Fictitious Employment Relationship: The 2014 Project Plan and Its Link to the Childcare Benefits Scandal

Executive Summary

On 8 May 2014, the Dutch government finalized a project plan to combat fictitious employment relationships through 13 sub-projects spanning KvK, Belastingdienst, UWV, IND, DUO and municipalities. The plan was triggered by a cabinet letter of 20 December 2013 announcing a fraud crackdown. It ran parallel to the FSV (Fraude Signalerings Voorziening) deployment and created the infrastructure for automated risk signalling between government agencies. The Combiteam Aanpak Facilitators (CAF), born from sub-project M, wrongly branded approximately 630 childcare agencies as fraud facilitators, affecting around 2,200 families.

What Happened

The cabinet declared fraud a national priority in December 2013. By May 2014, a 1.8 FTE project team delivered a plan targeting fictitious employment, defined as presented employment relationships where no actual work is performed and no salary is paid. The plan identified eight types of fraud enabled by fictitious relationships, including fraudulent payroll filings, benefit claims on fake employment and childcare benefit fraud. Thirteen sub-projects (A through M) established barriers, risk detection systems and data sharing mechanisms across government. The project concluded in December 2014, but sub-project M’s Manifestgroep Schijnconstructies merged with the Malafide Uitzendbureaus initiative to form the permanent CAF.

Evidence

The project plan explicitly states that legal entities were being abused to create fictitious employment relationships and that fraudsters exploited the presence of fake salary data in the Polis administration to obtain benefits, provisional tax returns and childcare benefits. Sub-project G established automatic sharing of fraud risk signals between KvK and GBA systems with the Belastingdienst. Sub-project I enabled unilateral correction of payroll data in the Polis administration. Sub-project M created the CAF, which applied an 80/20 approach that the parliamentary inquiry later criticized as based on “gross generalisations.” The plan was commissioned by the State Secretary for Finance through the Ministeriele Commissie Aanpak Fraude.

Analysis

The project plan was not a direct cause of the childcare benefits scandal, but it built the infrastructure that enabled it. Risk scores were amplified by the plan’s measures, CAF wrongly labelled childcare agencies as facilitators and the focus on fictitious employment normalized a fraud paradigm that also swept up innocent ZZP entrepreneurs and SMEs. The 64 million files discovered in the Datakluis (April 2026) may contain data collected through this plan’s mechanisms. The plan’s 1.8 FTE staffing for a government-wide operation indicates under-resourcing that favoured automated, broad-net approaches over careful individual assessment.

Frequently asked questions

What was the Project Plan Fictitious Employment Relationship?

The project plan was finalized on 8 May 2014 and comprised 13 sub-projects spanning KvK, Belastingdienst, UWV, IND, DUO and municipalities. It followed the cabinet letter of 20 December 2013, in which the government declared fraud a national priority, and it ran parallel to the rollout of the FSV.

How many childcare agencies did the CAF wrongly label as fraud facilitators?

Approximately 630 childcare agencies were wrongly branded as fraud facilitators by the Combiteam Aanpak Facilitators (CAF), with consequences for around 2,200 families. The CAF emerged in December 2014 from sub-project M of the project plan. The parliamentary inquiry later concluded that the team worked with gross generalisations.

How many staff worked on the project plan?

A project team of just 1.8 FTE delivered the plan in May 2014 for this government-wide operation. That low staffing level indicates deliberate under-resourcing, which favoured automated broad-net approaches over careful individual assessment. The plan identified eight types of fraud, including fraudulent payroll filings and childcare benefit fraud.

What is a fictitious employment relationship?

A fictitious employment relationship is a presented employment relationship where no actual work is performed and no salary is paid, governed by Article 7:610a BW. According to the project plan, legal entities were abused to create such constructions, and fake salary data in the Polis administration was used to obtain benefits, provisional refunds and childcare benefits.

Read also

• The Butcher as Gatekeeper — why the cabinet keeps the prosecution service out
• The accountability matrix 2017-2026 — who knew what about the data vault, and who is still there
• The full data vault timeline — the full timeline, 2019-2026
• The discovery of 64 million files — the discovery and the nine-month delay

Sources

• Projectplan Gefingeerde Dienstbetrekking (8 mei 2014, kenmerk 1910883/02774) via Informatiepunt Kinderopvangtoeslag
• Kamerstukken II 2012/2013, 17 050, nr. 450 - Kabinetsbrief 20 december 2013
• Art. 7:610a BW en Art. 7:610 BW (wetten.overheid.nl)
• Jurisprudentie: Gouden Kooi (ECLI:NL:HR:2011:BP8223), X/Gemeente Amsterdam (ECLI:NL:HR:2020:411), Deliveroo (ECLI:NL:HR:2023:501), Uber (C-434/15)