Sick leave and the Dutch Gatekeeper Act: the timeline from the sick report to the WIA application, who does what, and what an employer may record

What the Gatekeeper Act asks.

A sick employee keeps receiving at least 70% of their wages for up to 104 weeks, in the first year at least the statutory minimum wage. In that period employer and employee both have to work on the return to work, with the help of a company doctor. The Gatekeeper rules say what has to happen and when: a problem analysis, a plan of action, regular evaluations, a report to UWV and, near the end of the second year, a reintegration report that goes with the application for a WIA benefit.

UWV assesses that report. If it finds that the employer did not do enough, it can extend the period of continued pay by up to 52 weeks: the wage sanction. So the file matters as much as the effort: what is not written down with a date did not happen, as far as UWV can see. Employer and employee may deviate from the deadlines for the problem analysis and the plan of action, but only with a reason, written down.

This guide is general information, not legal advice. The deadlines below follow the law and UWV's guidance as of 28-10-2026. Check UWV and Rijksoverheid for the current rules, and your occupational health service for your own case.

The timeline, week by week.

The weeks count from the first day of sickness. Periods of sickness with less than four weeks in between count as one period, so a relapse soon after recovery continues the old timeline.

• Day 1: the sick report. The employee reports sick according to the company's own absence rules. The employer passes the report on to the company doctor or the occupational health service. The law says "in time"; UWV's guidance and most contracts with an occupational health service say within the first week.
• Week 6: problem analysis. If the company doctor expects long-term absence, they make a problem analysis within six weeks of the first day of sickness: what the employee can and cannot do, and what is needed to return. If that only becomes clear later, the analysis follows straight away.
• Week 8: plan of action. Within two weeks of the problem analysis, employer and employee agree a plan of action: activities, goals, deadlines, evaluation moments, the case manager, and the views of employer and employee on it. With an analysis in week 6, that is week 8.
• Evaluations. The plan is evaluated periodically; UWV expects at least once every six weeks. Every change to the plan goes into the file with the reason.
• Week 42: report to UWV. The employer reports the long-term sickness to UWV no later than the first day after the sickness has lasted 42 weeks.
• Week 52: first-year evaluation. At the end of the first year employer and employee look back and decide on the second year, again with both views written down. If return to the own work or other work at the own company is not realistic, UWV's guidance says the second track, work at another employer, starts no later than six weeks after this evaluation.
• Week 88: letter from UWV. UWV writes to the employee about applying for a WIA benefit.
• Week 91: final evaluation and reintegration report. No later than thirteen weeks before the 104 weeks end, the employer draws up the reintegration report, with a final evaluation and a current judgement of the company doctor.
• Week 93: WIA application. The employee applies for WIA no later than eleven weeks before the 104 weeks end, with the reintegration report.
• Week 104: end of continued pay, unless UWV imposed a wage sanction or employer and employee agreed to extend it.

Who does what.

• The employer is responsible for the reintegration and for the file. They need a written contract with a company doctor or an occupational health service, agree the plan of action with the employee, report to UWV in week 42 and draw up the reintegration report.
• The employee reports sick, stays reachable, cooperates with the company doctor and the plan of action, does suitable work when able, and applies for WIA.
• The company doctor or occupational health service assesses what the employee can still do, makes the problem analysis, advises on the plan and the evaluations, and gives the current judgement for the final report. Only the doctor knows the medical details; the employer gets advice about capacity, not a diagnosis.
• The case manager is named in the plan of action. They guide the process, keep the deadlines and the file, and are the contact for employee, manager and doctor. That can be someone at the company or at the occupational health service.
• UWV receives the report in week 42, assesses the reintegration report when the employee applies for WIA, and can impose the wage sanction.

What an employer may record, and what not.

The Dutch Data Protection Authority is clear: an employer may not record what the employee has or what caused it, also not when the employee tells it of their own accord, and consent does not change that. Health data belongs with the company doctor, and an employer may not have medical files stored in its own absence system. What it may record is limited:

• the phone number and the address where the employee can be reached, also a nursing address;
• the expected duration of the absence;
• current work and appointments that someone has to take over;
• whether the absence is related to a work accident, and whether a traffic accident with a liable third party is involved;
• whether the employee falls under one of UWV's safety-net schemes, for example sickness related to pregnancy.

Share with the occupational health service only what it needs, such as name and contact details. Keep the absence and reintegration file no longer than two years after the employee leaves, unless the company is its own risk bearer for the Sickness Benefits Act; then it is five years. Work accidents that led to more than three working days of absence go on a list with their nature and date. The full rules are on the page of the Data Protection Authority for employers with sick employees.

What SAP Business One covers.

The Human Resources module has absence lines on the employee: in Employee Master Data (Human Resources → Employee Master Data), on the Administration tab, Absence gives a from date, a to date, a reason of twenty characters and who approved it. The Absence Report (Human Resources → Human Resources Reports → Absence Report) lists them for a period. That is enough to know who is away. It is not a sick leave file.

• No timeline. No date for the problem analysis, the plan of action, week 42 or week 91, and no reminder when one is due.
• No counting. Two lines with three weeks in between stay two lines; B1 does not see them as one period. No partial recovery and no absence rate.
• No file. No place for the plan of action, the evaluations and the advice of the company doctor, each with a date.
• A free-text reason. Typing "flu" or "back" there is exactly the health data you may not record, and everyone who may open the employee master can read it. Leave it empty or use a neutral word such as "sick".

For what the employee master holds, who can see it and what Dutch HR needs on top, see the guide on HR in SAP Business One.

Where it goes wrong.

• A late start. The company doctor hears about it in week four, and the problem analysis misses week 6.
• A plan on paper only. A form filled in by HR, not agreed with the employee and without their view, and never evaluated.
• A relapse as a new case. A new sick report within four weeks of recovery starts a new count, and week 42 is missed.
• The diagnosis in the wrong place. In an email to the team, a spreadsheet or the reason field in B1.
• Sick when the contract ends. The employer reports to UWV on the last day of employment, and after six weeks or more of sickness a reintegration report is due by that day too.
• The state pension age. For an employee who has reached it, continued pay lasts six weeks, not 104.

Checklist: before the first sick report.

• A written contract with a company doctor or occupational health service, and an agreement on who passes on sick reports.
• Absence rules on paper: how and by when to report sick, to whom, and how to stay reachable.
• One file per case, with the date of every step, open only to HR and the case manager.
• A calendar or system that calculates the deadlines from the first day of sickness and counts periods with less than four weeks in between as one.
• A named case manager, and a backup for holidays.
• Agreement on what managers see: the report, the expected duration and the tasks; never the reason.
• A retention rule: delete the file two years after the employee leaves, five years if you are your own risk bearer.
• In B1: the absence reason stays empty or neutral, and you know who may open the employee master.

How KoonHRM approaches it.

KoonHRM, our HR system for small companies, on its own or with SAP Business One, has sick leave and the Gatekeeper rules built in: sick and recovered reports, partial work, the Gatekeeper timeline with every deadline from week 1 to week 104 per case, a relapse within four weeks counted together, and the absence rate per department. A daily signal warns when a Gatekeeper step is due. There is no field for the reason of sickness anywhere; sick leave notes are for HR only, and a manager sees the report, the percentage and the Gatekeeper tasks. If the company switches it on, employees report sick and recovered themselves on their phone.

With the SAP Business One link switched on, sick leave lands on the employee's absence in B1 as 'absent', without a reason, through the Service Layer; the sick leave file never goes to B1. KoonHRM runs on your own server. It is in development: the functions are built and tested against a simulated SAP, and the statutory rules have been checked against the law itself. The next step is the test on a real B1 and a pilot at a first company; there is no price and no date yet. It does not replace your occupational health service or legal advice. The KoonHRM page says exactly where it stands.

Sources: Regulation on the procedure in the first and second year of sickness (Regeling procesgang eerste en tweede ziektejaar, articles 2, 4 and 5); Civil Code book 7, article 629; Sickness Benefits Act, article 38; WIA, articles 23, 25 and 64; Working Conditions Act, articles 9 and 14 (all on wetten.overheid.nl); UWV, Werkwijzer Poortwachter and the pages on the plan of action and the final evaluation; Dutch Data Protection Authority, rules for employers with sick employees and on reintegration; Rijksoverheid; SAP Business One help documentation (Employee Master Data, Absence Information, Absence Report) and the database reference (OHEM, HEM1).