The Netherlands is one of Europe’s most active destinations for international talent, and the Highly Skilled Migrant (HSM) scheme — known in Dutch as the kennismigrantenregeling — is the main route employers use to bring non-EU professionals into the country. It is a well-established, employer-driven system, which is both its strength and its challenge: the company, not the employee, carries most of the responsibility.
That responsibility is growing. Salary thresholds are indexed every January, record-keeping requirements were tightened for 2026, and the IND (the Dutch Immigration and Naturalisation Service) is increasingly data-driven in how it supervises sponsors. For employers, understanding the HSM scheme is no longer just about getting a permit approved — it is about staying compliant for as long as the employee is on your payroll. This guide covers what employers need to know, from becoming a recognised sponsor to ongoing obligations.
1. What Is the Highly Skilled Migrant Scheme?
The HSM permit is a temporary residence permit that allows a non-EU/EEA/Swiss national to live and work in the Netherlands for a specific employer. Key features, according to the IND:
- Only an employer recognised by the IND can apply for the permit on the employee’s behalf, and the employer must be listed in the IND’s public register of recognised sponsors.
- The employee needs an employment contract with that employer (or with a research institution in the Netherlands).
- The salary must meet the legal minimum for the year and be in line with the market rate — meaning comparable to what people in the same job earn on average.
- The permit runs for the length of the contract or job, up to a maximum of five years.
The scheme is closely related to — but separate from — the EU Blue Card, which also exists in the Netherlands and has its own salary thresholds. Employers hiring senior or highly qualified talent should compare both routes.
2. Step One: Become a Recognised Sponsor
A company that wants to hire through the HSM scheme must first be recognised by the IND as a sponsor. Without this status, it cannot file the application. A few points matter here:
- The IND lists a legal decision period of three months for an application for recognition as a sponsor, so employers should apply well before the intended start date of the first hire.
- According to Grant Thornton’s summary of the 2026 IND fees, the recognised sponsorship application costs €2,539 for employers with fewer than 50 employees and €5,080 for employers with 50 or more. (Other sources quote different figures, so always confirm the current fee with the IND.)
- Companies that are not recognised sponsors and do not want to apply themselves can use an Employer of Record or payroll provider that already holds sponsor status — though this changes who carries the legal obligations and should be considered carefully.
Recognition is not just a formality. It brings continuing legal obligations, which are covered in section 6.
3. 2026 Salary Thresholds
Salary is the single most common reason HSM applications fail or create compliance problems. The IND adjusts the required amounts every 1 January, and the amount that applies is the one on the application date or, when changing employers, the one on the date the new contract starts. The 2026 required gross monthly amounts for the HSM scheme are:
- Age 30 or older: €5,942 per month.
- Under age 30: €4,357 per month.
- Reduced salary criterion (recent graduates and orientation year): €3,122 per month. This applies when the application is made during an orientation-year permit, or within three years of graduation, a doctoral defence, or the expiry of a research permit.
- EU Blue Card: €5,942 per month, or €4,754 under the reduced criterion for recent graduates.
A few details employers often miss about what counts toward the threshold:
- The amounts are gross monthly salary excluding the holiday allowance — the vacation allowance does not count toward the criterion.
- Payments in kind and uncertain pay, such as overtime, tips, and similar variable elements, do not count.
- Fixed allowances can count if they are written into the contract and paid monthly into the employee’s own bank account; a thirteenth month counts only if paid in twelve equal instalments.
- The criterion must be met continuously, not just at the moment of application. A salary that was sufficient in December can fall short in January if it is not updated.
4. The Application Process,
Step 1 — Prepare the contract and documents
Before filing, make sure the employment contract clearly states the salary (meeting the 2026 threshold), the role, and the start date. Typical supporting documents include a copy of the employee’s passport, the signed contract, and the declarations required by the IND forms.
Step 2 — Check whether an MVV is needed
Most non-EU nationals need a provisional residence permit (MVV) to enter the Netherlands for a long stay, although nationals of some countries are exempt. When an MVV applies, it is generally handled together with the residence permit in a single application submitted by the employer, which avoids avoidable delays.
Step 3 — File the application online
Applications are submitted by the recognised sponsor through the IND’s Business Portal, which requires DigiD with SMS verification and iDEAL for payment. The IND notes that some forms may occasionally be unavailable online due to technical issues, in which case written applications by post are also possible. According to Grant Thornton’s summary of 2026 IND fees, the application fee for an HSM, EU Blue Card, or ICT permit is €423, and €254 for a family-based dependent permit — confirm current fees with the IND before budgeting.
Step 4 — Wait for the IND decision
The IND lists a legal decision period of 90 days for an HSM application, counted from the day it receives the application. For initial work-related permits, the IND can extend this by 30 days and must explain the reason. In practice, complete applications from recognised sponsors are often decided faster, but employers should plan around the legal period rather than the best case. For a change of employer where the current permit is HSM, the IND has 45 days to decide.
Step 5 — After approval: entry, registration, and the residence card
Once approved, the employee travels (with the MVV where required), registers with the local municipality, and collects the residence card at an IND desk after the biometric steps. Municipal registration is also what leads to the BSN (the Dutch citizen service number), which unlocks banking, healthcare, and payroll — so employers should schedule these steps into onboarding so the start date is not delayed.
5. Family Members and Partner Work Rights
One of the strongest selling points of the HSM scheme for candidates is how it treats the family. Spouses and registered partners can apply for a dependent residence permit, and partners of HSM permit holders generally have unrestricted access to the Dutch labour market without a separate work permit. Family permit applications are filed on a separate form and carry their own fee, so it is usually simplest and fastest to plan them together with the employee’s own application.
For dual-career households, clear communication on this point can make the difference between a candidate accepting an offer or declining it — and, once they have moved, between a family that settles and one that struggles.
6. Ongoing Obligations: What Employers Must Do After Approval
This is the part of the HSM scheme that creates the most exposure for employers. According to the IND, a recognised sponsor has an information obligation, an administrative obligation, and a duty of care, and failing to meet them can result in an administrative fine. In practice:
- Information obligation: relevant changes must be reported to the IND within a statutory period, commonly four weeks. “Relevant changes” is interpreted broadly and can include salary reductions (even temporary ones), a move from full-time to part-time, role changes, corporate restructuring, and the end of employment.
- Administrative obligation: a complete, accurate file must be kept for each sponsored employee — typically for up to five years after employment ends — including identity documents, contracts and amendments, and evidence of salary and reporting. From 1 January 2026, sponsors must also keep bank statements showing that salaries were actually paid. The IND can request them to verify salary compliance, and sponsors who cannot produce them in an audit may be sanctioned.
- Duty of care: sponsors must perform basic due diligence, give employees accurate information about their residence conditions and reporting obligations (ideally during onboarding), and may be liable for certain repatriation costs for a period after employment ends.
Supervision is also becoming more data-driven. The IND may compare the immigration file against payroll data, tax filings, and working-time records, and inconsistencies can be treated as red flags. Consequences range from administrative fines to formal warnings and, in the most serious cases, suspension or withdrawal of sponsor recognition — which blocks new hires under the scheme and creates uncertainty for existing employees.
7. Changing Employers, Job Loss, and Renewals
- Change of employer: a new employer must be a recognised sponsor and a fresh notification or application is required. The 2026 salary threshold on the new contract’s start date applies.
- Job loss: for permit holders whose permit has run for two years or more, and whose unemployment began on or after 22 May 2026, the IND allows a job-search period of up to six months. Otherwise it is up to three months. The period cannot exceed the permit’s remaining validity.
- Renewals: start the extension process well before expiry, and re-check that the employee’s salary still meets the threshold for the year of the extension.
8. Practical Tips for Employers
- Apply for recognised sponsor status before you need it, since the process takes time and cannot be rushed once a candidate has accepted an offer.
- Build the threshold check into your payroll calendar every January, so no sponsored employee falls below the new minimum by accident.
- Keep a single, organized digital file per sponsored employee, including salary bank statements, and review it at least annually.
- Brief new hires during onboarding about their residence conditions, so they understand the information and reporting duties on both sides.
- Treat the 30% ruling as a separate workstream. It is handled by the Dutch tax authority rather than the IND, has its own eligibility rules and income threshold, and does not apply automatically.
- Run a periodic internal immigration audit covering file completeness, salary thresholds, timeliness of reporting, and governance — especially where payroll or secondment arrangements involve more than one entity.
Common Pitfalls to Avoid
- Offering a salary that is only just above the threshold and forgetting that the minimum is indexed every January.
- Counting the holiday allowance, overtime, or other variable pay toward the minimum salary criterion.
- Starting the HSM process before the company is a recognised sponsor.
- Missing the reporting deadline for changes such as salary adjustments, working-hours changes, or the end of employment.
- Failing to keep salary bank statements and payslips for the required period.
- Assuming the 30% ruling will apply automatically alongside the permit.
- Treating the permit approval as the finish line rather than the start of ongoing sponsor obligations.
How Eres Legal Helps
The HSM scheme rewards employers who are prepared and penalizes those who are not. Eres Legal supports companies through the entire process: assessing whether a candidate qualifies and which route fits best, guiding recognised sponsor applications, preparing and filing HSM and family permit applications, and setting up the internal processes that keep sponsors compliant — from annual threshold reviews to record-keeping and reporting. Combined with Eres Relocation’s on-the-ground settling-in support, employers can bring international talent into the Netherlands with confidence from the first offer to the first year and beyond.
Planning to hire a highly skilled migrant in the Netherlands? Contact Eres Legal to build a compliant, well-timed sponsorship and application plan.
Disclaimer: This article is provided for general informational purposes only and does not constitute legal, tax, or immigration advice. Salary thresholds, fees, decision periods, and sponsor obligations in the Netherlands are updated regularly and may not reflect the most current figures. For guidance specific to your organization’s or employee’s situation, please consult a qualified immigration lawyer or contact us directly.



