Protection covers employment only
Temporary protection lets you work without a TWV only in employment (loondienst). The employer must notify UWV at least 2 working days before the start.
Sources: rijksoverheid.nl, uwv.nl
Zzp and Ukrainians with temporary protection: what is and is not allowed
In short: with temporary protection you may work without a work permit only in employment (loondienst). As a zzp'er, in practice no. Below: why, what comes next, and what we offer.
As of 07.11.2026Sources are at the bottom of the page. We update it every time the rules change.
In short: who may work as a zzp'er
| Your status | May you work as a zzp'er? | For whom | Note |
|---|---|---|---|
| EU, EEA or Swiss passport | Yes | For any client | A genuine assignment, Wet DBA: see the check below. |
| Permanent residence or a residence permit marked “arbeid vrij toegestaan” | Yes | For any client | Check the wording on your IND card. |
| Residence permit “arbeid als zelfstandige” | Yes | For any client | A separate IND permit; hard to get. |
| Temporary protection (RTB) | Effectively no | Only if the client obtains a TWV (work permit) for each assignment. | In construction, hospitality, agriculture and personal services such applications are rejected. Registering with the KvK does not change this. Sources: kvk.nl, refugeehelp.nl |
Why this is so
Every assignment needs a TWV
To work as a zzp'er, the client must obtain a TWV for every single assignment. In construction, hospitality, agriculture and personal services such applications are rejected: always, according to KvK, and about 99% of them according to RefugeeHelp.
Sources: kvk.nl, refugeehelp.nl
The government chose not to relax the rules
In January 2025 the Dutch cabinet decided not to relax these rules.
Sources: abu.nl
The client gets the fine
Wav fines (Wet arbeid vreemdelingen) have fallen on the client since 1 February 2025: per person and along the whole chain of contractors. Companies: €6,000 (up to €11,250 with aggravating circumstances), sole proprietors €3,000, private persons €1,500. That is why careful clients will not take you on as a zzp'er without a TWV.
Sources: awvn.nl, kroesadvocaten.nl
A contract for services, a KvK number or a DBA check does not replace the TWV. If someone offers you to “register as a zzp'er”, ask whether the client has obtained a TWV and check ind.nl and refugeehelp.nl.
What happens after 4 March 2028
Temporary protection is extended to 4 March 2028. After that the government is preparing a “transitiedocument”, but that is an intention only. What is known today:
5 August 2026Temporary protection has been extended until 4 March 2028 (IND, as of 07.11.2026). For anyone applying after 5.08.2026 an extra condition applies — see IND. Sources: ind.nl
25 September 2026The government is preparing a transitiedocument as a safety net for the period after 4 March 2028 (government letter of 25.09.2026). The details have not been decided. Sources: open.overheid.nl
After 4 March 2028Working in employment (loondienst) will remain possible. Permission to work as a zzp'er is only “being studied” by the government: the letter of 25.09.2026 calls it an intention. That is not law and not a decision, so do not build plans on it. Sources: open.overheid.nl
We will update this page when an official decision is published.
What Razom offers instead of zzp
Two legal routes. Both are free for you.
Employment in a Razom crew
Razom is a contractor with its own crews. You work under an employment contract (loondienst) per the collective agreement (cao), led by a foreman. Always 0 EUR for job seekers (Waadi, art. 3).
Join a crewA job with a Dutch employer
Recruitment and selection (W&S): you hire directly and we find and vet the candidate. The employer pays for the recruitment only at the start date, at a published fee. It costs you nothing.
How it worksAre you a client?
You buy a result at a fixed price, not hours. Our crews are employed, so the TWV question for zzp'ers does not arise.
For clientsSteps, DBA check and templates for people with free access
For people with free access to the labour market
EU passport or permanent residence. 10 steps to your first invoice.This section is only for people with an EU/EEA/Swiss passport, permanent residence, or a permit marked “arbeid vrij toegestaan” or “arbeid als zelfstandige”. With temporary protection it is not a route to zzp.
A genuine contract or disguised employment?
Three Wet DBA questions. Answer honestly about one specific assignment.Is there a clearly defined result (scope, deadline, acceptance)?
Did you set the price and give the estimate yourself?
Your own tools, your own schedule, no daily instructions from the client?
Answer the three questions and the result will appear here.
Looks like a genuine contractResult, your own price and independence: the three main signs are there. Put them in the contract.
More likely a contract, but there is a weak spotOne of the signs is missing. Fix it in the agreement, otherwise the Belastingdienst may reclassify the relationship.
There are signs of disguised employmentDo not sign a contracting agreement for this work. The right form is an employment contract: write to us and we will arrange it.
10 steps to your first invoice
Check your status and prepare your documents
You can work as a zzp'er only with an EU/EEA/Swiss passport, permanent residence, or a permit marked “arbeid vrij toegestaan” or “arbeid als zelfstandige”. Temporary protection is not included (see the table above). You need a valid document and a BSN; check the conditions on ind.nl.
Name, activities, address
Choose a name (your own name is fine), your activities by SBI code, and a mailing address. Do not promise in the description what you cannot do: clients read it.
Registration at the KvK: €85.15
Prepare the registration on kvk.nl and confirm your identity at the KvK. The one-off fee is €85.15 (amount as of 20.10.2026; the current amount is on kvk.nl). After registering you receive a KvK number.
VAT number and the KOR decision
After registration the Belastingdienst sends you a VAT number automatically. If your turnover stays under €20,000 a year you can choose the KOR (kleineondernemersregeling, VAT exemption). It affects your prices and invoices, so think about it beforehand.
A separate business account
For an eenmanszaak a separate account is not required by law, but it makes bookkeeping easier and keeps private and business money apart. We recommend receiving payment for assignments only on it.
Insurance (AVB, AOV)
Clients often ask for liability insurance (AVB). An AOV (disability insurance) is voluntary: as a zzp'er you get no sick pay from an employer. More below. Compare offers from several insurers.
Hours and invoices
Record your hours: tax deductions rely on the urencriterium of 1,225 hours a year. An invoice must show the mandatory details (name, address, KvK number, VAT id, invoice number and date, description, amount and VAT if you charge it). Keep your records for 7 years.
Taxes
If you are not on the KOR you file a VAT return (usually quarterly). Once a year comes income tax. The zelfstandigenaftrek (self-employed deduction) is €1,200 for 2026 (2027: €900) and falls every year. Work out with a bookkeeper how much to set aside: this is not tax advice.
A contract for every assignment
Put every assignment in its own contract: result, price, deadline, your own materials and tools, right of substitution. Templates are below; have an accountant check them before use.
Your first client and first invoice
Find your first clients through your own network and other contractors. Run the DBA check before every assignment. After handover, send an invoice with all mandatory details, agree a payment term and keep a copy.
DBA check: genuine contract or disguised employment?
The check is only for people with free access to the labour market. It does not replace a TWV and does not make zzp work lawful under temporary protection.
Since 1 January 2025 the Belastingdienst again enforces against false self-employment (Wet DBA). Three signs of employment: the client directs you daily (gezag), you are embedded in its team like an employee, and you carry no entrepreneurial risk.
| Aspect | Genuine contract | Employment |
|---|---|---|
| Result | A fixed result | Hours, "being there" |
| Price | Own quote | Hourly rate set by the client |
| Tools | Own tools and materials | Provided by the client |
| Scheduling | You decide | Client's schedule |
| Substitution | A substitute is allowed | Personal work only |
| Risk | Yours: warranty, illness | Carried by the client |
| Clients | Several | One, for months |
| Duration | Limited, per result | Open-ended or "another month" |
If the client directs you daily, supplies the tools and pays by the hour, that is employment: you are entitled to an employment contract, collective agreement and sick pay. Do not sign a “contract for services” for that kind of work.
From 2026: vergrijpboetes of 10–100 % of the additional assessment for intent or gross negligence. Sources: pwc.nl, mkbservicedesk.nl
Result and explanation after eight questions, with a PDF summary. No name, no registration.
Rate and the rechtsvermoeden
From 31.12.2026 the rechtsvermoeden applies: below the threshold rate an employment contract is presumed. The 2026 threshold: €38 per hour (€36 in the text of the law, indexed every year). Your zzp rate must be clearly above it.
The law was published in the Staatsblad on 29.06.2026. A rate alone is not enough: you need a genuine contract for work, your own tools and your own clients. Sources: zzpnieuws.nl
Insurance: AVB and AOV
An AVB covers damage you cause to the client or to third parties. Many clients require it before work starts.
An AOV insures your income if you cannot work. It is voluntary; without it, illness means no income.
Templates and checklist
Free and without registration. These are drafts: have an accountant or lawyer check them before use.
Contract for services (opdrachtovereenkomst)
draft: have it checked
Invoice (factuur)
draft: have it checked
Hours log
draft: have it checked
Frequently asked questions
May I work as a zzp'er with temporary protection (RTB)?
Only if the client obtains a TWV for each assignment. In construction, hospitality, agriculture and personal services such applications are rejected, so in practice no.
Sources: kvk.nl, refugeehelp.nl
Can I work in employment instead?
Yes. With temporary protection you may work without a TWV in employment (loondienst). The employer notifies UWV at least 2 working days before the start.
Sources: rijksoverheid.nl, uwv.nl
What happens after 4 March 2028?
The government is preparing a transitiedocument; details have not been decided. Employment will remain possible. Permission for zzp is “being studied”: that is an intention, not law. We will update the page when a decision is published.
Sources: open.overheid.nl
Does a contract for services or a KvK number help?
No. For someone with temporary protection the client needs a TWV for each assignment, and neither a contract, a KvK registration nor a DBA check replaces it.
I have an EU passport or permanent residence. Where do I start?
You may work as a zzp'er. Follow the 10 steps above, run the DBA check before every assignment and download the templates. Subcontracting for Razom is possible only on genuine terms.
What does it cost me at Razom?
0 EUR. Razom does not charge job seekers or employees: not for placement, not for “membership”, not for a course in advance (Waadi, art. 3).
Sources: wetten.overheid.nl
Sources and disclaimer
This is general information, not legal or tax advice. Legal statements are current as of 07.11.2026. Amounts (KvK fee, KOR, urencriterium, zelfstandigenaftrek) are given as of 20.10.2026. Rules change: check the official sites. Official sources: kvk.nl · uwv.nl · ind.nl · refugeehelp.nl · ondernemersplein.overheid.nl- IND — Richtlijn Tijdelijke Bescherming verlengd tot en met 4 maart 2028
- KvK — Oekraïense vluchteling inschrijven bij KVK (TWV, sectoren)
- Rijksoverheid — Werk en inkomen voor vluchtelingen uit Oekraïne
- RefugeeHelp — Voorwaarden om je eigen bedrijf te beginnen
- Belastingdienst — Arbeidsrelaties en handhaving (Wet DBA)
- Nederlandse Arbeidsinspectie — Wet arbeid vreemdelingen