Sick Leave and Reintegration in the Netherlands (2026): Employer Obligations, Timelines and Checklist

Sick leave obligations Netherlands employers face are among the most demanding in Europe, combining extended wage-continuation duties with a tightly sequenced reintegration process that is actively supervised by the UWV (Uitvoeringsinstituut Werknemersverzekeringen) and the Netherlands Labour Authority (Nederlandse Arbeidsinspectie). For 2026, renewed enforcement attention makes it essential that employers map every obligation to the correct day, week and month, and keep the documentation to prove it. This guide sets out the complete employer process under the Wet verbetering poortwachter (the Gatekeeper Improvement Act) and the loondoorbetaling (continued wage payment) rules in the Dutch Civil Code (Burgerlijk Wetboek, Book 7), with numbered steps, deadline tables, a required-documents checklist and a costs table.

It explains exactly when the bedrijfsarts (company doctor) must be involved, when the Plan van Aanpak (Plan of Approach) must be drafted, and what triggers an inspection or financial sanction. Throughout, Dutch legal terms are explained in plain English for international readers. For broader context, see our Employment law, Netherlands practice area.

Overview, What this guide covers and who must act

Dutch law places primary responsibility for managing sickness absence and reintegration on the employer, not on the state or the employee. Understanding your sick leave obligations Netherlands wide begins with two statutory pillars: the duty of continued wage payment during illness (loondoorbetaling) under the Dutch Civil Code, and the structured reintegration duties set out in the Wet verbetering poortwachter. The UWV monitors how well employers meet these duties, and the Netherlands Labour Authority can act where health-and-safety or systemic failings arise.

Quick summary of employer obligations

• Contact promptly. Make early contact when an employee reports sick and record it.
• Pay wages. Continue paying wages, generally at least 70%, for up to two years of illness.
• Engage the bedrijfsarts. Arrange occupational health assessment and obtain a problem analysis.
• Draft a Plan van Aanpak. Agree a reintegration plan jointly with the employee.
• Act and document. Implement reintegration measures and keep a full dossier.
• Report to UWV. Compile and submit the reintegration dossier ahead of any WIA (Work and Income according to Labour Capacity Act) assessment.

Who this applies to

The obligations apply to all employers with staff on an employment contract, regardless of company size, and extend to employees on fixed-term contracts for the duration of the contract. Larger employers often operate internal occupational health services (arbodienst), while smaller employers typically contract an external bedrijfsarts or arbodienst. Agency and temporary workers are generally the responsibility of the agency as formal employer, but the hiring organisation still has practical duties around workplace adjustment. Employees retain a reciprocal duty to cooperate, a point addressed further in the FAQ on employee rights.

Eligibility and triggers, When sick leave obligations Netherlands employers face begin

The clock on your sick leave obligations Netherlands wide starts on the first day of reported illness. From that day, both the wage-continuation duty and the Gatekeeper reintegration process are active; there is no waiting period before duties attach.

When does the employer’s duty to pay apply?

The duty to continue paying wages applies from the first day of sickness and can last up to 104 weeks (two years). The statutory minimum is 70% of the wage (in the first 52 weeks, subject to the statutory minimum wage floor where applicable), though many collective labour agreements (CAO) or individual contracts require a higher percentage, frequently 100% in the first year. Payroll must be adjusted correctly from the outset, because inconsistent or incorrect wage records are a common trigger for later disputes.

When does the reintegration procedure (poortwachter) begin?

The Gatekeeper process runs in parallel with the sickness from day one, but its formal milestones are staged. Early contact is expected within the first days of absence. The bedrijfsarts problem analysis follows within approximately six weeks, and the Plan van Aanpak must be drafted within approximately eight weeks of the first sick day. These are not optional best-practice targets, they are the backbone of a defensible reintegration dossier.

Step-by-step employer reintegration process

The following numbered process reflects how your sick leave obligations Netherlands employers must discharge over a full two-year cycle. Each step identifies who acts, what to document and when.

1. Step 0, Set up internal policies and designate a reintegration lead

   Before any absence arises, put a written sickness and reintegration policy in place and name a reintegration lead (usually an HR professional or, in small firms, the owner). Contract a bedrijfsarts or arbodienst in advance. This preparatory step ensures no time is lost once the clock starts.

2. Step 1, Notification and first contact (within 1–3 days)

   When an employee reports sick, the line manager or HR should make contact promptly, commonly within the first days. Record the date and time of the report, the fact of absence (not confidential medical details, which the employer is not entitled to request), any functional limitations the employee volunteers, and the expected return date. This first contact record is the foundation of the dossier and is frequently scrutinised later. Maintain regular, documented contact thereafter.

3. Step 2, Ongoing monitoring and loondoorbetaling obligations (first 2 weeks to 6 months)

   Register each sick day and ensure payroll reflects the correct continued-payment percentage, at least 70% of wage, or higher where a CAO or contract requires it. Keep monitoring the employee’s situation through regular check-ins, and begin considering whether any immediate, low-cost workplace adjustments could support an earlier partial return. Document every contact. During this window the employer should also decide, with the bedrijfsarts, whether the absence is likely to be short-term or whether the full Gatekeeper track must be mobilised. Treating a developing long-term absence as a routine short absence is one of the most damaging early errors.

4. Step 3, Occupational health assessment and problem analysis (within ~6 weeks)

   Where the absence is continuing, the employer must engage the bedrijfsarts to produce a probleemanalyse (problem analysis) within approximately six weeks of the first sick day. The analysis sets out the employee’s functional limitations and possibilities, the prognosis and advice on reintegration. The employer uses this medical input, with appropriate employee consent and confidentiality, to shape the Plan van Aanpak. Adapt work where the analysis indicates it is possible, and record the clinical advice in the dossier.

5. Step 4, Prepare the Plan van Aanpak (within ~8 weeks)

   Within approximately eight weeks of the first sick day, the employer and employee must jointly draft a Plan van Aanpak (Plan of Approach) based on the problem analysis. The plan should set out the reintegration goal (return to own role, a modified role, or another role), concrete actions and responsibilities, a timetable, review moments and the name of the case manager coordinating the process. Both parties sign it, and it is updated as circumstances change. A missing or superficial Plan van Aanpak is the single most common reason the UWV finds employer efforts inadequate.

6. Step 5, Implement reintegration actions and record progress (weeks 8–42)

   This is the active phase. Implement the agreed measures: phased return to work, modified duties, workplace adjustments, retraining, or, where return to the original employer is not feasible, reintegration with a different employer (the so-called “second track” or tweede spoor). Review progress at regular intervals, typically every six weeks, and record each meeting in a dated contact report. Where progress stalls, the employer must escalate: revisit the bedrijfsarts, revise the Plan van Aanpak and consider external reintegration services. Around week 42, the employer notifies the UWV of long-term sickness, and a first-year evaluation is carried out jointly with the employee.

   The evidential value of this phase lies entirely in the completeness of the contact reports; gaps here are difficult to repair later.

7. Step 6, Second-year obligations and WIA preparation (after 52 weeks)

   At the end of the first year, the employer and employee complete a first-year evaluation (eerstejaarsevaluatie) and reassess the reintegration direction. The wage-continuation duty continues into the second year. Reintegration efforts must be sustained, with continued exploration of both the first and second tracks. The employer should brief the employee on the forthcoming WIA assessment and keep the dossier current, because the quality of the second-year file contributes significantly to how the UWV judges the employer’s overall efforts.

8. Step 7, Reporting to UWV and finalising the employer dossier (before 104 weeks)

   Ahead of the two-year mark, the employer completes a final reintegration evaluation (eindevaluatie) and compiles the complete reintegration dossier for the UWV, which the employee submits with any WIA application. The dossier must demonstrate that the employer took all reasonable reintegration steps. If the UWV finds the efforts inadequate, it can impose a loonsanctie, an obligation to continue paying wages for up to a further year, before the WIA claim is assessed. This sanction makes the quality of the dossier a direct financial risk.

Step / Who / Duration timeline table

Required documents and templates

A defensible reintegration file is a documentary exercise. Meeting your sick leave obligations Netherlands wide means not only acting correctly but proving you did so. The following documents are mandatory or strongly recommended, and most should be retained within a single, indexed reintegration dossier.

Mandatory documents for compliance

Recommended templates

Maintain standard templates for the Plan van Aanpak, the problem analysis cover sheet, contact reports, periodic reintegration progress reports and a dossier index. Consistent templates reduce the risk of missing a mandatory element and make the file easier for a UWV assessor to follow. A well-structured dossier index that cross-references each document to its date is itself persuasive evidence of diligence.

Timeline and deadlines

The sick leave obligations Netherlands law imposes are governed by fixed milestones. Missing them is the fastest route to an adverse UWV finding.

Key statutory deadlines

• First days of absence: first contact and absence record.
• From day 1: continued wage payment at a minimum of 70%.
• Around week 6: bedrijfsarts problem analysis.
• Around week 8: Plan van Aanpak drafted and signed.
• Approximately every 6 weeks: progress reviews and updated contact reports.
• Around weeks 42–52: long-term notification to UWV and first-year evaluation.
• Around week 93: WIA application submitted; final dossier compiled before 104 weeks.

When the authorities may intervene

The UWV focuses on employers whose files show structural failings: no Plan van Aanpak, no bedrijfsarts involvement, missing contact reports, inconsistent payroll records or late UWV reporting. An inadequate dossier presented at the WIA stage can lead the UWV to impose a wage sanction of up to a further year of payment. Where health-and-safety or systemic sickness-management failings are identified, the Netherlands Labour Authority (Nederlandse Arbeidsinspectie) can open an administrative enforcement process in its own right.

Costs, penalties and fees

Meeting your sick leave obligations Netherlands wide carries direct and indirect costs, but the cost of non-compliance is typically far higher. The table below sets out the main cost elements. Figures are indicative only and vary by provider and case.

Direct employer costs

Potential enforcement penalties and indirect costs

The most significant financial exposure is the UWV wage sanction for inadequate reintegration efforts, which can extend wage payment by up to a further twelve months. Beyond that, employers face potential compensation claims where reintegration was mishandled, administrative penalties where the Netherlands Labour Authority identifies breaches, and reputational damage. The economics strongly favour early, documented compliance over remedial action after an adverse assessment.

What changes in 2026, new rules, guidance and enforcement focus

For 2026, the clearest emphasis is on consistent application of the established Gatekeeper framework rather than a wholesale rewrite of it. Employers should treat the year as a prompt to audit existing practice against the established statutory milestones. Where specific legislative changes are under discussion or in progress, employers should confirm the current position with official sources before relying on any particular reform.

2026 enforcement priorities

Practitioners generally expect continued regulatory focus on the quality and completeness of reintegration dossiers, on genuine bedrijfsarts involvement, and on the consistency of wage-continuation records. The likely practical effect is that superficial, box-ticking Plans van Aanpak will attract closer scrutiny at the WIA stage, and that employers with thin documentation will find wage sanctions harder to avoid.

Immediate remedial actions, a 30-day checklist

• Audit open cases. Check every current absence against the 6-week and 8-week milestones.
• Review templates. Confirm your Plan van Aanpak and contact-report templates capture all mandatory elements.
• Verify payroll. Reconcile continued-payment percentages against each CAO and contract.
• Confirm bedrijfsarts arrangements. Ensure assessments are being requested and recorded on time.
• Train HR and line managers. Refresh understanding of early-contact and documentation duties.
• Index dossiers. Make sure each file is complete and retrievable for UWV review.

Common pitfalls and how to avoid them

The failures that most often undermine sick leave obligations Netherlands employers must meet are procedural and documentary rather than medical. Avoiding them is largely a matter of discipline.

• No Plan van Aanpak, or a late one. Draft and sign it within eight weeks; diarise the deadline from day one of absence.
• No bedrijfsarts involvement. Engage occupational health early and record the problem analysis, do not rely on line-manager impressions of the employee’s health.
• Inadequate documentation. Keep dated, signed contact reports throughout; a long gap is read as inaction.
• Late UWV reporting. Notify long-term sickness and finalise the dossier before the statutory points; do not leave the file until the WIA deadline.
• Inconsistent payroll records. Apply the correct continued-payment percentage consistently and document any CAO uplift.
• Treating long-term sickness like short-term absence. Mobilise the full Gatekeeper track as soon as the absence looks set to continue.

As practical guidance, contact reports should record the date, who was present, what was discussed, what was agreed and the next review date, short factual entries, free of medical diagnosis, create the strongest evidential record.

Roles and responsibilities at a glance

Conclusion and next steps

The sick leave obligations Netherlands employers must manage are demanding but predictable: they turn on fixed milestones, genuine occupational-health involvement, and a complete, well-indexed dossier. The employers who meet them with the least risk in 2026 are those who prepare templates in advance, act within the six-week and eight-week windows, document every contact, and audit open cases now against heightened enforcement expectations. Treating the reintegration dossier as a live evidential record, rather than a file assembled at the WIA deadline, is the single most effective protection against wage sanctions and penalties.

This guide provides practical compliance steps rather than bespoke legal advice; where a specific case raises difficult questions, particularly around dismissal, second-track placement or a disputed UWV finding, obtain tailored professional advice.

Sources

1. Rijksoverheid, Ziekte en arbeidsongeschiktheid
2. UWV, Ziekteverzuim en re-integratie (werkgevers)
3. Nederlandse Arbeidsinspectie (Netherlands Labour Authority)
4. Wetten.overheid.nl, Wet verbetering poortwachter and Burgerlijk Wetboek Book 7
5. Rechtspraak.nl, published judgments
6. Nederlandse Orde van Advocaten