Discussion around the DBA Act (Deregulation of Employment Relationships Act) flares up periodically. With enforcement having come into effect in 2025, many organisations are wondering what this means for their use of self-employed finance professionals. In practice, however, the market for self-employed financial professionals remains robust.

What the law says
The DBA Act replaces the former VAR declaration and places responsibility for the correct classification of the employment relationship on both client and contractor. The central question is: is there bogus self-employment? In other words: is someone effectively working as an employee but engaged as a self-employed professional?

Why demand for interim professionals persists
Organisations have a structural need for flexible, high-quality finance capacity. For projects such as ERP implementations, post-merger integrations, restructurings or temporarily covering a CFO vacancy, an interim professional is the appropriate solution. That need does not disappear because of legislation — what changes is the way contracts are structured and monitored.

How organisations are responding
An increasing number of clients are working with framework agreements reviewed by an employment lawyer, in which the assignment is described with sufficient specificity to meet DBA criteria. The key lies in safeguarding genuine independence: no authority relationship, freedom over working hours and use of one's own resources.

The role of Blooming Hill
We also facilitate interim finance placements and guide both clients and candidates in establishing the right contractual structure. We work exclusively with professionals who operate through their own private limited company and have demonstrable experience at management or board level. This ensures placements that remain sound under the new enforcement reality.