The Renseigneringsverplichting (UBD reporting obligation)

As of January 1, 2022, the renseigneringsverplichting applies. This means that intermediaries or freelance platforms must share payment information about third parties with the Dutch Tax Authorities (Belastingdienst). Several rules (and exceptions) apply to this obligation.

By complying, you can avoid fines.

The renseigneringsverplichting applies to all entrepreneurs, foundations, and associations that pay third parties, such as freelancers who work without registration or VAT numbers and have formally applied for this arrangement.

A New Format

You may know the renseigneringsverplichting as the IB-47 declaration, but this is not the same. The IB-47 was discontinued in 2018 due to privacy regulations. There is now a new legal basis for processing the social security number (BSN), and the renseigneringsverplichting was reintroduced in 2022.

What is the Renseigneringsverplichting?

It obliges you to report to the Belastingdienst when you pay someone for services or work, including in-kind rewards. You need to provide specific details about the payments made.

The Belastingdienst uses this information to pre-fill income tax returns for those required to file.

Does This Apply to Your Business?

The obligation applies if you are required to keep records (required to maintain financial records). If you pay a natural person (like a freelancer) for services, you must report this payment to the Belastingdienst. For intermediaries and platforms, this obligation applies to the end client. They pay the individual without a VAT number and are not responsible for wage taxes. An intermediary or platform can submit the report on behalf of the client, depending on the setup of the platform.

For any specific questions about how the renseigneringsverplichting applies to your platform or intermediary business, feel free to contact us for further assistance.

What Information Must Be Provided?

If you are administratieplichtig, you need to submit the following details to the Belastingdienst about the recipient of the payment:

• Name

• Address

• Date of birth

• BSN (Social Security Number)

You also need to specify the amounts paid in a calendar year, including in-kind payments and expense reimbursements, with the exact date of the payments.

How Should You Submit the Information?

You have three ways to submit the data:

1. Web Form – For individual payments, use the web form in the Belastingdienst's data portal. This is best for occasional payments but can be time-consuming for multiple transactions.

2. UBD Template – Use the UBD template to submit details for multiple payments in one batch.

3. XML Data File – For larger numbers of payments, using an XML file is the most efficient, especially for intermediaries or freelance platforms. Since January 2023, you can submit the data via Digipoort, which requires a PKIoverheid server certificate. This method is most suitable for high-volume platforms but comes with a cost of up to €599 for three years.

Important Deadlines

You must submit the payment data for 2023 to the Belastingdienst no later than January 31, 2024. This includes all payments made to third parties in 2023.

Tip: Prepare your data in advance to avoid a rush in January.

Consequences for Non-Compliance

Failure to submit the required information on time, correctly, or completely can result in a fine of up to €9,000 or even six months imprisonment. If it is determined that you intentionally withheld information, the fine could rise to €22,500 or the amount of unpaid taxes, whichever is higher.