Problem analysis and action plan in the Netherlands
If an employee looks likely to be off sick for more than a few weeks, the company doctor draws up a problem analysis (probleemanalyse) by week 6 at the latest. It sets out what the employee can still do and what's needed to get back to work. Within two weeks after that, so by week 8 at the latest, you and the employee draw up an action plan (plan van aanpak). Below you'll find what goes into both documents, what you as the employer do and don't get to see, and an example action plan.
When does the problem analysis have to be ready?
No later than six weeks after the first day of sickness. That's in the Regeling procesgang eerste en tweede ziektejaar, the regulation under the Wet verbetering Poortwachter. As the employer, you're responsible for making sure the company doctor or occupational health service (arbodienst) gives their assessment on time. The company doctor makes the analysis, but you have to have passed on the sick report in time.
Work it out like this: first day of sickness + 6 weeks. If someone has been sick since Monday 13 April 2026, the problem analysis must be there by 25 May 2026 at the latest.
The problem analysis is only required if the absence threatens to become long-term. If someone with the flu is back at work after two weeks, there's no need for one. If it only becomes clear after week 6 that it's going to take a while, you request the analysis straight away.
Not sure whether it'll take long? Pass the sick report on to your occupational health service early anyway. A late problem analysis is one of the things the UWV (the Dutch employee insurance agency) looks at later. What to arrange in the first few days is in what to do in the first week of a sick report.
What's in the problem analysis?
The company doctor talks to the employee and looks at three things:
Limitations: what can the employee (temporarily) not do because of the illness?
Capabilities: what can the employee still do, and for how many hours?
Outlook: how long will recovery probably take, and what's needed to return?
Based on that, the company doctor advises on reintegration: can the employee return to their own job, with adjustments, or to other work within your business?
What do you get to see as the employer?
Not everything. The company doctor also discusses the employee's physical or mental symptoms, but you're not allowed to receive that medical information. According to the UWV, the company doctor puts the medical details on a separate form that only goes to the employee.
You get a short version with what you need to arrange the reintegration:
the expected length of the absence
the limitations and capabilities, in terms of work (for example "can do 4 hours a day of seated work")
the advice on returning to work
Does the document you receive contain a diagnosis or other medical information anyway? It shouldn't. Don't keep it, and ask the occupational health service for a version without medical details.
What is the action plan?
The action plan describes how the employee gets back to work. You draw it up in agreement with the employee. So it's not your plan that the employee has to sign, but a plan you make together, based on the company doctor's advice.
The deadline: no later than two weeks after the problem analysis. If the problem analysis is ready on 25 May, the action plan must be there by 8 June 2026. If the analysis comes earlier, the deadline moves with it.
If the company doctor finds that a return to work isn't possible at all, there's no need for an action plan (yet).
What has to be in the action plan?
The regulation lists four parts that must be in it:
The goal: back to their own job, to adjusted work, or to other work within your business.
The activities: what you'll do to reach that goal, with deadlines. Think fewer hours, different tasks, an adapted workplace, therapy or a course.
Evaluation moments: when you'll discuss progress.
A supervisor: the person who keeps an eye on whether the agreements are kept. This is usually called the case manager. In a small business, that's often you. The UWV recommends choosing the case manager together with the employee.
The UWV also advises writing down in the plan what employer and employee each think of the agreements. If you disagree on something, it's on record.
Here too: no medical information in the plan. Write "can't lift", not "has a hernia".
Does the action plan have to be signed?
The regulation only says the plan has to be in writing, and that the employee, the case manager and the company doctor each get a copy. A signature isn't required. You can still both sign it if you like. That shows you drew it up together, which can help if the UWV looks at your file later.
Example action plan
Copy this and fill in the [brackets]. The UWV also has its own form (in Dutch), but your own document is fine too, as long as it covers all the parts.
Action plan for reintegration
Employee: [name] · Role: [role] · First day of sickness: [date]
Date of problem analysis: [date] · Date of action plan: [date]
Case manager: [name] · Company doctor/occupational health service: [name]
1. Company doctor's advice. The company doctor advises [short summary of the advice on work, without medical information].
2. Goal. [Return to own job / own job with adjustments / other work at [company name]], expected by [date].
3. Agreements.
From [date], [name] works [number] hours a day on [tasks].
From [date], [name] builds up to [number] hours a week.
[Workplace adjustment / different tasks / course], by [date] at the latest, arranged by [name].
4. Evaluation. We discuss progress every [number, at most 6] weeks. The first meeting is on [date]. If there's reason to, we adjust this plan.
5. Employee's view. [What the employee thinks of the agreements.]
6. Employer's view. [What you think of the agreements.]
Copy to: employee, case manager, company doctor.
Employer's signature: ______ · Employee's signature: ______
What happens after the action plan?
The plan isn't something you file away. Discuss progress with the employee regularly, according to the UWV at least once every six weeks. Write a short report of each meeting: what's going well, what isn't, what you agree. If something changes, for example because the company doctor gives new advice, you adjust the plan. The company doctor can also update the problem analysis itself.
All these documents later go into the reintegration report (re-integratieverslag), if someone has been sick for almost two years. Before that, you'll also need to do the sick report to the UWV in week 42, and a first-year evaluation at the end of year one. The full process is in the complete Poortwachter timeline.
What if the employee doesn't cooperate?
If an employee refuses without good reason to cooperate in drawing up, evaluating or adjusting the action plan, you don't have to pay salary for that period (article 7:629 paragraph 3 of the Dutch Civil Code). Do tell the employee straight away. If you wait too long, you can't rely on it later.
Don't reach for this too quickly. Often it's a difference of opinion, and there's a better route for that.
What if you disagree?
With the company doctor's advice? The employee can ask for a second opinion from another company doctor.
About the reintegration itself? For example whether the work is suitable, or whether someone is cooperating enough. Then you or the employee can request an expert opinion (deskundigenoordeel) from the UWV. It's advice, not a ruling, but the UWV does take it into account later.
Whatever you do: put it on record. A disagreement that's properly documented isn't a problem. An action plan that doesn't exist is.
What happens if you're late?
At the end of the process, around week 91, the UWV assesses whether you as the employer did enough for the reintegration. If the problem analysis or action plan is missing, or very late, the UWV can impose a wage sanction (loonsanctie): you then keep paying salary for up to one more year.
Good to know: you and the employee can agree to depart from the deadlines, as long as you have a good reason and write it down. For example because the employee is in hospital in week 6. Record why.
How Heartsome helps
As soon as you record a sick report in Heartsome, Heartsome calculates every Poortwachter deadline from the first day of sickness: week 6, week 8, week 42 and beyond. You see them on a timeline and get a notification before a deadline passes.
You store the problem analysis, the action plan and the progress reports in the employee's profile. Those documents are only visible to HR admins, not to managers. If you don't want to share a document with the employee themselves, you can hide it per document. That way you have everything together when the UWV asks for it. More on what belongs in a file is in keeping employee records. See all Heartsome features.
Frequently asked questions
Who makes the problem analysis? The company doctor or occupational health service. You make sure they know about the sick report in time.
When does the action plan have to be ready? No later than two weeks after the problem analysis, so usually in week 8.
Do I get to see the problem analysis as the employer? You get a version without medical information: the expected length, the limitations and capabilities for work, and the advice. What's wrong with the employee isn't shared with you.
Does the employee have to sign the action plan? That isn't required, but the plan does have to be in writing. You can still both sign it if you like.
Is a problem analysis always needed? No, only if the absence threatens to become long-term. If someone is better after a few weeks, it isn't needed.
Who is the case manager in a small business? Usually the owner or a manager. It can also be someone from outside, for example from the occupational health service.
The rules on sickness absence can change. This article gives a general picture based on current Dutch law and is not legal advice. If in doubt, always consult an employment lawyer or HR adviser.
Sources
Regeling procesgang eerste en tweede ziektejaar, articles 2 to 6 (in Dutch)
Dutch Civil Code, article 7:629 paragraphs 3 and 7 (no salary when not cooperating)
UWV: Probleemanalyse bij ziekte werknemer (in Dutch)
UWV: Plan van aanpak (in Dutch)
UWV: Deskundigenoordeel (in Dutch)