NOW 2.0 program - Key takeaways

The details of the NOW 2.0 program have been disclosed. Below we summarize the key takeaways for your consideration. Please reach out to our corona crisis team for assistance and guidance.


  • Application as of July 6 until August 31, 2020 via
  • In principle electronic filing, it is recognized that filing in writing could be preferable in some situations (BOL: for example in case of a foreign bank account).
  • Final determination of compensation is possible as of November 15, 2020.


  • Turnover loss 20% on group level (similar to NOW 1.0).
    o Entity level possible:
    o Prohibition on divided payments over 2020
    o Prohibition on bonusses to directors or management
    o Accountant’s report required for the final determination
  • Four-month period (NOW 1.0 three-month period):
    o June, July, August, September
    o July, August, September, October
    o August, September, October, November
    o In case of application NOW 1.0: no choice possible but consecutive to NOW 1.0-period!
  • Reference period is 1/3 of 2019


  • Basis:
    o 90% Wage bill March 2020 (status of May 15) capped at € 9.538
    o In case March wage bill is not present; November 2019
    o 80% as an advance payment in two terms (NOW 1.0 in three terms) within 13 weeks decision
  • Advance payment of € 100,000 or final compensation of € 125,000:
    o Accountant’s report required for the final determination
    o Extended filing for final subsidy (38 weeks instead of 24 weeks)
    o Prohibition on dividend payments over 2020 and purchase of own shares
    o Prohibition on bonusses to directors or management
    • Broad scope: all policy makers
    • Bonusses to other staff (remunerated via such variable payments) are allowed
  • Advance payment of € 20,000 or final compensation of € 25,000:
    o Third-party statement required for the final determination
  • Surcharge 40% (NOW 1.0 30%)
  • No additional penalty/correction of compensation under NOW 2.0 program for dismissal of personnel (except in case of ≥ 20 employees)

Other remarks

  • Many employees are currently working less (or not at all) and have to prepare for another way of working or other type of work. Under NOW 2.0, employers have the obligation to facilitate and support employees to request development advice or participate in training.
  • For dismissal of 20 or more employees additional rules apply.

Contact our Corona Crisis Team »

24 June 2020