SNA Certification Mark: Knowledge Document for the Organisation

Introduction

This document is the foundation for helping employees get up to speed on the SNA certification mark (Stichting Normering Arbeid / Labour Standards Foundation): what it is, why it matters for our work, and which requirements come with it. It is intended as a reference and training resource — not as the full legal standard. If you are unsure about a specific situation, consult the standard itself or the inspection body.

After going through this document you will be able to:

• explain what the SNA certification mark is and why it exists;
• name the main components of an SNA inspection;
• recognise the key risks (hiring-in percentages, false self-employment, non-conformities);
• know what happens when a deviation is found.

A glossary is included at the end of this document. The accompanying knowledge test lets you check whether you have mastered the material.

Our situation: all entities of HeadFirst Group are SNA-certified. This means every entity is periodically inspected against the requirements in this document, and that clients can verify this for each entity in the public Labour Standards Register.

1. What is the SNA certification mark?

The SNA certification mark is a private quality mark that demonstrates a company operates in line with laws and regulations on wages, tax, and identification of personnel. It is based on the standard NEN 4400-1 (and NEN 4400-2 for foreign-based companies), supplemented by the SNA standard for Intermediary Services for Self-Employed Professionals (zzp).

• The standard was developed in 2006 together with sector and industry associations (including ABU, NBBU, Schoonmakend Nederland, LTO, COV, and Bouwend Nederland).
• The standard is managed by the Stichting Normering Arbeid (SNA).
• Certified companies are listed in the public Labour Standards Register (Register Normering Arbeid, www.normeringarbeid.nl). Anyone — including (potential) clients — can check there whether a company is certified.

Why does this certification mark exist?

The certification mark gives clients assurance that they will not be confronted with:

• Chain liability — the risk for companies that have work carried out through a contract for services or a contract of assignment.
• Hirer's liability — the risk for companies that hire in personnel from third parties.

Both forms of liability can result in a client still having to pay tax or social security contributions if the other party fails to do so (properly) itself. In short, the SNA certification mark is a form of risk management.

Revision of the standard

Since February 2023, the standard (NEN 4400-1:2022/2023) has been revised:

• A more risk-based approach through procedures and the so-called 4-O methodology (see Chapter 4).
• Structured into 3 modules: General, Making labour available, Contracting of work.
• Revised inspection method, statistical basis, and weighting of standard requirements.

2. How does an SNA inspection work?

Who carries out the inspection?

Not SNA itself, but an independent, accredited inspection body (in our documents: Bureau Cicero). SNA manages the standard and the register; the inspection body verifies whether a company actually complies with it.

Two types of inspections

• Full inspection — a broad assessment of all elements of the standard.
• Follow-up inspection — more targeted, based on the outcome and risk profile of the previous inspection.

How is compliance assessed?

The inspector draws a sample from the personnel, payroll, and financial administration and assesses it against the standard. Ahead of an inspection, a fixed set of documents must be ready (think of trade register extracts, payslips, blocked-account [G-account] statements, and agreements with self-employed professionals and suppliers).

How often are inspections carried out?

Frequency is determined on a risk basis:

• Risk-increasing factors (e.g. a payment arrangement with the Tax Authority) can lead to inspections every quarter.
• Frequency-reducing conditions (a demonstrable low-risk track record plus internal control measures) can lower the frequency instead.

What does an inspection produce?

• An inspection summary report (summary of findings).
• An inspection report (detailed findings).
• An assessment letter (whether the company remains in the register, and when the next inspection will take place) — sent to both the company and SNA.

3. What happens when a deviation is found?

There are three possible outcomes after an inspection:

• Compliant → the company remains/is entered in the register.
• Non-conformity — Minor → a smaller deviation. There is a remediation period of 3 months, or until the next regular audit (this depends on the weighting of the specific requirement). If not remediated in time, it automatically becomes a major.
• Non-conformity — Major → a larger deviation. This leads to suspension of registration, unless:
  • the company responds within 10 days to the draft report, and
  • corrective measures are taken within 30 days.

A suspension is visible in the public register — this can directly affect the trust of (potential) clients.

4. Remediating deviations: the 4-O methodology

When a deviation is found, it must be remediated — including, where relevant, retroactive correction. This follows a fixed, four-step methodology:

1. Cause — what caused the error to occur? Analyse and describe this.
2. Scope — is the deviation incidental or structural? Does it affect part of the sample, or the entire population?
3. Solution — how was the deviation remediated, including any retroactive correction? This must be demonstrated, not merely claimed.
4. Operationality — what measures have been taken to prevent recurrence, and how has this been made demonstrable?

This methodology exists to prevent a deviation from being resolved only "on paper" without the underlying process actually improving.

5. The main standard requirements

Identification of the company

• Correct trade register (KvK) registration (directors, stated business purpose, WAADI registration where applicable).
• Correct disclosure of group/corporate relationships.
• Payroll tax number, VAT number, and a mandatory G-account (blocked bank account).
• A quarterly statement of good payment behaviour, and the most recent annual accounts.
• An obligation to report investigations or legal proceedings by government or enforcement bodies within 2 weeks.

Personnel and payroll administration

• Identity verification (for non-Dutch nationals: confirmation of the right to work).
• A written, sufficiently detailed employment contract.
• No "all-in wage": the payslip must be itemised and holiday entitlements must be reserved.
• Hours registration that reconciles with the payroll administration: hours worked = hours paid = hours disbursed = hours invoiced (with the exception of contracting of work).
• A 7-year record-keeping obligation.

Financial administration

• Complete and timely payment of payroll tax, social security contributions, and VAT.
• Correct invoices (in line with the VAT Act).
• Correct use of the G-account.

Hiring in from third parties

This is one of the highest-risk areas, with hard percentage limits:

• When hiring from a non-SNA-certified party: a maximum of 5% of own revenue per supplier, and a maximum of 25% in total.
• 55% of the invoice amount (or 40% where VAT is reverse-charged) must be paid into the G-account of that non-certified party.
• When hiring from a certified party, these percentages do not apply, but adequate ID verification remains mandatory.

Self-employed professionals (zzp'ers)

There are two routes, each with its own requirements:

• Intermediation — the company acts as intermediary between the client and the self-employed professional; a model agreement approved by the Tax Authority is required, and invoicing is done recognisably on behalf of the self-employed professional.
• Intervention (tussenkomst) — the self-employed professional carries out work or an assignment independently; here too an approved model agreement is required, along with ID verification, an "entrepreneur check," and a trade register check. In this case, the self-employed professional invoices the company directly.

False self-employment is the biggest risk here: if the practical reality (e.g. mandatory attendance, direct supervision, a single fixed client) resembles an employment relationship more than genuine independent entrepreneurship, this creates a tax and legal risk — separate from the SNA certification mark. Indicators of genuine independence include: working for multiple clients, using one's own equipment, bearing financial risk, and the ability to be substituted by another suitably qualified professional.

Collective labour agreement (CAO) compliance

When the ABU or NBBU collective labour agreement applies, checks include: participation in a pension fund and social fund, a correctly structured payslip, correct accrual/use of holiday entitlements and holiday allowance, and timely implementation of CAO wage increases. For the Meat Sector CAO, similar but stricter requirements apply, where failure to demonstrably pay pension contributions leads directly to a targeted inspection.

6. Why this matters to us

• We are certified ourselves: all entities of HeadFirst Group are SNA-certified and are periodically inspected against the requirements in this document. This is not theory — it is the practice we operate in as an organisation.
• Liability risk: if we or our partners fail to meet the requirements, we (or our clients) could still be held liable for unpaid tax or contributions.
• Reputation: the register is public. A suspension is visible to everyone — including for each individual entity of HeadFirst Group.
• Client trust: clients deliberately choose certified parties to limit their own risk, and actively check this in the register.
• Speed of escalation: with a "major" non-conformity there is very little time (10 + 30 days) to respond — the sooner this is known within the organisation, the faster action can be taken.

7. Glossary

Further information

For the full, current standard and interpretations: SNA's Handbook of Standards (Handboek Normen, www.normeringarbeid.nl). For practical preparation ahead of an inspection: the NEN 4400-1 Checklist. If in doubt about a specific situation: consult the inspection body or the internal process owner.