New Circle8 policy as of 1 January 2026
Shift in risk and responsibility, with consequences for suppliers
Circle8's clients increasingly require Circle8 to keep the chain of work as short as possible and to carry out compliance checks itself. In practice, this means Circle8 bears the (compliance) risks and must carry out the additional processes and administration, rather than relying on third parties to do so. On top of that, the new SNA standard places full responsibility for the chain on the certified party. For this reason, Circle8 is introducing a new policy for sub-lending (doorleen) constructions as of 1 January 2026. The renewed policy shortens the chain and offers the client transparency and reduced risk.
What changes after 1 January 2026?
The intermediary party/supplier shifts the (compliance) risk to Circle8.
The administrative workload shifts from the intermediary party/supplier to Circle8.
The new SNA standard (version 2025.05) places full responsibility for the chain of work on the certified party.
As an additional service, the intermediary party/supplier proactively receives the declared hours of the relevant professional for invoicing purposes.
To sustain this extra administrative work and fully cover the risk for Circle8, Circle8 is introducing a processing fee of 1 euro per hour as of 1 January 2026 (the fee may vary per client).
Impact of the SNA standard on non-certified chain partners
The new SNA standard (version 2025.05) places full responsibility for the chain on the certified party. This has two key implications for suppliers/brokers without SNA certification:
Risk of exclusion: Certified clients/MSPs, such as Circle8, must exclude partners without SNA certification. The standard explicitly requires that partners in the "intermediation" chain also hold the certification. Engaging a non-certified partner is a direct violation for the certified client.
Shift in inspection risk: Auditors will check whether engaged partners comply. A shortcoming at the non-certified partner leads to a non-conformity for the certified client. This makes the non-certified partner a "liability risk," which greatly increases the pressure to obtain the certification after all.
Conclusion: Due to the risks associated with the relevant hiring via sub-lending constructions, and the tightened SNA guidelines, Circle8 is taking on the responsibility to contract the assignments directly. As a result, as of 1 January 2026, all sub-lending parties will be contracted through a margin agreement.
