The IND will add stricter administrative duties on 1 January 2026. Every recognised sponsor must keep proof that each highly skilled migrant or Blue Card holder received their salary in an account under their own name.
IND Compliance: What is now required
From 2026, pay slips alone are not enough. Sponsors must store documents that show the actual transfer of money. Examples include:
- Statements from the company business bank account
- Overviews of batch payments
These documents must show that the salary reached the employee’s own account.
Why does this duty expand compliance
The IND had a gap in its enforcement. There was no legal base to demand insight into salary payments if an employer refused to share it. The new rule closes that gap. From 1 January 2026, the IND can ask for proof of payment during an audit and expect direct access to the records.
What changes for recognised sponsors
Most companies already keep proof of salary payments within their finance systems. Many will only need small updates. What matters is traceability.
Payments must be easy to link to each employee during an IND check. The rule does not force companies to store proof of payment inside every personal file. It only expects clear and complete records on request.
Other duties that still apply
Recognised Sponsors must already follow several rules to stay compliant. They must report changes in an employee’s situation. This includes contract termination and any leave that brings the salary below the required threshold. A move of the company must also be reported within two weeks.i
Sponsors must also keep core documents. This includes a copy of the passport, the antecedents certificate, and the employment contract. For Blue Card holders, sponsors must show that the employee meets the required qualifications.
They also have a duty of care. They must recruit with care and give correct information to the employee. The IND can hold an employer responsible for the departure of a foreign national.
A Practical Next Step
Do not wait for an inspection to test your compliance.
Ensure that your batch payment overviews or bank statements clearly display the beneficiary’s name and account number.
If your current reporting is vague or aggregated, update your settings now. Establishing clear traceability today safeguards your status as a recognised sponsor tomorrow.
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