According to Statistics Netherlands (in Dutch), sickness absence in the first quarter of 2025 stood at 5.8 per cent, meaning 58 out of every thousand working days were lost to illness. Within that, long-term absence, where an employee is away for six weeks or more, remains a stubborn problem. And it is precisely for those long cases that a legal framework exists which everyone knows by name but whose content is far from always clear: the Gatekeeper Improvement Act (Wet verbetering poortwachter).
According to Arboportaal (in Dutch), the Act was introduced with the aim of getting employees who are ill back to work as soon as possible, on the basis that acting quickly and effectively shortens absence. The Act requires employer and employee, together with the occupational physician, to make an effort towards reintegration. That sounds logical, but in practice employers and HR professionals regularly run into uncertainty: which step follows when, who is responsible for what, and what happens if you miss a deadline?
In this article we set out step by step how the Act works, which obligations apply to employer and employee alike, and where most mistakes are made. That way you know exactly where you stand, and how to keep your organisation in control of the reintegration process.
What is the Gatekeeper Improvement Act?
The Act came into force on 1 April 2002. The reason was concrete: the intake into the disability benefit system of the time had grown explosively, and employees who were ill for a long period ended up on a disability benefit automatically, without serious attempts having been made to keep them at work. The Act was meant to change that. Arboportaal describes the Act (in Dutch) as a set of rules employers and employees must follow during long-term sickness absence, especially in the first year.
The heart of the Act is simple: employer and employee are jointly responsible for reintegration. Waiting is not an option. Both parties have to take demonstrable action, take documented steps and record those steps at set moments. After two years of illness, UWV tests whether all the obligations have been met. If they have not, sanctions follow.
The steps of the Act in order
The process runs from the first day of illness to a maximum of 104 weeks. Below are the most important moments and what is expected of you in each phase.
Week 1: sickness report and first contact
As soon as an employee reports sick, the clock officially starts running. The first day of illness is the starting point for all the deadlines that follow, so correct registration matters straight away. As an employer you report the employee to the occupational physician or health service as quickly as possible. Personal contact with the employee belongs here too: not to check up, but to show involvement and get a sense of the situation.
Week 6: problem analysis by the occupational physician
By week six at the latest, the employee sees the occupational physician for a problem analysis. The physician maps the medical limitations, what the employee can still do and which reintegration possibilities exist. This document is the medical basis for everything that follows. UWV stresses (in Dutch) that the physician draws up the problem analysis together with the employee, and that this conversation forms the basis for the intended reintegration route.
Week 8: action plan
Within two weeks of the problem analysis, so by week eight at the latest, employer and employee draw up an action plan together. In it you record the reintegration goals, the concrete steps to be taken and who does what. The plan is a living document: it is reviewed every six weeks and adjusted where needed. A missing or demonstrably incomplete action plan is one of the most common reasons for a wage sanction later on.
Week 42: notification to UWV
In week 42 you as the employer are required to report the long-term illness to UWV. This is an administrative step that many employers forget or carry out too late. The notification is not optional: UWV uses this information to follow the rest of the process. A missed or late notification counts towards the final assessment.
Week 52: first-year evaluation
After a year of illness you review the reintegration process together with the employee. What has been achieved? What is going well and what has to change? At the same time, from this moment on you are required to adjust the work, the workplace or the equipment if that is needed for the employee to return. If reintegration within your own company does not work, you have to look actively for possibilities outside the organisation: the second track.
First and second track: what is the difference?
Reintegration runs along two routes. The first track is aimed at a return to the current employer, possibly in an adjusted or different role. The second track is started when it becomes clear that a return to the current employer is no longer realistic. That often happens between weeks 30 and 52, on the physician's advice. Both tracks can also run at the same time. Waiting to start the second track is a common mistake that can weigh heavily in UWV's assessment later.
Weeks 87 to 93: reintegration report and WIA application
Between weeks 87 and 93 you draw up a reintegration report together with the employee and the physician. This report contains a complete overview of the process: all the steps, documents, evaluations and agreements. It accompanies the WIA application that the employee submits to UWV by week 93 at the latest. On the basis of this report, UWV tests whether employer and employee have made enough effort.
The employee's obligations
A common misunderstanding is that the Gatekeeper Improvement Act is mainly an employer's Act. That is not so. The employee has clear duties too. They are required to cooperate with the reintegration process: to be available for conversations with the occupational physician, to keep to agreements and to accept reasonably offered suitable work. If an employee refuses to cooperate without good reason, the employer can stop paying wages. If there are differences of opinion about the reintegration, either party can request an expert opinion from UWV.
What happens if you do not comply?
The Act has teeth. As an employer you are required to keep paying at least 70 per cent of the wage for up to 104 weeks. If you do not meet the obligations under the Act, UWV can impose a wage sanction: you are then required to keep paying wages for up to a year longer. For employees the consequences are concrete too: their benefit can be reduced or they can even lose their right to a WIA benefit.
Practical tips for getting through the process well
- Always register the first day of illness immediately and correctly, because every deadline runs from it.
- Bring the occupational physician in early, preferably in the first week.
- Keep all documents, notes of conversations and evaluations in a reintegration file.
- Put the review moments in the diary in advance, so that deadlines are not missed.
- Start the second track on time, even if you still hope for recovery through the first.
- In case of disagreement, request an expert opinion from UWV in good time rather than waiting.
A well-organised process gives both employer and employee clarity and something to hold on to, precisely in a period that is demanding for everyone.
The occupational physician as the pivot
The occupational physician is not a neutral outsider but an active partner in the reintegration process. The physician assesses what the employee can bear, advises on possibilities and limitations, and records findings in the problem analysis and the reintegration report. At Dokter Beter we work closely with employers and employees to guide this process from start to finish: from the first problem analysis to drawing up the reintegration report. That keeps the deadlines safe and puts the employee at the centre of recovery.
Acting in time when someone is absent does not only prevent a wage sanction; it gives the employee a real chance to recover.
The Gatekeeper Improvement Act is not a bureaucratic hurdle but a structured framework that gives employer and employee something to hold on to together during long-term absence. Knowing the steps and acting in time prevents sanctions and, at least as valuable, improves the chance of a lasting return to work.
Key takeaways
- The Act applies from the first day of illness and places obligations on employer and employee alike.
- The occupational physician draws up a problem analysis by week six at the latest: that document is the medical basis for the whole process.
- By week eight at the latest, employer and employee draw up an action plan together, which is reviewed every six weeks.
- In week 42 you are required to report the long-term illness to UWV, a step that is often overlooked.
- Second-track reintegration has to be started in good time when a return to the current employer is not feasible.
- Failing to meet the obligations risks a wage sanction: up to a year of extra wage payment.
- A good occupational physician is not an administrative obligation but a valuable partner who watches over the substance of the process.
Questions about a running reintegration process, or want to know what Dokter Beter could do for you as an employer or employee? Get in touch. We are happy to think along, from the first sickness report through to the reintegration report.