New IND requirement under compliance duty to administrate for IND recognised sponsors

What is the new administrative compliance duty?

The IND has announced that, as of 1 January 2026, the compliance duty to administrate for recognised sponsors will be expanded. From that date onward, recognised sponsors will be required to include proof of salary payments to employees holding a residence permit as a highly skilled migrant or European Blue Card in their administration.For example, statements from the company’s business bank account or an overview of batch payments must be retained. These documents must demonstrate that the salary was transferred to a bank account in the employee’s name.

Why is the administrative compliance duty expanded?
The Explanatory Memorandum (Dutch) shows that the main reason for this adjustment is that previously there was no legal basis to enforce compliance if an employer refused to provide insight into the payment of wages. By introducing this new administrative requirement, the IND will be able to request evidence of salary payment from employers per 1 January 2026.

What will change for recognised sponsors?
We expect that many employers will not have to make any adjustment, or need to make only minor adjustments. After all, most companies already document salary payments within their administration. It is, however, important that salary payments can be traced per employee in the event of an IND audit. The new administration compliance duty does not require employers to keep proof of payment in each individual employee file.

Other obligations for recognised sponsors
In addition to this new administrative obligation, IND recognised sponsors are already subject to a range of compliance duties.

For instance, a sponsor must inform the IND of any changes in the situation of a foreign national, such as:

the termination of the employment contract

any leave situation in which the salary temporarily falls below the required threshold.

A relocation of the company itself must also be reported to the IND within two weeks.

Furthermore, an employer must retain for example:a copy of the employee’s passportthe signed antecedents certificate and the employment contract in its administration.

For holders of a European Blue Card, the administration must also demonstrate that the employee meets the required qualifications.

The recognised sponsor also has a duty of care. This includes a careful recruitment and selection process and providing correct information to the employee.

The employer can be held responsible by the IND for the departure of a foreign national.

If you are a recognised sponsor and unsure whether you fully comply with the IND compliance duties, please feel free to contact us: we are happy to guide you on this.

Considering becoming a recognised sponsor? We would be pleased to assist you through the application process.