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When Sickness Files Become the Gatekeeper for Dutch Employers

A sickness file now shapes payment timing, privacy and reintegration for own-risk employers.

Most sickness files begin quietly. A worker reports ill, the roster shifts, payroll is told, and the company doctor is involved. At first, that feels manageable in a small business. The problem starts when the story must stand on its own. In Dutch sickness files, the record must carry the case without the owner beside it. That makes Dutch sickness files a record of trust, timing and reintegration, not only an HR note.

When the record carries the case

On 1 May 2026, UWV started a temporary route for Eerstejaars Ziektewetbeoordelingen for employers that are eigenrisicodrager for the Ziektewet. UWV will do 3,400 of these assessments from 1 May to 31 December 2026. The first phase runs through Acture, HCS and Robidus. In Dutch sickness files, the absence note, company-doctor route, payment timing and UWV step must tell one story.

The selection rule matters. Private executors submit files where the worker has a high chance of leaving the Ziektewet. UWV says this should use scarce assessment capacity better. It should also reduce later WIA applications and WIA assessments. Still, that is triage, not a faster lane for every ERD-ZW employer.

The one-year file becomes a control point

UWV says WIA and Wajong claim assessments keep priority. Those decisions determine benefit entitlement and income security. The first-year Ziektewet assessment sits inside a system under pressure, not beside it.

The pressure is clear in UWV's 2025 figures. It received 96,700 WIA applications, up from 93,100 in 2024. It performed 74,500 WIA claim assessments, down from 83,700. At year-end, 26,700 WIA clients had waited more than eight weeks for a claim assessment. Also, 7,900 had waited more than six months.

The government said in December 2025 that UWV expected 40,000 more socio-medical assessment requests in 2026 than it could assess. That is the setting for the temporary ERD-ZW route. For a small employer, delay is now part of the environment. It is not an odd exception.

Payment pressure meets privacy

For HR, the one-year sickness point changes meaning. It is not the day to discover whether the file is ready. Instead, it is the day when the file should already be complete. Sickness date, earlier sickness periods, recovery reports and benefit calculation need to line up. So do paid periods, reintegration steps and UWV requests.

Outsourcing does not move responsibility

UWV guidance is clear. An ERD-ZW employer remains responsible even when execution is outsourced. That matters more than many contracts suggest. A private executor, insurer, payroll provider or occupational health service may do the work. Still, the employer needs to know who holds each part of the record.

This is especially relevant for flexible labour. UWV's premium material for 2026 says the expected share of ERD-ZW in total wage sum was 70 percent in the temporary agency sector in 2025. In other companies, it was 49 percent. UWV also names coordination with PPUSZ, ABU and NBBU around the temporary route.

The point goes beyond staffing agencies. Hospitality, logistics, cleaning, retail and care-related support services often run on changing rosters, short contracts and outsourced administration. In those businesses, absence can look like a staffing problem. Yet it may already be becoming a file problem. The roster shows who is missing. The control file shows whether the employer can defend the next decision.

An ERD-ZW employer pays the Ziektewet benefit when the rules place that responsibility with the employer. That also covers former workers in relevant cases. In addition, UWV says the employer and worker are jointly responsible for reintegration. So the file is not a dead archive. It is the record of active handling.

Privacy and proof have to live together

In a constrained system, the temptation is to collect more information. However, that is not always lawful or useful. UWV says the employer, company doctor or occupational health service may not share medical data without the worker's consent. So the file has to be strong without becoming medically intrusive. That is why Dutch sickness files depend on reintegration records, lawful decisions and payroll timing that can survive review.

The employer needs operational facts. These include dates, reports received, decisions requested, payments made, role allocations, reintegration actions and communication trails. Meanwhile, medical content belongs in the proper professional channel. Good control separates those worlds. Otherwise, weak control mixes them, or leaves both incomplete.

The assessment itself has a direct financial consequence. UWV assesses work possibilities and earning capacity. If the UWV doctor assesses that the former worker can perform their own work, the benefit stops about one day later. If the labour expert assesses earning capacity above 65 percent of the previous wage, the benefit stops about one month after the assessment.

What employers should keep readable

That 65 percent point is where the human record, payroll record and reintegration record meet. A complete file will not decide the medical outcome by itself. However, it can make the process clearer. By contrast, a confused file often leaves cost, uncertainty and correspondence behind it.

The ledger sits inside HR

Own-risk bearing is often discussed as a premium question. UWV says the average Ziektewet premium for 2026 rises from 0.50 percent to 0.56 percent. It also says the average WGA premium rises from 0.83 percent to 0.96 percent. For own-risk bearers, the public differentiated premium is nil for the relevant risk. Yet the risk does not disappear.

Instead, it moves into payments, private cover, executor fees, file handling and cash-flow timing. For a small company, one long sickness case can affect liquidity, management time and planning confidence. If the assessment is delayed, the exposure continues. The same applies if payment cannot yet stop.

There is also a calendar point. Belastingdienst material says ERD-ZW can start on 1 January or 1 July. The application and declaration must arrive 13 weeks before the start date. In practice, that puts the own-risk decision inside the payroll calendar. It does not sit outside it. Governance, HR and finance should share the choice.

The practical response is not dramatic. It is a calmer file habit. Choose one current sickness case. Then ask whether an outsider could reconstruct what happened without calling the owner. Who reported what, and when? Which decision was requested from UWV? What payments were made? Which supplier holds each document? Where is medical information kept, and who may see it?

That question respects both sides of the employment relationship. The worker needs clarity and privacy. The employer needs lawful decisions and a reliable financial view. Meanwhile, UWV needs a file that can be assessed within a scarce system. None of this requires panic. Instead, it requires clean boundaries and a record that does not depend on memory.

The new UWV route is small in number, with only 3,400 assessments over eight months. Still, it is large in meaning. It shows that public assessment capacity is being directed to the files most likely to move. For Dutch employers carrying Ziektewet risk, the message is plain. The sickness file is no longer a back-office folder. Instead, it is the gatekeeper to cash-flow control, supplier accountability and lawful HR decisions.

Editorial standard

The Polder is written for readers who need the Dutch business environment translated into practical meaning. Corrections, source policy and editorial accountability are part of the publication record.

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