VOG for technicians in refrigeration engineering: when is it requested, when is it mandatory?

A technician who enters a private individual's home to install an air conditioner or heat pump literally comes through the front door. So it's not a strange question you get as an installation company: from a customer, a client in a tender, or simply from a new technician themselves — "do I need a VOG?" The short answer: there is no general legal VOG requirement for refrigeration engineering technicians. But that doesn't mean you'll never encounter it. Below is the difference between what's legally required, what a client may require, and how you arrange such an application in practice.

What exactly is a VOG?

A Verklaring Omtrent het Gedrag (VOG) is a document from Justis, part of the ministerie van Justitie en Veiligheid, showing that someone's criminal record poses no objection to carrying out a specific role or task. In doing so, Justis does not screen someone's entire criminal record in a general sense, but tests that record against a screening profile tailored to the role: which risks belong to this work, and what kind of offences would be a problem in that context.

A VOG has no fixed legal period of validity — the assessment is a snapshot in time. Whether a VOG needs to be "fresh enough" is decided by the party requesting it (for example: no older than three months), not by the law.

Is a VOG legally required for refrigeration engineering technicians?

No, not in a general sense. A legal VOG requirement only applies to a limited group of roles that the legislator has specifically designated — think of teachers, childminders and taxi drivers. Technicians in refrigeration engineering, HVAC or installation engineering are not on such a legal list.

Outside those legally required roles, the following applies: if there is no legal requirement, an employer (or client) may decide for itself whether it sets a VOG as a requirement for a particular role or assignment. For refrigeration engineering technicians, a VOG is therefore in practice always a choice made by a specific party, never a nationwide legal requirement. Note: this is a conclusion based on the official VOG information from Justis and Ondernemersplein, which do not mention refrigeration engineering/HVAC as a legally required sector — we have not found an exhaustive, explicit exclusion for this industry. If you're unsure about a specific situation, check directly with Justis.

So when does a client ask for a VOG after all?

Even without a legal requirement, you do encounter a VOG requirement in refrigeration engineering fairly often in practice, for example with:

• A cao provision that prescribes a VOG for certain roles
• The company's own policy, for example because the company structurally enters the homes of private individuals or vulnerable groups
• An assignment for a housing association, care institution, educational institution or municipality that sets as a condition that technicians who enter the building can produce a valid VOG
• A tender in which the client sets contractual requirements for the personnel carrying out the work

In short: no law requires it, but a specific customer or contract partner can indeed set it as a condition. So check this per assignment/contract instead of assuming a nationwide rule.

VOG versus Gedragsverklaring Aanbesteden (GVA) — not the same thing

In tenders you sometimes encounter another document that resembles a VOG but is not one: the Gedragsverklaring Aanbesteden (GVA). A GVA is applied for by an authorised representative (for example a director or proxy holder) on behalf of the legal entity (the company), and serves to demonstrate that the company has not been convicted of certain offences that would justify exclusion from a tender. A VOG, by contrast, is tied to an individual person and concerns an individual technician. So don't confuse the two if a client in a tender process asks for a "declaration" — check exactly which of the two is meant.

How do you, as an employer, apply for a VOG for a technician?

If you as an installation company decide to require a VOG (or a customer asks it of you), the application usually works as follows:

• The employer sets up the application digitally via MijnJustis, using eHerkenning (level 2+, with VOG authorisation)
• In doing so, you choose a screening profile that fits the role — which risk areas and job aspects are relevant to the technician's work
• The technician (employee) automatically receives an e-mail, checks the details and completes the application using DigiD and iDEAL
• Alternative: a paper application, in which the employer and employee together fill in a form that the employee then submits at the municipality (requires registration in the BRP)
• For technicians without a fixed home or residential address in the Netherlands, the application runs directly via Justis

What does a VOG cost and how long does the application take?

According to Justis you pay €33.85 (VAT-exempt) if the employer sets up the application digitally, or €41.35 (VAT-exempt) for a paper application via the municipality or a direct application to Justis. These amounts are subject to change by Justis — check the current rates at justis.nl before starting an application.

Justis itself states that most applications are processed within 1 to 4 weeks, with a legal maximum decision period of 8 weeks if additional investigation is needed. There is no guarantee of the shorter period, so plan an application well before the start date of a new technician or an assignment.

Practical advice for installation companies

• Don't require a VOG as standard "because it's the done thing" — first check whether your cao, a specific client or a tender actually asks for it
• Record per assignment whether a VOG was required, and keep a copy in the technician's personnel file. This fits with how you keep track of staff certificates and diplomas anyway — see also Technician leaving employment: what do you need to arrange for certificates and the BRL 100 personnel file?
• Do you work with sole traders who enter the homes of private individuals? No automatic VOG requirement applies to them either, but a client can still ask for it — see Sole trader in refrigeration engineering: which certificates and insurance do you need?
• A VOG says something about a criminal record, not about professional competence or liability — make sure your business insurance is in order separately from that, see Public liability insurance for refrigeration engineering companies
• If you're unsure about a specific situation (for example: a client requires something you can't make sense of), check directly with Justis or with the client themselves what exactly is meant and why