The recent post from Bart Maes marks an important development in the field of intra-EU service provision. The Dutch Immigration and Naturalization Service (IND) has effectively reduced its legal charges for residence permit applications for Third-Country Nationals from €405,00 to €81,00.

This is good news: lower administrative barriers make compliance more accessible. Yet, the ruling also casts a sharper light on a deeper structural issue within the Dutch labour market: one that CIS has been monitoring closely.

Thousands of Third-Country Nationals (TCNs) currently operate in Netherlands under intra-EU service arrangements. They hold valid work permits but often lack the required residence permits after 90 days. While the Court of Justice confirmed that such a permit is mandatory beyond that threshold, enforcement in practice remains inconsistent. Certification bodies like SNA, through the NEN 4400-2 standard, check only for work permits and not for verblijfsvergunningen, creating a systemic blind spot.

The result?

Workers may be legally employed but illegally residing.
Certified companies may (un)knowingly breach immigration law.
Advisors face an ethical dilemma: encourage compliance and lose clients, or look away to stay competitive.
Compliant firms are priced out by those exploiting this loophole.

While the reduced fees are a step forward, the underlying compliance challenge remains. Unless residence status checks become a core requirement of certification and audit processes, the Dutch system risks institutionalizing illegality under the banner of “self-regulation.”

At CIS, we welcome this cost reduction, but call for a broader rethink: fair competition and legal compliance must go hand in hand. Certification should guarantee integrity, not just appearance.