Skip to Content

Business advicehealthcare and wellbeing

Wtza licence since 2025: needed from your first employee or hired freelancer?

If you work alone, you register. If you have care provided by someone else, you become an institution and need an admission licence for Zvw and Wlz care. This shows you where the line is.

8 min read

Yes, in most cases. Since 1 January 2025 every care provider that provides or has others provide care under the Health Insurance Act (Zvw) or the Long-term Care Act (Wlz) needs an admission licence, even with fewer than eleven care providers. Only the freelancer in a sole proprietorship who provides all care personally registers and does not need a licence.

The Wtza is the Care Providers Admission Act. It regulates who must register before care starts, and who needs a licence. The CIBG, an executive agency of the Ministry of Health, Welfare and Sport, implements the act.

In short

  • Register: every care provider before care starts, including the freelancer. Licence: every institution that provides or has others provide Zvw or Wlz care or medical specialist care.
  • You are an institution as soon as you have care provided by someone else, or if you are a legal entity, such as a private limited company. According to the CIBG, a legal entity can never be a freelancer.
  • The application costs € 725 and the decision period is in principle 8 weeks. Providing care without a licence can lead to a fine of up to € 87,000.

In this article

  1. What changed on 1 January 2025?
  2. When are you an institution and no longer a freelancer?
  3. For which care does an institution need a licence?
  4. What must you arrange before you start providing care?
  5. Which requirements must you meet?
  6. What happens if you provide care without a licence?
  7. What should you watch out for when you grow or move to a company?

What changed on 1 January 2025?

The licensing requirement was extended to small care providers. The CIBG writes that since that date the licensing requirement also applies to care providers that provide care under the Zvw or the Wlz with fewer than 11 care providers. Sole practitioners, freelancers and subcontractors remained excluded (CIBG, Amendment of the Wtza from 1 January 2025, 30 December 2024).

Providers who were already giving care before 2025 and became subject to the licensing requirement through the change automatically received a licence by operation of law, without an application. They must still meet all the requirements of the licence (CIBG, All about the licensing requirement). A new provider must apply for the licence itself.

When are you an institution and no longer a freelancer?

As soon as you have care provided by someone else, or if you are a legal entity. The act defines an institution as a legal entity that provides or has others provide care on a business basis, and a natural person who has others provide care on a business basis. A sole practitioner is someone who provides care professionally and does not work as an employee of, or on assignment for, an institution (Wtza, article 1).

The CIBG puts it like this: a freelancer is one person who carries out the actual care personally, and a legal entity can never be a freelancer (CIBG, Information for freelancers). The page on exceptions states that sole practitioners do not need to apply for a licence, except if it is a legal entity, for example a private limited company (CIBG, Exceptions to the licensing requirement).

In practice this means the following. If, as a sole proprietor, you employ one care provider, or hire a freelancer who gives care to your clients, you have care provided by others. By definition you are then an institution. If you work alone, but through your own private limited company, you are also an institution.

You are going to provide careOnly Wmo care?no Zvw, Wlz or youth careNo registration neededmunicipal requirements applyyesnoAlone, as a sole trader?no care provided by othersRegister, no licencesole practitioneryesnoZvw, Wlz or specialist care?you are an institutionRegister and licenceapplication € 725, 8 weeksyesno, e.g. youth care onlyRegister onlyno licenceA company is always an institution,even if you work in it alone.
Registration or licence under the Wtza. Simplified from the Wtza (articles 1, 2 and 4), the Wtza Implementing Decree and the CIBG pages. If in doubt, use the CIBG licensing check.

For which care does an institution need a licence?

For care under the Health Insurance Act or the Long-term Care Act, and for medical specialist care (Wtza, article 4(1)). Think of district nursing, physiotherapy covered by basic insurance, mental health treatment or Wlz care at home.

If you provide only Wmo care or only youth care, you do not need to apply for a licence (CIBG, All about the licensing requirement). Also exempt are providers that only supply aids, arrange transport, clean homes or supply movable facilities (Wtza Implementing Decree, article 3).

Subcontractors are in principle exempt. That does not apply to an empty shell: a provider that gives no care itself and has all care done by a subcontractor. Then both the main contractor and the subcontractor need a licence (CIBG, All about the licensing requirement). A main contractor must also record in a written agreement how the subcontractor safeguards the quality of care (CIBG, Questions about the licensing requirement).

An agency that only matches supply and demand is not a care provider. If the agency itself concludes an agreement with a personal budget holder or health insurer to provide care, arranges replacement during illness and makes agreements on the content of the care, it is a care provider and needs a licence (CIBG, Questions about the licensing requirement).

What must you arrange before you start providing care?

Register first, and as an institution also obtain the licence. The registration requirement applies to every care provider: care may only start after you have registered with the minister (Wtza, article 2). You do this in the Care Providers Portal, after which the Health and Youth Care Inspectorate knows you exist (KVK, Starting as a freelance nurse or care worker, updated 15 September 2026).

You apply for the licence online. You need eHerkenning at level 2+ or higher, your KVK number and the (draft) articles of association. Processing costs € 725 and only starts once that payment has been received. The decision period is in principle 8 weeks and can be extended once. The CIBG can ask for a Certificate of Conduct or start a Bibob integrity screening (CIBG, Applying for a licence).

1. RegisterCare Providers Portalbefore the first client2. ApplyeHerkenning 2+, articlespay € 725 up front3. Assessmentin principle 8 weekspossibly VOG or Bibob4. Licencestart Zvw or Wlz carekeep meeting the rules
From plan to licence. Amounts and periods: CIBG, Applying for a licence. If the CIBG asks for additional documents, the decision period is suspended until you supply them.

Which requirements must you meet?

The CIBG refuses the licence if it is not plausible that you meet a set of requirements. These include good care and a quality system under the Wkkgz, transparent financial management under the Healthcare Market Regulation Act (article 40a) and correct billing (article 35) (Wtza, article 5(2)).

The requirement of transparent financial management means in practice: recording in writing who has which financial tasks, separating care activities financially from other activities, and making every receipt and payment traceable to source and destination. These requirements do not apply to freelancers (CIBG, Financial management and derivatives).

An internal supervisory body, such as a supervisory board of at least three people, is not needed for institutions that normally work with ten or fewer care providers. Institutions without accommodation with normally fifty or fewer care providers do not need one either, unless they provide medical specialist care or personal care, support or nursing (Wtza Implementing Decree, articles 5 and 6).

What happens if you provide care without a licence?

Then you are breaking the law and risk a fine and an order subject to a penalty. According to the CIBG, the Inspectorate can use an order subject to a penalty to force an institution to apply for a licence after all, and impose a fine of up to € 87,000 if the institution provided care without a licence (CIBG, Questions about the licensing requirement).

Your turnover is also at risk. Health insurers and care offices can make the licence a condition for paying claims. They cannot require a licence if the Wtza does not require one from you (CIBG, Questions about the licensing requirement).

What should you watch out for when you grow or move to a company?

Plan the licence before the first employee or the first hired care provider starts. With a decision period of 8 weeks and possible questions from the CIBG, the application may take longer than recruiting a colleague.

Take extra care with a new legal form. If the switch gives you a different KVK number, as with the move from sole proprietorship to private limited company, you must in any case apply for a new licence (CIBG, Questions about the licensing requirement). Include that in the planning of the conversion. The tax side of that step is covered in a separate article (Converting a sole proprietorship into a company).

The rules on who may enter the care market help shape what that market looks like. Research on commercial nursing homes in the Netherlands showed that changes in the rules made the growth of that sector possible, together with access to capital from private investors (Bos, Kruse & Jeurissen, 2020). The wider licensing requirement is one of the ways the government now wants more control over new providers.

Sources

  • Care Providers Admission Act (Wtza), articles 1, 2, 4 and 5, version 5 July 2025, read via the BWB repository (in Dutch). wetten.overheid.nl
  • Wtza Implementing Decree, articles 3, 5 and 6, version 1 July 2026 (in Dutch). wetten.overheid.nl
  • CIBG, Amendment of the Wtza from 1 January 2025: licence by operation of law, 30 December 2024 (in Dutch). toetredingzorgaanbieders.nl
  • CIBG, All about the licensing requirement (in Dutch), accessed 1 November 2026. toetredingzorgaanbieders.nl
  • CIBG, Exceptions to the licensing requirement (in Dutch), accessed 1 November 2026. toetredingzorgaanbieders.nl
  • CIBG, Information for freelancers (in Dutch), accessed 1 November 2026. toetredingzorgaanbieders.nl
  • CIBG, Applying for a licence (in Dutch), accessed 1 November 2026. toetredingzorgaanbieders.nl
  • CIBG, Questions about the licensing requirement (in Dutch), accessed 1 November 2026. toetredingzorgaanbieders.nl
  • CIBG, Financial management and derivatives (in Dutch), accessed 1 November 2026. toetredingzorgaanbieders.nl
  • KVK, Starting as a freelance nurse or care worker, updated 15 September 2026 (in Dutch). kvk.nl
  • Bos, A., Kruse, F.M. & Jeurissen, P. (2020). For-profit nursing homes in the Netherlands: what factors explain their rise? International Journal of Health Services, 50(4), 431-443. doi.org

This article belongs to

Business advice

Growth, acquisitions, succession and the choices that shape your business.

Would you like to know what we do in this area for your business?

View the service More for your sector Request an introductory meeting

Further reading

All articles

Business advicemedical specialists

An entrepreneur in the MSB: what are real and substantial risks?

With integrated funding, medical specialists lost their own billing right in 2015, and with it, in principle, their status as entrepreneurs for tax purposes. Remaining an entrepreneur is only possible with real and substantial risks, such as investing in equipment, employing staff or other financial risks. The overall picture counts. Without entrepreneur status, the self-employed deduction and the SME profit exemption are lost.

7 min read

Business adviceallied health practices

From sole proprietorship to practice bv: new KVK number, new licence

A physiotherapist with a sole proprietorship and no staff does not need a licence. A practice bv does, even if you work alone, because a legal entity can never be a freelancer. If the bv gets a new KVK number, you must apply for a new licence and a new AGB code. The bv must also publish an annual accountability report every year. For tax purposes you can convert without settling, but you get a customary salary of at least € 58,000 and a different pension build-up.

7 min read

Shall we meet?

Tell us about your business. We deliberately work with a limited number of clients. That is why we first look together at whether we are a good fit.

Request an introductory meeting