Dutch Digitalisation Subsidies: Who May Send the Invoice Is Decided Province by Province

In Luxembourg the question has one answer, written into the law: the adviser must be external to the beneficiary, and nothing else is asked. In Flanders providers register. In Wallonia they were labelled, until labelling was frozen. The Netherlands does something different again — it hands the question to the provinces, and they answer it in ways that have almost nothing in common.

That matters in a very practical way. One Dutch regulation accepts an adviser registered in a trade register of another state, in so many words. Another lets a regional innovation hub decide whether you count as an expert at all. And the one national scheme that is open today and does pay for implementation by a supplier is capped at an amount you could spend on a laptop.

Everything below was read first-hand on 11 and 12 October 2026 in the regulations and in the official publications, not in subsidy round-ups. Three of the figures in this article differ from what you will find in secondary write-ups, and one of them differs from the summary on the administering agency's own website. Subsidy rules move quickly: check the date above before you build a budget on any of this.

The question, and where the answers live

An SME buys a digitalisation project. A subsidy pays part of it. Somebody has to send the invoice that goes into the file. Whether your invoice is allowed to be that invoice is decided by one clause in one regulation, and in the Netherlands there is no single regulation to look it up in.

There are three layers, and it is worth being clear about which does what:

• National schemes run by RVO, the government enterprise agency, under the Regeling nationale EZK- en LNV-subsidies. Broad, standardised — and, as of today, almost none of them buy external advice.
• Provincial and regional schemes, each with its own regulation adopted by the province or by a regional cooperation body. This is where the money for an external adviser actually sits.
• Tax instruments, chiefly WBSO, which work through payroll tax rather than through a grant and follow a completely different logic about who benefits.

Most people looking for "the Dutch digitalisation subsidy" are looking for something that does not exist. What exists is a scattering of schemes with different rates, different windows and different rules on the provider.

Nationally, one open scheme pays a supplier — and it is small

The scheme is called Mijn Cyberweerbare Zaak — "My Cyber-Resilient Business", MCZ. It is a subsidy module inside the Regeling nationale EZK- en LNV-subsidies, and it is open right now: the current window runs from 7 September 2026, 09:00 to 30 November 2026, 17:00, with a ceiling of €1,000,000 for the whole country. Those two facts come from the amending regulation published in Staatscourant 2026 nr. 31342 on 31 August 2026.

What it funds is specific. Eligible costs are the costs of obtaining and implementing, from a supplier, products and services that appear on the scheme's roadmap of cyber-resilience measures. RVO currently lists eight: secure network access and wifi, a password manager, two-factor and multi-factor authentication, patch management, antivirus software, setting up and testing backups, a risk inventory and evaluation, and cyber awareness training.

The conditions on the applicant are light by the standards of this landscape. The company must be registered with the Dutch chamber of commerce, have at most 50 employees and a turnover under €10 million in the preceding financial year. Primary agricultural production and the fishery and aquaculture sectors are excluded. The measures have to be implemented after the window opened and fully paid for. Minimum eligible costs are €400. One application per company, decided in order of receipt until the million is gone.

And on who may supply: nothing. The regulation speaks of taking products and services from a leverancier, a supplier. No register, no certification, no list, no country. For an agency that configures authentication, sets up and tests backups, or runs a security review, this is a door that is actually open — just a narrow one.

The figure the agency's own page understates by half

Here is why reading the regulation is not a pose. The summary sentence on RVO's own page reads: "De subsidie is 50% van de aanschafwaarde en/of het implementeren van een digitale technologie, of dienst tot een maximum van € 1.250 van de aanschafprijs." Read that as written and the €1,250 caps the purchase price — which would mean a maximum payout of €625.

The regulation says something else, and says it without ambiguity. The article that fixes the amount, introduced with the module in Staatscourant 2023 nr. 26170, reads: "De subsidie bedraagt 50 procent van de subsidiabele kosten met een maximum van € 1.250 per aanvrager." Fifty percent of eligible costs, maximum €1,250 per applicant. The subsidy is the capped amount, not the price. So eligible costs of €2,500 are used in full, and a company reading only the summary line would ask for half of what it is entitled to.

The 2026 amendment also narrowed what counts, and this part is easy to miss. Regular operating costs, including management and maintenance costs, are no longer eligible — explicitly including new versions of programs, apps or operating systems, and subscriptions in which a measure happens to be bundled. For paid subscriptions running longer than a year, only one year of cost is eligible.

Translated into a quote: the one-off work of putting a measure in place can go into the file. The monthly fee that keeps it running cannot. That distinction decides how you write the proposal, and it is nowhere in the headline numbers.

WBSO and MIT: why the national route does not lead to an adviser

Two national instruments come up in every conversation about Dutch technology funding, and neither one pays for buying a project.

WBSO is a payroll tax credit for research and development. For 2026 the rate is 36% of the first tranche of the R&D base, 50% for starters, up to a first-tranche limit of €391,020, and 16% above it. The decisive condition is in the eligibility rules: "U mag alleen WBSO aanvragen voor S&O-uren van uzelf en van medewerkers die bij u op de loonlijst staan" — you may claim only your own hours and the hours of people on your own payroll. Hired labour is excluded. Outsourced research is excluded. There is a narrow opening for the costs of outsourced work that is not research itself, such as a laboratory test or building a prototype that you cannot do in-house, and the work must be carried out in an EU member state.

So WBSO rewards whoever does the development with their own staff. If a Dutch company buys a development project from an agency, WBSO does nothing for that purchase. It is the agency's instrument, if the agency has Dutch payroll — not a subsidy on the agency's invoice.

MIT, the SME innovation stimulus, used to be the obvious national route to a paid external opinion, and that route has been dismantled. On RVO's own overview, checked today: the knowledge vouchers are closed, with the blunt note that the instrument will not open again; feasibility projects are no longer run by RVO at all and have to be applied for regionally; and the R&D collaboration projects, including the AI variant, are temporarily closed.

That is the real finding at national level. It is not that the Netherlands has nothing — it is that what it has for external advice was handed down to the regions, which is why the rest of this article is about provinces.

Groningen and Emmen: a regulation that names other countries' trade registers

The scheme is Subsidieregeling Stimulering digitalisering en robotisering mkb 2.0, in force since 1 October 2025, adopted jointly by the province of Groningen and the municipality of Emmen and administered by SNN, the Northern Netherlands cooperation body. I read the regulation in full, including its explanatory notes.

The money: 50% of eligible costs. For a strategic digitalisation or robotisation advice drawn up by an independent expert, up to €20,000 of subsidy — so a project of €40,000 is fully used. For buying and implementing hardware and software, up to €100,000, with €100,000 the lifetime cap per undertaking across this scheme and its predecessor. On every invoice of €250 or more excluding VAT, a flat 1% uplift is added; costs below €250 cannot be claimed at all.

Minimum eligible costs are €10,000 for an advice and €20,000 for a purchase. That is not guidance — it sits in the article listing grounds on which the subsidy shall be refused, next to the ground that no work may have started and no commitment may have been entered into before the application was received.

The timing is the sharpest thing about it. Applications close on 31 October 2026 at 17:00. The overall ceiling is €5,000,000 and the remaining budget shown on the scheme page when I checked today was €1,556,026.13. Allocation is in order of receipt; if an incomplete file is sent, the date that counts is the date it became complete; and if several complete applications arrive on the same day and would breach the ceiling, the order between them is decided by lottery. A decision follows within 13 weeks of a complete application, and the project must be finished within 18 months of the award.

Now the clause this whole article is about. Eligible costs include "het inschakelen van een onafhankelijke deskundige, die is ingeschreven in een handelsregister" — engaging an independent expert who is registered in a trade register. The explanatory note to that provision then says which register: "De onderneming waar de deskundige werkt, moet ingeschreven zijn bij het handelsregister van de Kamer van Koophandel of vergelijkbare handelsregisters in andere staten. Particulieren kunnen daarmee niet optreden als onafhankelijke deskundige."

The company employing the expert must be registered with the Dutch chamber of commerce or in comparable trade registers in other states. Individuals cannot act as the independent expert. So a Belgian company registered in the BCE, or a German, French or Dutch one in its own register, satisfies the text as written; a freelancer with no company does not. An "expert" is defined only as someone who must be regarded as qualified to carry out the assignment on the basis of education or experience — no accreditation anywhere.

What is demanded instead is independence, and the list is concrete: no financial interest in either direction between expert and applicant, not the same director, no family relationship in the first or second degree, and no interest in the outcome of the project beyond the usual. The regulation adds that the list is not exhaustive.

What Groningen will not pay for

Before anyone builds a pipeline on that clause, the filter in this scheme is severe, and it sits entirely on the client.

The beneficiary must be an SME with a physical establishment in the province of Groningen or the municipality of Emmen, carrying out activities there, in the process and manufacturing industry, with activities under SBI codes 10 to 35, 41 to 43, or 72 — food manufacturing through energy supply, construction, and scientific research. The explanatory note says plainly how this is tested: by the SBI code and, where there is one, the company's website. A post-box address does not count, and renting a meeting room for a few hours a month is not an establishment. The effects of the project must land in the region.

What the money is for is narrower still. "Digitalisation" is defined in the regulation as making and processing information digitally for the purposes of production processes. A strategic advice is defined as an extensive piece of work whose purpose is to set the direction for the medium to long-term development of the company in digitalisation or robotisation, based on an analysis of the current situation and the company's potential.

And then the exclusion that rules out most agency work directly. The explanatory note states that standard office hardware and software — accounting packages, laptops, mobile phones — are not eligible, and goes further: "Enkel het digitaliseren van de kantooradministratie (bv offerteproces of de planning) is in de basis niet subsidiabel omdat dit niet wordt gezien als het primaire proces bij een maakbedrijf." Digitising only the office administration, for instance the quotation process or planning, is in principle not eligible, because that is not the primary process of a manufacturer.

Read that honestly and a webshop project does not qualify here. What qualifies is the production environment — and, for the advice track, a strategy document about digitising it. Supplier independence is required for hardware and software too, on the same criteria as for the expert. Costs for which a subsidy has already been obtained or applied for elsewhere cannot be presented again; the scheme states its expectation that the applicant finances half the cost itself.

Overijssel: forty percent, and a hub decides whether you are an expert

One province to the south the answer changes shape completely. Overijssel's scheme Digitale en circulaire industrie runs under the Uitvoeringsbesluit subsidies Overijssel 2022, chapter 1 and paragraph 6.13. It is open on a first-come, first-served basis, with applications possible from 21 May 2026, 09:00 until the budget is spent.

The money is more modest: 40% of eligible costs, maximum €10,000 per application, minimum eligible costs €5,000 excluding VAT, under the de minimis regulation. The ceiling for 2026 and 2027 together is €350,000, of which €250,000 is reserved for digitalisation. A company may receive at most two subsidies per three calendar years — one for digital, one for circular activities — and connected companies count as one applicant.

The applicant must be a BV, NV, sole trader, maatschap or v.o.f. with at least two employees in permanent employment, an industrial SME established in Overijssel. Activities must start within 3 months of the award and be completed within 12.

Two changes to the current version matter. First, buying hardware or software is no longer eligible — the scheme now pays for advice and support by private organisations only. Second, the eligible digitalisation activities are listed, and one of them is squarely commercial work: digitally connecting the offering, business operations and sales. The others are managing and using company data and getting current insight across the organisation, digital archiving and securing the exchange of business information, applying or improving ERP or MES software, and automating production processes through industrial automation and robotics.

Now the provider rule, and it is a different species. A deskundige derde — expert third party — is defined as an adviser or organisation with demonstrable knowledge and experience in digitalisation in industry, and may not be a parent, subsidiary or sister company of the applicant. No residence requirement, no register. But on top of that:

• the client must have had an EDIH assessment carried out after 1 July 2025 — a screening by innovation experts resulting in an EDIH digitalisation plan — and the work must appear in that plan;
• the client must submit the intended activities and your quotation to an adviser at Kennispoort Regio Zwolle or Novel-T, who issues a statement saying whether the activities are in the plan and whether the work is being done by an expert third party.

So the selection of the provider is effectively made by a regional hub rather than by the client, and your commercial offer is part of what the hub looks at. That is closer to the Walloon labelling model than to a rule you can read and satisfy on your own. It is not a closed door — it is a door with a gatekeeper, and the gatekeeper has a name and an email address.

SLIM: the highest rate in the landscape, for a different subject

One more instrument deserves a mention precisely because people reach for it expecting digitalisation money. SLIM is the national scheme for learning and development in SMEs, run by the ministry of social affairs rather than by RVO. Its application criteria list four eligible activities, and the first is a doorlichting van de onderneming uitmondend in een opleidings- of ontwikkelplan — a review of the company resulting in a training or development plan.

That is an external adviser's deliverable, and the rate is the most generous anywhere in this comparison: 80% for small enterprises, 60% for medium-sized ones, up to €25,000 per SME applicant. The criteria set no requirement on who carries out the work — no certification, no list, no nationality.

The catch is the subject matter. The deliverable has to be about learning and development, and the review has to end in a training or development plan. A digitalisation roadmap is not that, however much training it implies. If the engagement genuinely is about how a team learns to work differently, SLIM is the best rate on this page; if the word "digitalisation" is doing the work, it is the wrong scheme.

One honest gap: the official criteria page does not state the 2026 application windows, and I am not going to infer them from past years. SLIM has historically opened for individual SMEs in two short windows per year, and the window is the whole game in a scheme allocated by order of receipt. Verify the current dates with Uitvoering van Beleid before promising anything.

The Netherlands next to Luxembourg and Belgium

Placed side by side with the schemes we have already written up, the Dutch picture stops looking exotic and starts looking like one option among several — with the question of who may invoice answered differently in every column.

Three rows that did not fit the table are worth stating in words. Every one of these schemes requires a local beneficiary, and in the two Dutch provincial ones the client carries extra conditions that have nothing to do with the project: SBI codes 10–35, 41–43 or 72 and a physical site in the region for Groningen, an EDIH assessment after 1 July 2025 and at least two permanent employees for Overijssel. All five demand that you file before you act — before the measures are implemented, before any commitment is entered into, before the mission starts. And on whether an ordinary online-shop project fits: in Luxembourg and Brussels yes, in Overijssel partly, in Groningen no, and under MCZ only for the listed cyber measures.

The Brussels scheme and what happened to its neighbours in August 2026 are covered in Brussels Digitalisation Grant: Getting Up to €10,000 Back on a Consultancy Mission and What Brussels Cut From Its Business Primes in August 2026 — and Why Digitalisation Survived. The Luxembourg scheme, which remains the cleanest text we have found on this question, is in Luxembourg Pays Half of an SME Consultancy Project — and Sets No Rule on Who Invoices.

Two patterns survive the comparison. The restrictions live on the client, not on the provider — every one of these schemes demands a local beneficiary, and only two of the five say anything at all about who may be paid. And the rate is the least interesting number in the table: the window, the minimum and the primary-process test decide far more cases than the difference between 40% and 50%.

What this means in practice — and what I did not check

If you are a Dutch SME, the order to work in is boring and effective. Find out which province's regulation applies to your site, read the clause on eligible costs before you choose a supplier, and file before you sign anything. In both provincial schemes above, a commitment entered into before the application is a ground for refusal, not a detail to negotiate. If your project is cyber hygiene, MCZ is open until 30 November and €1,250 is worth an afternoon's paperwork. If you are in Groningen or Emmen and have been putting off a digitalisation strategy, the window closes on 31 October 2026 at 17:00, and same-day competition is settled by lottery.

If you are an agency wondering whether your invoice can be in the file: in Groningen the regulation already answers yes, provided you are a company in a trade register somewhere and genuinely independent of the client. In Overijssel the answer runs through Kennispoort or Novel-T, and the sensible move is to talk to them before quoting, not after. Nationally, MCZ asks nothing about you at all.

We build the digital side — websites, online shops, integrations, automation — and we are comfortable being the external party named in a subsidy file. We would also rather say at the first call that a scheme does not fit than help assemble a file that fails on a condition both of us could have read. For a manufacturer in the north of the Netherlands, that conversation is about the production environment and a strategy document, not about a webshop.

Finally, the honest limits of this article. I read the Groningen regulation and the Overijssel conditions in full, the MCZ module in the official publications, and the WBSO, MIT and SLIM criteria on the administering agencies' own pages. I did not read the regulations behind the vouchers that RVO lists for Utrecht, Flevoland, Noord-Holland and Zuid-Holland, or the DigiPro scheme in the Dutch-German border region — RVO's index page gives neither amounts nor deadlines for them, and I will not quote numbers I have not seen in a text. There are twelve provinces and I have read two. If your site is somewhere else, the clause you need exists, and it will not say what either of these two say.

Want us to check whether a project fits a scheme, and what the file would need? Write to [email protected] with your company number, your location and a sentence about what you want to build. Every figure, article and condition above was read in the regulations and official publications themselves on 11 and 12 October 2026, and the administering bodies — RVO, SNN, the province of Overijssel and Uitvoering van Beleid — are the only authority on their own rules.