Absence Registration: Employer Obligations Explained

Absence Registration: What Are Your Obligations as an Employer?

Not legal advice — consult an employment law specialist or adviser for guidance tailored to your situation.

Every employer faces it at some point: a sick employee. But do you know exactly what you must record and when? The Wet verbetering poortwachter (Dutch Gatekeeper Act) sets requirements for absence registration. Failure to comply risks a wage sanction from the UWV (Employee Insurance Agency). This article explains what you must do, which steps are required and when, and how to keep your records in order without the hassle.

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What Does the Gatekeeper Act Require?

The Gatekeeper Act is the legal framework governing how employers and employees cooperate to prevent long-term absenteeism. The goal is straightforward: get sick employees back to work as quickly and responsibly as possible.

The law requires you to record every sick report immediately — not next week, not when you find a moment: right away. From that point, a fixed timeline of obligations begins:

Moment	Obligation
Day 1 of sick report	Register absence, engage occupational health service or company doctor
By week 6	Company doctor draws up problem analysis
After problem analysis	Draw up reintegration plan together with employee
Ongoing	Record progress in absence file
Week 42	Report sick employee to UWV
Week 87	Prepare reintegration report for WIA application

You must be able to demonstrate each of these steps in writing. Missing documentation can lead the UWV to conclude you have done insufficient work, resulting in a wage sanction of up to 52 additional weeks of salary payments.

Want an overview of your broader employer obligations? Read what payroll compliance rules mean for you in 2026.

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What Exactly Must You Record?

Imagine you run a small IT firm with five employees. One calls in sick on Monday morning. You note the date, inform your occupational health service, and log it in your system. Clear enough — but what comes next?

A complete absence file should contain at minimum:

• The date of the first sick report
• Contact and follow-up moments with the employee
• The problem analysis from the company doctor (by week 6)
• The reintegration plan, including goals and review dates
• Periodic updates to the plan as the situation changes
• Correspondence with the UWV once the absence reaches 42 weeks

Many SME employers store this information in scattered emails or a spreadsheet. That works — until the UWV requests the full file and you spend an evening hunting for documents from 18 months ago. Read more about the limitations of spreadsheets in Excel vs. time tracking software: which is right for you?

Employers in the construction sector face additional sector-specific CBA requirements. See Construction CBA Time Tracking: What You Must Log.

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Absence and Attendance: Two Sides of the Same Coin

Absence registration does not exist in isolation. Tracking when employees are present helps you spot patterns earlier — such as frequent short-term absences or difficulty returning to work. That enables timely intervention, which is precisely what the Gatekeeper Act aims to achieve.

Modern software combines attendance and absence management in a single overview. At a glance you can see:

• Who was present on which day
• When a sick report started and how long it has been running
• Which steps in the Gatekeeper process have been completed

Try PrikKlokPlus for free and discover how to track attendance and hours in one clear system.

For hybrid or flexible teams, a calendar view is particularly useful. Learn how it works in the Feature spotlight: Hour logging & calendar view.

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What Are the Risks of Poor Absence Records?

The consequences of poor record-keeping are concrete.

If the UWV concludes during the WIA assessment that you have not met your reintegration obligations, it can require you to continue paying salary for up to 52 additional weeks. This applies regardless of whether the employee is actually incapacitated.

In employment disputes or dismissal proceedings, a complete absence file is your most important line of defence. Missing documentation leaves you exposed.

Without structured recording, you miss patterns. Short-term absences that go unnoticed over time can result in higher costs than those identified and addressed promptly.

If you also work with freelancers alongside your employees, it is worth reading about Dutch DBA Act 2026: protect yourself from sham self-employment — a separate but equally serious risk.

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Wrapping Up

Absence registration is not a bureaucratic afterthought. It is a legal obligation with direct financial consequences if you cut corners. The Gatekeeper Act requires structured, demonstrable recording of every absence: from the first sick report to the reintegration file. Keep your records complete, monitor your deadlines, and maintain an organised administration, because the UWV will ask for it sooner or later.

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Frequently Asked Questions About Absence Registration

Must I always report a sick employee to the occupational health service immediately? Yes. Under the Gatekeeper Act, you are required to contact your occupational health service or company doctor at every sick report. The sooner this happens, the better you can guide the reintegration process.

What happens if I miss the week 6 problem analysis? The company doctor is responsible for producing the analysis, but you are required to facilitate and organise it on time. Missing this step without valid reason can be flagged as a shortcoming during the WIA assessment, leading to a wage sanction. Consult an employment law specialist for advice specific to your situation.

Does the Gatekeeper Act apply to small employers with only one or two employees? Yes. The law applies to all employers with staff on a contract of employment, regardless of company size. The obligations are identical whether you employ one person or one hundred.

How long must I keep an absence file? There is no specific retention period under the Gatekeeper Act, but it is prudent to keep files for at least two years after the absence ends — especially if a WIA application was submitted or an employment dispute occurred. Consult an adviser for guidance on your specific circumstances.

Can I keep absence records in a plain text file or spreadsheet? This is legally permitted, but risky in practice. Without automated deadline reminders and a clear log, it is easy to miss steps or lose documents. Dedicated software significantly reduces that risk.

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