Validation backlog at TNO’s Heavy Work Expertise Centre

Publication date: 10 November 2025

This year, more information has been emerging around the 2024 agreement on the heavy work scheme. One of the now well-known assignments to the social partners is to clearly objectify when there is a case of heavy work. Social partners must then submit the related collective labour agreement arrangements to TNO’s Heavy Work Expertise Centre. The Labour Foundation of the Netherlands has now made public what was in fact already known: processing of validations by the Expertise Centre is experiencing delays. It’s not a showstopper, but the delay is neither convenient nor surprising.

In the Labour Foundation’s letter, three aspects are mentioned which, in my view, speak for themselves given earlier publications in 2025, but apparently are intended to provide comfort to decentralised social partners:

• Arrangements (based on the RVU threshold exemption) that start from 2026 are possible, even if the validation process at the Expertise Centre has not yet been completed.
• The validation process must, however, be initiated or continued.
• The parties to the collective agreement still have the task of ensuring that the target group for the RVU scheme is clearly delineated and substantiated for employees with heavy work, and that the RVU arrangements are linked to additional efforts on sustainable employability.

No reason for the delay is given in the Labour Foundation’s letter, but I can imagine a few. There will likely be many requests submitted; it is complex material (even for specialists); the Expertise Centre may (still) be understaffed; there is no uniform definition of what constitutes heavy work; there are diverse sectors with diverse types of work; TNO’s criteria are not exhaustive and have not previously been widely applied in the Netherlands. The question also arises whether social partners and the government underestimated this or actually anticipated it.

In any case, what the Labour Foundation also emphasises in its letter — and I agree with this — is that decentralised social partners must take into account the signal value of 15,000 times the RVU threshold exemption per year. Decentralised social partners would do well to be cautious with heavy work arrangements based on the RVU threshold exemption. If they do not, they are shooting themselves in the foot. The government can, after all, decide to lower or abolish the RVU threshold exemption.