€153,600
• Pension cost increase: €153,600 × 23.4% = €35,942 additional annual cost

This cost applies to every temporary worker your park hires, whether directly or through an agency.

Equal Conditions Replace Old System

Under the new CLA, temporary workers must receive equal conditions to comparable regular employees. “Equal” means the total employment package—not just hourly wage—must be equivalent.

This includes:

• Pay: Same hourly or salary rate
• Working hours: Same schedule and overtime rules
• Holidays: Same number of days (no more holiday reservations or separate accruals)
• Sick pay: Same percentage as regular staff (no reduction to 80% or 90%)
• Benefits: Any pension, health insurance, or other benefits regular staff receive
• Allowances: Travel, meals, uniforms, or other allowances

If your park’s permanent receptionists earn €15/hour with 25 holiday days and full sick pay, your seasonal receptionists must receive the same.

No Holiday Allowance Reservations

Previously, parks could reserve 8.33% of wages as holiday pay instead of granting actual holiday days. This no longer applies. Holiday days must be granted according to the same terms as permanent staff.

Transition Protection

If a worker would lose entitlements under the new system, they have a 6-month transition period (until June 30, 2026) during which they retain existing holiday allowance and sick pay percentages.

The Licensing Requirement: WTTA (2027-2028)

Starting January 1, 2027, temporary employment agencies must be licensed by the Dutch government’s newly created NAU (Nederlandse Autoriteit Uitleenmarkt) to legally operate.

Why This Matters for Parks

From January 1, 2028, parks cannot legally hire from any agency not registered in the NAU public register. Using an unlicensed agency exposes parks to:

• Substantial fines from Dutch labor authorities
• Chain liability: Parks become liable for unpaid taxes and social security contributions owed by the agency
• Reputational damage: Association with non-compliant agencies affects your standing

Agency Licensing Timeline

The process unfolds in three phases:

Phase 1: Transition Window (November 1 - December 31, 2026)

• Agencies with current SNA certification can apply for NAU licenses
• This simplified pathway reduces administrative burden for compliant agencies
• Parks should encourage current agencies to apply during this window

Phase 2: General Application Period (January 1 - July 1, 2027)

• All other agencies can apply for NAU licenses
• Applications must be submitted by July 1, 2027
• Agencies receive a public listing once licensed

Phase 3: Enforcement (January 1, 2028)

• Mandatory NAU register becomes the only legal source for temporary staff
• Parks must verify all agencies in the public database
• Non-compliance results in fines

What Agencies Must Provide

To receive a NAU license, temporary employment agencies must:

• Submit a Certificate of Good Conduct (VOG-RP) for the legal entity
• Deposit €100,000 as a financial guarantee (waarborgsom)
• Demonstrate compliance with the new CLA (pension contributions, equal conditions)
• Prove they meet all employment law requirements (minimum wage, working hours, tax obligations)

How Parks Verify Licenses

From January 1, 2027, the NAU maintains a publicly accessible register of licensed agencies. Parks must:

1. Check the NAU public database before hiring from any temporary agency
2. Verify that each agency they use is listed as active
3. Document this verification for compliance purposes

Failure to verify puts your park at legal and financial risk.

Implementation for Park Operations

Update Staffing Budgets

The pension increase is effective immediately on January 1, 2026. Adjust your 2026 staffing budget to reflect the additional 23.4% pension cost for all temporary workers.

Verify Agency Status

Start now:

• Contact your current temporary employment agencies and ask if they plan to apply for NAU licensing
• Request proof that they’re SNA-certified (this makes the transitional path easier for them)
• Make a list of which agencies you work with and confirm their licensing plans

Prepare for Transition

Between now and December 31, 2026:

• Monitor your agencies’ licensing progress
• Begin evaluation of direct hiring as an alternative (if staff volume justifies it)
• Document the certification status of each agency you use

From January 1, 2027:

• Check the NAU public register to confirm all agencies have applied
• Agencies should have NAU approval by mid-2027 (after the July 1 deadline)

From January 1, 2028:

• Verify licenses one final time before the enforcement date
• Ensure all agencies are listed in the NAU register
• Do not hire from any unlicensed agency

Consider Direct Hiring as an Alternative

If key agencies fail to obtain NAU licenses, direct hiring becomes necessary. This approach:

Advantages:

• Avoids dependency on licensed agencies
• Possible cost savings if you eliminate agency fees
• Greater control over staff scheduling and placement
• Equal conditions are easier to manage directly

Responsibilities:

• Payroll administration, taxes, and social security
• Workplace health and safety
• Holiday scheduling and sick leave management
• All employment documentation

Considerations:

• Requires internal HR capacity
• Higher admin burden than agency hiring
• Responsibility for benefits and pension contributions
• Legal liability for employment disputes

For seasonal staff, direct hiring works best if you have 15+ staff or a dedicated HR person to manage onboarding and payroll.

Financial Impact Summary

For a 50-unit holiday park with 10 seasonal staff:

Immediate (January 1, 2026):

• Pension contribution increase: ~€35,942/year
• CLA compliance review (internal time): minimal direct cost

2027:

• Agency verification processes: minimal direct cost
• Potential switch to direct hiring (if needed): variable, depends on your choice

2028 Onwards:

• Ongoing pension contributions: €35,942+/year (may increase with wages)
• NAU license verification: ongoing administrative task

Total 2026 impact: ~€35,942 additional staffing cost (plus any wages increases tied to equal conditions)

What to Do

1. Now (by end of 2025):

   • Review your current temporary staffing arrangements
   • Contact agencies and confirm their NAU licensing plans
   • Calculate updated 2026 staffing budget including pension increases

2. January 1, 2026:

   • Implement new pension contribution rates (23.4%)
   • Ensure all temporary workers receive equal conditions to comparable permanent staff
   • Discontinue holiday allowance reservations; start accruing actual holiday days

3. Throughout 2026:

   • Monitor agency licensing applications (transitional window: Nov-Dec 2026)
   • Prepare documentation of agency verification for compliance

4. By July 1, 2027:

   • All agencies you use must have submitted NAU applications
   • Start checking NAU public register for licensing status
   • Have a backup agency or direct hiring plan if primary agencies don’t receive licenses

5. By December 31, 2027:

   • Confirm all agencies are licensed in NAU register
   • Complete any transition to direct hiring if applicable

6. January 1, 2028:

   • Verify NAU licenses one final time before enforcement begins
   • Do not work with any unlicensed agencies

Frequently Asked Questions

When do the new Dutch staffing regulations take effect?

The Collective Labour Agreement (CLA) changes take effect January 1, 2026, with immediate pension contribution increases. The WTTA temporary agency licensing law takes effect January 1, 2027, with enforcement and fines beginning January 1, 2028.

How much will pension contributions increase in 2026?

Employer pension contributions increase to 23.4% (15.9% employer-paid, 7.5% employee-paid) starting January 1, 2026. For a 50-unit park with 10 seasonal staff, this represents an additional cost of approximately €35,942 per year.

What does ‘equal conditions’ mean for temporary workers?

Equal conditions means a temporary worker’s total employment package (pay, hours, overtime, holidays, sick pay, allowances, pension, and benefits) must be at least equal in value to a comparable regular employee at the same park. You can’t offer lower pay or fewer benefits just because they’re seasonal.

Do I need to verify my temporary agencies are licensed?

Yes. From January 1, 2028, it is illegal to work with temporary agencies not listed in the official NAU (Nederlandse Autoriteit Uitleenmarkt) public register. Parks must verify licenses and can face substantial fines for using unlicensed agencies.

What happens if a temp agency loses its NAU license?

You must immediately stop using that agency and find a licensed alternative. The NAU maintains a public register of licensed agencies that you must check.

Can we hire staff directly instead of using agencies?

Yes. Direct hiring is a legal alternative. You assume all employer responsibilities (payroll, taxes, social security, benefits, sick leave), but avoid agency fees and licensing risk. This is viable if you have internal HR capacity.

What are the penalties for non-compliance?

Fines are substantial. For working with unlicensed agencies from January 1, 2028, parks face penalties. Additionally, you can be held liable for unpaid taxes and social security contributions owed by the agency (chain liability).

When can temporary agencies apply for NAU licenses?

Agencies with current SNA certification can apply during the transitional window from November 1, 2026 to December 31, 2026. All other agencies apply starting January 1, 2027, with a deadline of July 1, 2027.

Sources

• Eerste Kamer stemt in met strengere regels voor de uitleenmarkt - Rijksoverheid
• Important CLA changes effective January 1, 2026 – equal pay & employer action required - AAme Adviseurs
• Working Conditions for Employees - Business.gov.nl
• Wet toelating terbeschikkingstelling van arbeidskrachten (WTTA) - Nederlandse Arbeidsinspectie