What if the UWV imposes a wage sanction?
- 07/04/2026
- Posted by: Rosalie Derksen
- Category: Uncategorized
A UWV wage sanction can severely impact employers when they fail to properly fulfill their reintegration obligations. This sanction means that as an employer, you must continue paying wages to a sick employee for up to one year longer, which can have significant financial consequences for your organization.
For many SME entrepreneurs, the complexity of sickness legislation and reintegration obligations is a source of uncertainty. The UWV assesses retrospectively whether you have made sufficient efforts to help your sick employee return to work. A wrong assessment or incomplete documentation can lead to costly sanctions that heavily burden your business.
What is a UWV wage sanction and when is it imposed?
A UWV wage sanction is an extension of the wage payment obligation by a maximum of 52 weeks when an employer has made insufficient reintegration efforts during the first two years of an employee’s sickness. The UWV imposes this sanction after reviewing the reintegration report with the WIA application, between weeks 88 and 93.
The sanction is imposed when the UWV determines that you as an employer have not correctly implemented the Gatekeeper Improvement Act. This can have various causes, such as starting track 2 reintegration too late, insufficient documentation, or the absence of demonstrable efforts to help the employee return to work.
The UWV assesses the complete file and looks specifically at the quality of the final report. Even when a track 2 trajectory has not led to placement, this can still be sufficient for the UWV, provided all realistic options have been utilized and the efforts have been serious and consistent.
Why do employers receive a wage sanction from the UWV?
Employers receive a UWV wage sanction because they have insufficiently executed their legal reintegration obligations during the first 104 weeks of an employee’s sickness. The most common reasons are a late start with track 2, incomplete documentation, and a lack of demonstrable efforts for work resumption.
The main causes of a wage sanction are:
- Late start with track 2 reintegration (must start when it becomes clear that track 1 is insufficient)
- Missing or incomplete essential documents, such as a labor expert report, personal profile, search profile, and trajectory plan
- Unrealistic search profiles that are not defensible from a labor market perspective
- Poor reporting without medical information, but also without concrete progress
- Insufficient guidance from the chosen track 2 organization
The UWV not only assesses whether efforts have been made, but also whether these efforts were of sufficient quality and started in time. A wrong choice for reintegration guidance significantly increases the risk of delay and ultimately of a sanction.
How high can a UWV wage sanction be?
A UWV wage sanction can amount to a maximum of 52 weeks of additional wage payment on top of the regular 104 weeks of sick leave. This means you must pay wages for a total of 156 weeks (3 years) instead of the standard 2 years, which has significant financial consequences for your organization.
The amount of the sanction depends on the severity of the shortcomings that the UWV identifies. In case of serious negligence, such as the complete absence of track 2 guidance or essential documentation, the full sanction of 52 weeks can be imposed. For less serious shortcomings, the UWV may impose a partial sanction.
In addition to the extra wage payment, you also remain responsible for ongoing social charges and possible WGA charges after the end of sick leave. Employers can remain financially responsible for WGA benefits for up to 10 years, which further increases the total costs. Only in case of complete and permanent disability (IVA) is there no charge-through to the employer.
How can you as an employer prevent a wage sanction?
You prevent a UWV wage sanction by timely and correctly executing your reintegration obligations, particularly by starting track 2 when track 1 is insufficient and by maintaining complete documentation. Ensure a realistic approach with demonstrable efforts and choose an experienced reintegration partner.
The most important preventive measures are:
- Timely start with track 2: Begin at the latest within 6 weeks after advice from the labor expert.
- Complete documentation: Ensure a labor expert report, personal profile, search profile, trajectory plan, and ongoing reports.
- Realistic search profiles: Align with workload capacity and labor market opportunities.
- Quality guidance: Choose a track 2 partner with labor market knowledge, customization, and UWV experience.
- Active monitoring: Track progress and adjust timely where necessary.
The quality of phase 1 (orientation and preparation) largely determines the success of the entire trajectory. A good connection between employee and counselor is crucial, as is the labor market knowledge of your chosen partner. Choose not only based on reporting, but also on experience with UWV assessment and complete guidance up to the WIA application.
What should you do if you have received a wage sanction?
If you have received a UWV wage sanction, you can file an objection against the decision within six weeks. Collect all relevant documentation that supports demonstrable reintegration efforts and get assistance from a specialist with knowledge of UWV procedures and jurisprudence.
When filing an objection, it is essential to demonstrate that sufficient efforts were indeed made. This can be done through:
- A detailed timeline of all actions undertaken
- Evidence of job applications and labor market approach
- Correspondence with reintegration partners and potential employers
- Medical documentation that supports limitations
Many objections are honored when it appears that efforts were made, but these were insufficiently documented. A specialist with legal background and knowledge of laws and regulations can help in drafting a well-founded objection letter. It is important to act within the set deadline, as after six weeks the right to object expires.
When is external reintegration help needed to avoid sanctions?
External reintegration help is needed as soon as it becomes clear that track 1 (return to own employer) is insufficient, usually around weeks 46-52 at the first-year evaluation. This especially applies to smaller companies without alternative positions or with complex limitations that make internal adjustments impossible.
Specific situations where external help is essential:
- Small organizations (25-250 employees) with limited internal redeployment opportunities
- Complex or long-term limitations that require specialized guidance
- Lack of internal expertise for track 2 trajectories
- Legal uncertainty about reintegration obligations
- Previous negative experiences with UWV assessments
The choice for external guidance should be based on more than just reporting. Look for partners with labor market knowledge, experience with UWV assessment, and a proven track record in complex situations. Effective track 2 guidance combines coaching, networking, and training in one person, ensuring all aspects are addressed in an integrated manner.
How UFIND helps prevent UWV wage sanctions
We help SME entrepreneurs prevent UWV wage sanctions through timely, quality track 2 guidance with complete documentation and proven results. Our approach combines legal expertise with practical labor market knowledge, while you retain control over the absence file.
Our specialized support includes:
- Timely trajectory start: We start within 6 weeks after labor expert advice.
- Complete documentation: All reports and documentation required by the UWV, aligned with your systems.
- Customized guidance: One coach for the entire trajectory, with ACT methodology for complex situations.
- Legal certainty: Guidance by specialists with knowledge of laws and regulations.
- Result-oriented approach: Focus on actual placement, not just file building.
Our compact, intensive programs maintain energy and momentum, while our experience with both reintegration and recruitment ensures better results. We specialize precisely in complex cases that other parties consider low-prospect.
Do you have questions about your reintegration obligations or want to prevent a wage sanction from affecting your organization? Contact us for a no-obligation conversation about your specific situation.