RI&E Explained: 11 Things UK and International Employers Must Know

A UK group opens an Amsterdam office. The group risk assessment is translated into Dutch, filed, and reported as complete. Eighteen months later the entity has grown past twenty-five people, and somebody discovers that the document was never valid, cannot be made valid retrospectively, and should have been examined by a certified external expert.

That is the RI&E, and it is the point at which Dutch occupational safety stops resembling the British system. The Netherlands does not merely require a risk assessment. It requires a specific instrument, produced in a specific way, and in most cases checked by somebody with a certificate.

If you already know the French DUERP or the German framework overseen by the DGUV, this will feel familiar in shape and different in detail. Here are the eleven things that matter.

1. Every employer needs one, from the first employee

There is no small-business exemption from having an RI&E. The Dutch government's Arboportaal states the position plainly: every company with at least one employee must have one, and the Steunpunt RI&E puts it the same way. If you employ people in the Netherlands, you are an employer and the obligation applies.

A two-person representative office is in scope. A UK entity with one Dutch salesperson on a local contract is in scope.

2. It is an inventory and an evaluation

The name is doing work that the English phrase "risk assessment" hides. Risico-Inventarisatie en -Evaluatie means you identify the risks and then you evaluate them: how significant they are, who is affected and how urgently they need addressing.

An inventory without the evaluation is half a document, and it is the half that Dutch employers most often produce when working from a translated group template.

3. The plan van aanpak is part of it, not a sequel

The RI&E includes a plan of action setting out what will be done, by whom and by when. It is not a separate deliverable produced afterwards if there is appetite for it.

This is the most consequential structural difference from UK practice, where the assessment and the subsequent actions frequently live in different places and different systems. In the Netherlands an RI&E without a plan van aanpak is incomplete on its face.

4. Above twenty-five employees, it must be tested by a certified expert

The requirement with no UK equivalent at all, and the one that catches growing entities.

The Steunpunt's guidance on toetsing sets out when testing by a certified arbodienst or arbokerndeskundige is required: where the organisation has more than 40 hours per week of personnel and more than 25 employees. Both limbs, together.

There is no self-certification route past that threshold. The UK allows a competent person inside the business to produce and own the assessment indefinitely; the Netherlands requires an external certified check once you are past the line.

5. There are exactly two exemptions, and they are narrow

The first applies where the organisation has up to 40 hours per week of personnel. You still need an RI&E, but you may use the official Checklist Gezondheidsrisico's, which does not require testing.

The second applies where you have up to 25 employees and produced the RI&E using a recognised branche-RI&E instrument, which is a sector-specific tool. That route removes the testing requirement.

Anything outside those two situations needs testing. Groups frequently assume a third exemption exists for office-based or low-risk work. It does not.

6. The branche instrument has conditions attached

If you rely on the second exemption, two conditions bite. Your company must actually belong to the sector whose instrument you used, and the instrument must have been recognised at the point you completed your RI&E. Borrowing a neighbouring sector's tool because it looked closer to your operation does not work, and if no recognised instrument exists for your sector then testing is required.

Worth checking currently rather than historically: the recognition procedure for branche instruments is changing, with a new procedure taking effect from 1 June 2026, so an instrument's status is a thing to confirm at the time of use rather than assume from a previous cycle.

7. The headcount test is people, not full-time equivalents

A detail that decides which side of the line you fall.

The twenty-five is counted in persons or employment contracts rather than FTE, so forty part-time staff are forty employees for this purpose, not twenty. The hours test counts personnel excluding the employer and includes interns. A group that calculates Dutch headcount from an FTE payroll report will under-count and conclude wrongly that no testing is needed.

8. Psychosocial workload is a required subject

Dutch law treats psychosocial workload as a subject the RI&E must address, covering workload, aggression and violence, bullying and harassment at work.

For professional and technology employers this is where group templates are thinnest, because UK practice has historically treated workload as a wellbeing topic rather than an assessable hazard. In the Netherlands it belongs in the statutory document with controls and an owner, and an RI&E silent on it is incomplete.

9. A preventiemedewerker must be appointed

The Dutch framework requires the appointment of an internal prevention officer, whose role includes assisting with the RI&E, advising on measures and liaising with the works council and the occupational health provider.

This is an internal appointment, distinct from both the external certified expert who tests the document and the competent person concept British employers already work with. In very small organisations the employer may fill the role personally; in larger ones it must be somebody with the time and standing to do it.

10. A contract with occupational health support is mandatory

Dutch employers must have a basic contract in place with an occupational health service or company doctor, covering matters including access to a company doctor, absence guidance and the handling of occupational illness.

British employers routinely treat occupational health as a discretionary service bought when needed. In the Netherlands the arrangement itself is the duty, which is the same pattern seen in Germany with the appointed company doctor and in Japan with the industrial physician. EU-OSHA's overview of the Dutch national system explains how the pieces fit together.

11. The works council has a say, and the inspectorate fines

Two closing points that change the timetable.

Where a works council exists it holds consent rights over arrangements concerning working conditions, so the RI&E and its plan van aanpak are agreed rather than announced. A group rollout that treats the Dutch entity as a recipient will stall there.

And enforcement is real. The Nederlandse Arbeidsinspectie can fine an employer for not having an RI&E, and the fine does not discharge the obligation: you pay and you still have to produce one. The Steunpunt is explicit that an RI&E is never finished, and that it should be reviewed as circumstances change.

RI&E against its European siblings

Feature	Netherlands RI&E	France DUERP	Germany	UK
Written document required	Yes, from the first employee	Yes	Yes	Yes, five or more employees for recording
Action plan inside the instrument	Yes, the plan van aanpak	Yes, within the document	Measures documented	Separate in practice
External certification of the document	Yes, above the thresholds	No	No	No
Standing occupational health arrangement	Yes, basic contract	Yes, occupational medicine	Yes, appointed company doctor	Discretionary
Psychosocial load as a required subject	Yes	Yes	Yes, statutory since 2013	Guidance based
Internal appointed officer	Preventiemedewerker	Designated worker	Sifa	Competent person

Read the third row twice. External certification of the assessment document itself is the feature that most distinguishes the Dutch regime, and the one that a group used to UK, Irish or US practice will not anticipate. All of these systems descend from the EU Framework Directive 89/391/EEC, which is why the shape rhymes and the detail does not.

Running the Netherlands inside a group system

The temptation is to produce the RI&E once, get it tested and consider the Netherlands closed. That lasts until the entity grows, moves premises or changes what it does.

The workable pattern is the one that holds across jurisdictions. One methodology and one register for the group, with the local statutory instrument produced properly in each country and its own status tracked: which document, which version, tested or exempt, by whom, when, and the plan van aanpak actions with owners and dates. That is where health and safety consultants and software are worth more in combination than either alone, because the RI&E's testing status is a date-sensitive fact that nothing in a UK-shaped system has a field for. Periodic health and safety audits then verify each entity against its own national test, and the Arboportaal remains the primary Dutch reference.

Where Arinite fits

Arinite has spent 15+ years producing the right local instrument in each country rather than translating one. We support 1,500+ businesses in 50+ countries and protect 100,000+ employees, with 95%+ client retention. Our health and safety consultants work extensively with IT and software and office-based clients, which is most of the foreign-owned footprint in Amsterdam, Rotterdam and Eindhoven, and our RI&E work is usually triggered by growth past the testing threshold rather than by a new entity.

Our global health and safety consultants coordinate certified Dutch practitioners alongside the equivalent roles elsewhere, including the Italian RSPP and the French and German appointments, and our international health and safety consultants can tell you where your Netherlands entity currently stands.

Count your Dutch headcount in people rather than FTE, then check whether your RI&E has ever been tested. Then book a free gap analysis and we will tell you in one call whether the document you hold is the one Dutch law requires.

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