Netherlands Highly Skilled Migrant Visa: Top Rejection Reasons and How to Avoid Them

Why HSM applications get rejected

The Netherlands Highly Skilled Migrant (Kennismigrant) scheme has a high approval rate — but rejections do happen, and they are almost always preventable. The IND Annual Report 2024 notes increased enforcement and more penalties issued to sponsors. Understanding the common pitfalls can save months of delay and thousands of euros.

1. Salary below the IND threshold

This is the single most common rejection reason — and it is non-negotiable. The IND applies a strict salary floor with zero discretion. If the gross monthly salary is even €1 below the threshold, the application is automatically refused.

2026 salary thresholds (January–June)

Category	Monthly gross (excl. 8% holiday allowance)
Age 30 and older	€5,688
Under age 30	€4,171
Reduced criterion (scientific researchers, university lecturers, doctors in training)	€2,801

How to avoid it: Verify the salary against the current IND thresholds before filing. The thresholds are updated every January and July — always check the latest figures.

Official source: IND — Highly Skilled Migrant requirements

2. Salary not adjusted for annual indexation

A less obvious but equally fatal mistake: the employer sets the correct salary at application time, but fails to increase it when the IND updates thresholds mid-year. The IND can — and does — revoke the permit if the salary drops below the new threshold after indexation.

How to avoid it: Include an automatic indexation clause in the employment contract. Set a calendar reminder for January 1 and July 1 each year to verify the salary still meets the updated threshold. The IND gives employers 2 months to correct a shortfall and notify them — after that, the permit is revoked.

Official source: Everaert Advocaten — Salary criteria

3. Employer is not a recognised sponsor

Only employers with IND-recognised sponsor status can file HSM applications. An application from a non-recognised employer is immediately rejected. Becoming a recognised sponsor takes 4–8 weeks and requires the employer to meet compliance obligations.

How to avoid it: Before signing a contract, verify the employer appears on the IND Public Register of Recognised Sponsors. If the employer is not listed, they must apply for recognition first — which delays the entire process.

Official source: IND — Public register of recognised sponsors

4. Sponsor recognition revoked

Even if the employer was recognised at the time of application, sponsor recognition can be revoked — leaving existing HSM permit holders in legal limbo. This is not theoretical:

• Nina.Care (au pair agency) — sponsor recognition revoked by IND in September 2025 (IND news)
• Avans+ (university of applied sciences) — recognition revoked in June 2025, directly affecting international students (IND news)

Grounds for sponsor revocation

• Three or more fines in the past four years for tax evasion, minimum wage violations, or illegal labour
• Not employing any HSM workers for two consecutive years (previously three years; tightened in 2025)
• Serious or repeated violations of the Aliens Act or Foreign Nationals Employment Act

How to avoid it: Research your prospective employer thoroughly. Check the public register, search for news about the company + "IND" or "sponsor", and ask the employer directly about their compliance history.

Official source: KPMG — Stricter rules for HSM sponsorship

5. Salary does not reflect market rate

Since 2025, the IND requires that the agreed salary is "marktconform" (in line with the market). This means the salary must be comparable to what others in the same role and sector earn. A company cannot simply pay the minimum HSM threshold for a senior position — the IND can reject the application if the salary is suspiciously low relative to the role.

How to avoid it: Ensure the salary matches industry benchmarks. The IND may compare against sector-specific data. If the offered salary is at the bare minimum threshold for a senior role, provide supporting documentation explaining why.

Official source: KPMG — Restrictive changes to HSM scheme

6. Incomplete or incorrect documents

Missing or invalid documents are a common cause of delays and rejections. The IND will not process an incomplete application.

Documents that most often cause problems

• Expired passport — must be valid for at least 6 months beyond the intended stay
• Missing legalisation or apostille — diplomas and civil documents from most countries must be legalised
• Unsigned employment contract — must be signed by both parties before filing
• Missing antecedents certificate — the employer must complete and sign this declaration
• Incorrect salary on the contract — the contract salary must match or exceed the IND threshold

How to avoid it: Use the official IND application form (7032) as a checklist. Have the employer's HR or immigration lawyer review all documents before submission.

Official source: IND — HSM application form and document requirements

7. BIG registration missing (healthcare workers)

If you intend to work in an individually regulated healthcare profession listed under Article 3 or 36a of the BIG Act, you must be registered in the BIG Register before the IND will grant the permit. Without BIG registration, the application is rejected outright.

How to avoid it: Start the BIG registration process early — it can take several months. Check if your foreign diploma is recognised. If not, you may need a supervised practice period of 3 months first.

Official source: BIG Register — Healthcare professionals

8. Employer has a violation record

The IND screens the employer's compliance history. An application can be refused if the employer has been fined under the Aliens Act (Vreemdelingenwet) or the Foreign Nationals Employment Act (Wav). Violations include:

• Employing workers without valid permits
• Tax fraud or evasion
• Paying below the statutory minimum wage
• Failing to keep required records for 5 years (previously 7 years; updated in 2025)

How to avoid it: Ask the employer directly whether they have received any fines or sanctions. You can also check public court records for labour law violations.

Official source: Kroes Advocaten — Stricter rules for HSM scheme

9. Job loss — 3-month search period expired

This is not a rejection of the initial application, but a revocation of an existing permit. If your employment ends (resignation, layoff, or contract expiry), you have exactly 3 months to find a new position with another recognised sponsor. If you fail to do so, the IND revokes your residence permit.

What you can do:

• Register as a job seeker with the UWV immediately
• Your new employer must be a recognised sponsor
• The new job must also meet the salary threshold
• Consider switching to a different permit type — there are eight alternative options including the Orientation Year (Zoekjaar), self-employment, or studying

Official source: IND — Highly Skilled Migrant; Mynta — Eight options for unemployed HSMs

What is changing in 2025–2027

The Dutch government is tightening the HSM scheme. Key changes to watch:

Change	Status	Impact
Salary threshold increase to 1.1× average gross salary	Proposed for 2026/2027	Under-30 threshold rises from ~€4,171 to ~€4,551
Inactivity period shortened from 3 to 2 years	Effective 2025	Sponsors lose recognition faster if not hiring HSMs
Market-rate salary requirement	Effective 2025	Minimum threshold alone no longer sufficient for senior roles
Record retention reduced from 7 to 5 years	Effective 2025	Lower admin burden but stricter enforcement
Enhanced digital oversight by IND	Rolling out 2025–2026	More automated checks, faster detection of non-compliance

Sources: KPMG; Centuro Global

What to do if your application is rejected

1. Read the rejection letter carefully — the IND states the specific legal ground for refusal
2. File an objection (bezwaar) within 4 weeks — this is free and handled by the IND internally
3. Consult an immigration lawyer — firms like Everaert and Kroes Advocaten specialise in HSM cases and report high success rates on appeal
4. Fix the underlying issue — if the salary was too low, negotiate a raise; if documents were missing, gather them
5. Reapply — there is no limit on the number of applications, but each new application incurs the full fee (€423)

Official source: IND — Objection and appeal