Custom software for the duty of inspection on foreign hiring
The notification duty lies with the foreign service provider, but the risk of a fine also lies with you. As the Dutch client, you must check whether the notification is correct and report any inaccuracies within five days of the work starting. This is an obligation regarding information you do not fill in yourself and must obtain from a third party.
Why you are liable for someone else's form
The Dutch Posting of Workers in the EU Act requires foreign service providers from the EU, the EEA and Switzerland to submit a notification via the Dutch online reporting portal before the work begins. It states who will be working, where, when and for which client.
What is often overlooked is the second obligation. The Dutch recipient of services must check that notification for accuracy and completeness, and report any inaccuracies within five days of the work starting. If you do not, you risk a fine yourself, even though you did not make the notification and did not enter the details.
That is where the practical problem lies. The details come from your subcontractor, who enters them into a portal you cannot see, and the clock starts running the moment the work begins. For one project that is a single task; for dozens of projects with changing crews, it is administration that nobody keeps up with until an inspection arrives.
How we build this
The project, with its start date, is the unit here. If the notification and the check are tied to it, the five-day deadline becomes a signal rather than a risk.
Which foreign parties work for you, on which projects, and who is your point of contact for each project. In most companies this is found in procurement contracts rather than in one overview.
The service provider submits its notification details through a portal, rather than by email with a screenshot. What arrives in a structured form can be checked; a PDF cannot.
As soon as a project starts, your deadline begins. The system warns you in advance, not on the day itself, because an inaccuracy still needs to be reportable.
We take a project from last quarter and check whether you can demonstrate that you verified it. Whatever is missing then would also be missing in a real inspection.
What the software actually does
The register of projects and their foreign parties carries everything. Which components you need depends on how many chains you have and how deep they run.
Register of projects and foreign parties
For each project, which service providers are working there, from when, and with which people. Without that overview, the duty to check is an obligation with no subject.
Portal for the service provider
Your subcontractor submits its notification details in a structured form rather than as a screenshot in an email. This lets you check for content, not merely for presence.
Checking accuracy and completeness
Are the named persons, the period and the activities consistent with what is actually happening? The system records your check with date and person, because that record is your evidence.
Monitoring the five-day deadline
From the start date of the work, your deadline runs for reporting inaccuracies. The system gives advance notice, so there is still time to have the service provider correct them.
Inaccuracies with follow-up
A person who is present but was not notified, a period that does not match. Each of these becomes an action with an owner and a deadline, because an identified inaccuracy without follow-up weighs against you in an inspection.
Evidence kept per project
Which notification was in place, what you checked, when, and with what outcome. In an inspection, what matters is not the notification but what you did with it.
Who we build for
The depth of your chain determines how much work this is. Four situations.
Construction and civil engineering
Chains of several layers deep, with crews rotating weekly. Here the problem is not the notification but keeping track of who is actually on site today; you do that with the gate app.
Food production and agriculture
Seasonal peaks with large numbers at once. The notification is often correct at the start and then falls out of step, because people join who were not on the original list.
Logistics and transport
Drivers and loading crews who come in short, repeated stints. The question of whether there is secondment and when the clock starts is hardest here, and it is your lawyer who answers that, not your system.
Installation and maintenance
Specialised fitters who come in for a short job. Small numbers, many projects, and precisely because of that, administration that quickly falls behind. If you work with hired-in staff through an agency, this touches your agency software.
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The reporting portal (meldloket) is a government service, not a system you can simply connect to. We therefore build your own register and the portal leading to it, and take changes to the procedure into account.
Why Appfront
The risk sits with you, the input with someone else
That is why we build the portal through which your service provider submits information, so you can check the content rather than wonder whether anything arrived at all.
The clock starts when the work begins
Not when the notification is made and not when the invoice arrives. We therefore tie the deadline to the project's start date and send reminders well in advance.
Your project administration already exists
Projects, suppliers and start dates are already recorded. We connect to them through integrations rather than letting a second list emerge.
Your evidence is the check, not the notification
We record what you checked, when, and what followed from it. That is what an inspector asks for and what an email thread does not provide.
Security and privacy
This file contains personal data of people who are not employed by you: names, nationalities, periods of residence and sometimes identity details. You process that because of a legal obligation, not because it is convenient, which means you must not record more than the inspection requires. We therefore set a retention period for each data type and show a project manager only the people on their own project.
The portal side calls for its own considerations. Your subcontractor supplies data about their staff into your system, and they must be able to trust that other parties cannot see it. In the portal, a service provider therefore sees only their own submissions. On the evidence side, your check must be recorded in a way that cannot be altered; a compliance statement that can be updated after the fact is no evidence at an inspection. Our own approach to security is set out in our information security policy; reports from outside come through our vulnerability disclosure policy.
Frequently asked questions about the WagwEU checking obligation
Because, alongside the reporting obligation, the law imposes a checking obligation that rests with you. You must verify that the notification from your foreign service provider is correct and complete, and report any inaccuracies within five days of the work starting. If you fail to do so, you can be fined yourself, even if you did not fill in the form.
At the start of the work, not when the notification is made or when you receive the invoice. That is why we tie the deadline to the project's start date. When work precisely begins in cases of short-term or repeated deployment is a legal question you should align with your own adviser.
The A1 certificate concerns social security: the country in which someone is insured. The reporting obligation concerns terms of employment and who is working where. They often come together in the same files, but they are separate obligations with their own rules; the registration side of that is covered under A1 and reporting obligation registration.
The reporting portal (meldloket) is a government service that you cannot simply plug into. What we build is your own register plus a portal through which your service provider submits its reporting data in a structured way. The available integration options change over time, so we assess them at the time of building.
The duty of care applies to the service provider you have the contract with. In practice, further parties work beneath them, and the question then becomes who reports to whom. That is a contractual matter you settle in advance; we build the system so you can record multiple layers if your contracts require it.
That is precisely the situation the duty of care exists for. It becomes a deviation with an owner and a deadline, and you pass it on within your five-day window. Recording that moment matters more than the finding itself, because it shows you have carried out your duty.
That is exactly when it pays off. On one large project, someone remembers; across dozens of small projects with varying start dates, it becomes impossible to oversee and only surfaces during an inspection. The system is also lighter in that situation, as you mainly need deadline tracking and less chain registration.
That depends on the number of projects and parties, whether the portal is needed and whether it must be integrated with your project administration. The register with deadline tracking is usually quick to put into use and removes the immediate risk; the portal costs more. We give a reasoned estimate after the discovery phase.
Making the duty of care demonstrable?
Take a project from last quarter involving foreign labour hire and try to show that you checked the notification. If that takes more than a few minutes, that is where the work lies. We build this as a standalone application and as part of a broader custom software engagement.