ACG International

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Sharp, practical legal support so you can do business confidently and safely.

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She never managed a cent – yet she was fined by the Dutch financial regulator

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A full-service law firm

focused on companies that are engaged in (international) trade and innovation.

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Labour Law

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Tenancy Law And Real Estate

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Procedural Law And Mediation

Tech, Data & Transactions

Products or software on the EU-market? Stricter product liability from 9 December 2026, including for importers

Products placed on the market on or after 9 December 2026 are subject to new EU product liability rules, which also cover software, apps and AI. If a defective product causes personal injury or damage to private property or private data. If the manufacturer is established outside the EU, the importer may also be liable. A defect caused by an update, or by a missing security update from the manufacturer, may also give rise to liability.Map your role in the distribution chain and review your contracts with suppliers and customers carefully to limit your liability exposure.

Dutch Wtta from 1 January 2027: do you hire out or hire in staff?

On 1 January 2027, the Dutch Act on the Admission of Labour Providers (Wet toelating terbeschikkingstelling van arbeidskrachten, Wtta) enters into force. Any business that places workers with another business in the Netherlands will need authorisation from the Dutch Labour Supply Authority (NAU). The Netherlands Labour Authority will enforce the rules from 1 January 2028.The Act reaches beyond temporary employment agencies: secondment firms, payroll companies and employers that occasionally lend out staff may also be caught. Hirers have obligations too: from 2027 they must keep records, and from 2028 they may only hire workers through an authorised provider.

EU AI Act amended: high-risk rules postponed, but 2 December 2026 stands

On 27 July 2026, the EU Digital Omnibus on AI entered into force. As a result, the rules for high-risk AI, such as AI used in recruitment or credit scoring, apply only from 2 December 2027. For AI embedded in products such as machinery and medical devices, the date is 2 August 2028. SMEs and small mid-caps benefit from lighter documentation requirements.Postponed does not mean cancelled. From 2 December 2026, AI that generates intimate images without consent is prohibited, and providers of generative AI already on the market must label AI-generated content.

Could you suddenly qualify as a creditor under the new European Directive?

Do you offer consumers deferred payment, payment in instalments or another form of credit? If so, the implementation of the Consumer Credit Directive II (CCD2) may have consequences for your business model and compliance obligations.CCD2 broadens the European framework for consumer credit. Buy Now, Pay Later providers and certain crowdfunding platforms, among others, will be brought within the scope of the new rules. As CCD2 is a directive, the new rules must first be implemented in Dutch legislation. For businesses, it is therefore important to assess now whether their products or services will fall under the new rules.