As a recognized sponsor, you are legally required to maintain specific records relating to each foreign national you sponsor. These records form part of your sponsor compliance obligations and may be reviewed by the Immigration and Naturalization Service (IND) at any time.
From January 1, 2026, this obligation will be expanded. Recognized sponsors will be required to retain additional documentation demonstrating that sponsored employees have actually received their salary. This requirement applies for highly skilled migrants and EU Blue Card holders. Sponsors must retain evidence of this, such as:
- A copy of a business bank account or other similar supporting document, including but not limited to a batch payment statement, showing that the wages have been credited to a bank account in the name of the foreign national, intended for electronic payment.
These documents must clearly show that the salary was credited to a payment account in the employee’s name and that the payment was made via non-cash transfer. Previously, the record-keeping obligation was limited to retaining payslips of the employees. However, payslips alone do not prove that salary payments were actually made. This amendment closes that gap by requiring verifiable proof of the actual payment of salary to the employees.
Please ensure that your records for highly skilled migrants and EU Blue Card holders are up to date and include proof that salary payments have been made. If the IND requests this information during a compliance check, audit, or residence permit-related procedure, it must be readily available.
If you have any questions or would like assistance in assessing how these changes affect your organization, please do not hesitate to contact us or call the phone number +31 (0) 85 – 620 4900.
