If 1 January 2023 is not met, the Netherlands will receive a notice of default and the Netherlands will be given another opportunity to comply with the obligation as soon as possible. There are currently no financial consequences in the form of a fine. If the new entry into force date is not resolved, a case can be brought before the Court of Justice. During this process, the European Commission can request the court to impose a penalty on the Netherlands, which will then be reduced to 1 January 2023.
Source: taxence.nl