COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report Country Chapter on the rule of law situation in Belgium Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Rule of Law Report The rule of law situation in the European Union

EN EN
EUROPEAN
COMMISSION
Strasbourg, 8.7.2025
SWD(2025) 901 final
COMMISSION STAFF WORKING DOCUMENT
2025 Rule of Law Report
Country Chapter on the rule of law situation in Belgium
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
2025 Rule of Law Report
The rule of law situation in the European Union
{COM(2025) 900 final} - {SWD(2025) 902 final} - {SWD(2025) 903 final} -
{SWD(2025) 904 final} - {SWD(2025) 905 final} - {SWD(2025) 906 final} -
{SWD(2025) 907 final} - {SWD(2025) 908 final} - {SWD(2025) 909 final} -
{SWD(2025) 910 final} - {SWD(2025) 911 final} - {SWD(2025) 912 final} -
{SWD(2025) 913 final} - {SWD(2025) 914 final} - {SWD(2025) 915 final} -
{SWD(2025) 916 final} - {SWD(2025) 917 final} - {SWD(2025) 918 final} -
{SWD(2025) 919 final} - {SWD(2025) 920 final} - {SWD(2025) 921 final} -
{SWD(2025) 922 final} - {SWD(2025) 923 final} - {SWD(2025) 924 final} -
{SWD(2025) 925 final} - {SWD(2025) 926 final} - {SWD(2025) 927 final} -
{SWD(2025) 928 final} - {SWD(2025) 929 final} - {SWD(2025) 930 final} -
{SWD(2025) 931 final}
Offentligt
KOM (2025) 0900 - SWD-dokument
Europaudvalget 2025
1
ABSTRACT
The level of perceived judicial independence in Belgium continues to be high. The
Government maintains the intention to transfer budgetary management powers for the
administration of the justice system from the executive to the judiciary. Following the
adoption of directives prohibiting the recording of meetings between lawyer and clients,
lawyers called for additional procedural safeguards to protect legal professional privilege.
Some further steps have been taken to address the structural resource deficiencies in the
justice system, such as the publication of all open positions for magistrates and court staff,
although a long-term structural approach is required. The Government is addressing criticism
by the Court of Audit on the management of the digitalisation of justice. Some further steps
have been taken to improve the efficiency of justice, particularly to reduce the length of
proceedings based on comprehensive statistical data.
New investigative and prosecutorial structures also targeting corruption will be set up. Good
cooperation between the Central Office for the Repression of Corruption and the prosecution
service continues, although concerns exist on the handling of prominent high-level corruption
cases. Some steps are under consideration to strengthen integrity procedures in the police.
Shortcomings continue in the monitoring and enforcement of existing integrity policies, and
in the verification and transparency of asset and interest declarations. The new Government
has not yet taken a decision on whether to proceed with draft lobbying rules. The House of
Representatives slightly updated its rules on gifts and benefits, while gaps in rules on
“revolving doors” remain. Increased attention is paid to addressing high risks of corruption
both at local level and linked to organised crime.
Despite challenges, media regulatory authorities across Belgium have taken steps in adapting
their strategies while maintaining a strong legal foundation for their independence. Public
service media in Belgium face various challenges across the three communities including
governance structures and budgetary pressures. Recent legislative developments led to some
improvements regarding access to public documents, while further procedural improvements
are needed. The Government took steps to strengthen legal protections for journalists, such as
decriminalising defamation and introducing harsher penalties for crimes committed against
journalists.
The Federal Human Rights Institute raised concerns regarding the budget of the interfederal
equality body. Limited steps have been taken on ensuring compliance by public authorities
with final rulings of national courts while supervision by the Council of Europe on structural
issues identified by the European Court of Human Rights continues. Despite a high level of
protection under the law, civic space remains narrowed, and stakeholders are raising concerns
regarding new obstacles to the right to demonstrate.
2
RECOMMENDATIONS
Overall, concerning the recommendations in the 2024 Rule of Law Report, Belgium has
made:
• Some further progress on efforts to address the structural resource deficiencies in the
justice system, taking into account European standards on resources for the justice
system.
• Some further progress on efforts to improve the efficiency of justice, particularly to
reduce the length of proceedings based on comprehensive statistical data.
• Some progress on strengthening the integrity framework by adopting rules on gifts and
benefits for members of Parliament and limited progress on rules on revolving doors for
government and their private offices.
• No further progress on completing the legislative reform on lobbying, establishing a
framework including a transparency register and a legislative footprint, covering both
members of Parliament and Government.
• Some further progress on efforts to strengthen the framework for access to official
documents, in particular by improving request and appeal processes, taking into account
European standards on access to official documents.
• Limited progress on measures to ensure compliance by public authorities with final
rulings of national courts and the European Court of Human Rights.
On this basis, and considering other developments that took place in the period of reference
and in addition to recalling the relevant commitments made under the national Recovery and
Resilience Plan, it is recommended to Belgium to:
• Continue ongoing efforts to address the structural resource deficiencies in the justice
system, taking into account European standards on resources for the justice system.
• Continue ongoing efforts to improve the efficiency of justice, particularly to reduce the
length of proceedings based on comprehensive statistical data.
• Strengthen the integrity framework, including by adopting rules on gifts and benefits for
members of Parliament and rules on revolving doors for government and their private
offices.
• Complete the legislative reform on lobbying, establishing a framework including a
transparency register and a legislative footprint, covering both members of Parliament
and Government.
• Further continue efforts to strengthen the framework for access to official documents, in
particular by improving request and appeal processes, taking into account European
standards on access to official documents.
• Take measures to ensure compliance by public authorities with final rulings of national
courts and the European Court of Human Rights.
3
I. JUSTICE SYSTEM 1
Independence
The level of perceived judicial independence in Belgium continues to be high among the
general public and among companies. Overall, 64% of the general population and 72% of
companies perceive the level of independence of courts and judges to be ‘fairly or very good’
in 20252
. The perceived judicial independence among the general public has increased in
comparison with 2024 (61%) and has slightly decreased in comparison with 2021 (66%). The
perceived judicial independence among companies has significantly increased in comparison
with 2024 (64%), as well as in comparison with 2021 (58%).
The Government maintains its intention to transfer budgetary management powers for
the administration of the justice system from the executive to the judiciary3. Once the
transfer is completed, the governing bodies of the three ‘pillars’ of the judiciary (the Entity
Cassation for the Court of Cassation, the College of Courts and Tribunals and the College of
Public Prosecutors) will be directly responsible for managing staff budgets and policy4
.
Discussions continue on the exact details of the transfer. Prior to the transfer, consideration
will be given to how the framework for the allocation of court staff and magistrates can be
improved5
, for instance based on regular workload measurements6
. According to the
Government, this increase in managerial autonomy of the judiciary cannot be established
without a reform of the evaluation and disciplinary system7
. The High Council for Justice and
Court of Cassation have however criticised the Government for making the link between
efficiency and disciplinary issues8
.
Following the adoption of directives prohibiting the recording of meetings between
lawyer and client, lawyers called for additional procedural safeguards to protect legal
professional privilege. As reported in the 2024 Rule of Law Report, directives prohibiting
the recording between lawyers and clients have strengthened lawyer-client confidentiality9
.
The Government highlighted the need for certain limitations to legal professional privilege to
uphold the public interest (for example whistleblower protection)10
. Bar Associations,
however, called for additional procedural safeguards. In particular, they consider that the
investigating judges who decide on whether lawyer-client communication is confidential (and
should therefore be excluded from the case file) should not handle the same case on
1
An overview of the institutional framework for all four pillars can be found here.
2
Figures 50 and 52, 2025 EU Justice Scoreboard and Figures 49 and 51, 2023 EU Justice Scoreboard. The
level of perceived judicial independence is categorised as follows: very low (below 30% of respondents
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%).
3
Coalition agreement, p. 158.
4
2024 Rule of Law Report Belgium, p. 4. The autonomous management of human resources would include
decisions on the transfer of magistrates and court staff.
5
Country visit Belgium, Government.
6
Country visit Belgium, Court of Cassation.
7
Coalition agreement, p. 159; The Government indicates that the Guidelines on the evaluation of the quality
of work of judges, adopted by the European Commission for the Efficiency of Justice (CEPEJ) in
December 2024, could serve as a valuable source of inspiration; Country visit, Government.
8
Country visit Belgium, High Council for Justice, Court of Cassation. The Court of Cassation points to the
risk of seeking to remedy the efficiency of the judiciary in general through the evaluation of individual
judges.
9
2024 Rule of Law Report Belgium, p. 6.
10
Belgian Government (2025), written input, pp. 6, 7.
4
substance11
. Bar Associations and the Court of Cassation furthermore criticised the use of
videoconferencing in civil and criminal cases, for its possible negative impact on lawyer-
client confidentiality12
. Bar Associations also raise concerns about public criticism of the
judiciary and lawyers by some politicians, which they see as undermining their fundamental
role in upholding the rule of law13
.
Quality
Some further progress has been made to address the structural resource deficiencies in
the justice system, such as the publication of all open positions for magistrates and court
staff, although a long-term structural approach is required14. The budget spent on the
justice system and the number of professional judges per 100 000 inhabitants remain below
the EU average15
, and as Belgium had a caretaker Government between June 2024 and
February 2025, no additional budgetary resources could be provided in this period. The new
Government exempted the judiciary from budget cuts16
. Moreover, there was a 5% increase
in the number of judges and public prosecutors between 2020 and 202417
, and publication of
all open positions for magistrates and court staff, although a significant number of those
vacancies could not be filled18
. In this regard, the Court of Cassation and High Council for
Justice point to the salaries not being sufficiently attractive and to challenging working
conditions in the judiciary19
. Bar Associations furthermore regret the abolition of the
privilege of jurisdiction for lawyers performing as substitute judges20
, considering the
willingness of many lawyers to remedy the shortage of judges by performing as a substitute21
.
While acknowledging the efforts made, the Committee of Ministers of the Council of Europe
has repeatedly called for a long-term structural perspective on the budget for the justice
11
CCBE (2025), written input, p. 21.
12
Law of 25 April 2024 organising hearings by videoconference in judicial proceedings; A survey conducted
amongst lawyers and judges in juvenile delinquency cases (where videoconferencing was already applied)
shows that 86% of participants did not consider the communication to be confidential. Country visit, Bar
Associations, Court of Cassation.
13
CCBE (2025), written input, p. 21.
14
The 2024 Rule of Law Report recommended Belgium to ‘continue efforts to address the structural resource
deficiencies in the justice system, taking into account European standard on resources for the justice
system’.
15
Figures 34 and 37, 2025 EU Justice Scoreboard.
16
The Council of State, however, was not exempted. The Council expressed concern that the Government
continues to link additional resources for the judiciary to the prioritisation of certain cases which, according
to some stakeholders, may lead to an additional backlog in other areas and affect citizens’ (equal) access to
justice. Country visit, Council of State.
17
Country visit Belgium, Government.
18
Country visit Belgium, Court of Cassation.
19
Reference is made to the physical working conditions and the intended lowering of pensions of magistrates;
Country visit, Court of Cassation; High Council for Justice (2025), written input, p. 10; On 27 June 2024
the first president of the Court of Cassation and the first presidents of the courts of appeal and labour courts,
the Prosecutor General at the Court of Cassation, the Prosecutors General at the courts of appeal, and the
federal prosecutor adopted a declaration calling on the Government and Parliament to fully recognize the
judiciary as a power of the State and providing it with the necessary funding to ensure quality justice;
Declaration by representatives of the judiciary (2025).
20
This privilege entails that a complaint with civil action against judges is not possible, that they cannot be
prosecuted directly by an aggrieved party and that prosecution must take place before a higher court. The
Government’s justification for abolition was that the current system of jurisdictional privileges for judges is
no longer adapted to reality. Some positions have been excluded, such as legal referendaries at the Court of
Cassation or the Constitutional Court, and retired judges.
21
CCBE (2025), written input, p. 20.
5
system and judicial staff22
. Overall, some further progress has been made on the 2024
recommendation.
The Government is addressing criticism by the Court of Audit regarding the
management of the digitalisation of justice. In December 2024, the Belgian Court of Audit
reported some serious shortcomings in the digitalisation strategy of the department of justice.
These include a lack of an overarching approach, inefficient use of resources and an
excessive reliance on external consultants, as well as a lack of oversight creating fraud
risks23
. The Government sent an initial action plan to the Court of Audit on 2 September 2024
in response to its draft recommendations. It indicates that many actions have already been
initiated or finalised to improve the governance, coordination, (financial) accountability and
exclusion of fraud risks24
. The Bar Associations call for one centralised point of contact
within the Justice Ministry that monitors the vision and progress of the digitalisation projects
together with the justice actors25
.
Efficiency
Some further progress has been made to improve the efficiency of justice, particularly
to reduce the length of proceedings based on comprehensive statistical data26. Length of
proceedings and the judicial backlog in Belgium are long-standing problems27
. On 28
November 2024, the High Council for Justice published an additional report on the Court of
Appeal of Brussels, where backlogs and processing time remain very problematic28
. A
comprehensive overview of the efficiency of justice remains unavailable due to a persistent
lack of data on court proceedings. The College of Courts and Tribunals is carrying out further
efforts on the issue of statistics and the mapping of the backlog of court cases. At the
beginning of 2025 it published data on the duration of criminal cases dealt with by the appeal
courts29
. A file management project funded under the Recovery and Resilience Facility will
facilitate the further collection of statistics30
. The disposition time in civil and commercial
cases at first instance courts was 246 days in 2023. No data were available for previous years.
The estimated time to resolve administrative cases at first instance courts increased (360 days
in 2023 compared to 288 in 2022)31
. The Government indicates that the creation of chambers
22
Council of Europe, Committee of Ministers (2024a); Belgian Government (2025), written input, p. 6;
Country visit Belgium, Court of Cassation.
23
Court of Audit (2024).
24
Country visit Belgium, Government. In general, judges and prosecutors can work remotely and make use of
an electronic case management system. Areas identified for improvement include the use of electronic
communication tools, digital solutions to initiate and follow court proceedings, online access to published
judgments and machine-readable judicial decisions.
25
Country visit Belgium, Bar Associations.
26
The 2024 Rule of Law Report recommended Belgium to ‘strengthen efforts to improve the efficiency of
justice, particularly to reduce the length of proceedings’.
27
Group of cases Bell (No. 44826/05) (ENHA): Excessive length of civil and criminal proceedings, in
particular in the judicial area of Brussels (see judgment Van Den Kerkhof, No. 13630/19) (violations of
Article 6 § 1).
28
The Report contains recommendations to improve productivity and ways to reduce the inflow of new cases;
High Council for Justice, Supplementary report audit of Brussels Court of Appeal, 28 November 2024.
29
Prior efforts were reported on in the 2024 Rule of Law Report, Belgium, p. 10.
30
Belgian Government (2025), written input, p. 3; Country visit Belgium, Government.
31
Figures 5 and 7, 2025 EU Justice Scoreboard.
6
for the amicable settlements of cases should also help to further reduce backlogs32
. Overall,
some further progress has been made on the 2024 recommendation.
II. ANTI-CORRUPTION FRAMEWORK
The perception among experts, citizens and business executives is that the level of
corruption in the public sector remains relatively low. In the 2024 Corruption Perceptions
Index by Transparency International, Belgium scores 69/100 and ranks 9th
in the European
Union and 22nd
globally33
. This perception of the level of corruption has significantly
increased34
over the past five years. The 2025 Special Eurobarometer on Corruption shows
that 59% of respondents consider corruption widespread in their country (EU average 69%)
and 18% of respondents feel personally affected by corruption in their daily lives (EU
average 30%). As regards businesses, 54% of companies consider that corruption is
widespread (EU average 63%) and 30% consider that corruption is a problem when doing
business (EU average 35%). Furthermore, 49% of respondents find that there are enough
successful prosecutions to deter people from corrupt practices (EU average 36%), while 40%
of companies believe that people and businesses caught for bribing a senior official are
appropriately punished (EU average 33%)35
.
New investigative and prosecutorial structures will be set up, with corruption being an
important target. The new Government intends to create a new financial investigation
service (to be named FIOD-SRFF36
) and a new specialised prosecution service focused on
financial crime and corruption, which would be established within current prosecutorial
structures37
. This frames within an overall “follow-the-money” approach targeting organised
crime38
. Detailed proposals are still forthcoming, also as regards the exact division of
competencies, as discussions remain ongoing between government and prosecution
services39
.
Good cooperation between the Central Office for the Repression of Corruption and the
prosecution service continues, although some concerns exist on the handling of
prominent high-level corruption cases. Good cooperation between the Central Office for
the Repression of Corruption (CDBC-OCRC) and the prosecution service continues, as does
work on several complex and high-level corruption cases. The prosecution is still developing
specific guidance for prosecutors in the area of economic and fiscal crime40
. Civil society
32
Belgian Government (2025), written input, p. 3; Act of 19 December 2023 containing various provisions on
civil and judicial matters.
33
The level of perceived corruption is categorized as follows: low (above 79); relatively low (between 79-60),
relatively high (between 59-50), high (below 50).
34
In 2020 the score was 76, while, in 2025, the score is 69. The score significantly increases/decreases when
it changes more than five points; improves/deteriorates (changes between 4-5 points); is relatively stable
(changes from 1-3 points) in the last five years.
35
Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025).
36
Fiscale en Financiële Opsporingsdienst / Service de Recherche Fiscal et Financier. See Ministry of Justice
(2025a) and Ministry of Justice (2025b), p. 32.
37
Belgian Government (2025a), pp. 128-129 and p. 154 and Country visit Belgium, public prosecution
service.
38
Ministry of Justice (2025a).
39
Ministry of Justice (2025a).
40
Public prosecution service (2025a) and 2024 Rule of Law Report, Belgium, pp. 13-14.
7
raises concerns over the resources of law enforcement and prosecution41
. Allegations of
information leaks in sensitive corruption investigations and undue political influence related
to the work of the CDBC-OCRC are a cause of concern42
and, according to civil society,
could impact the trust of the public in the CDBC-OCRC43
. In response to these allegations,
law enforcement reaffirms the independence of the CDBC-OCRC as enshrined in law44
. In
2024, the prosecution signalled 367 incoming corruption cases45
, of which 90 were
dismissed, while 7 cases led to an indictment (by January 2025)46
. The EPPO has signalled
seven corruption cases among its open cases (which consists of 5.1% of its total open cases)
in 2024 in Belgium47
. The investigation and prosecution of foreign bribery cases continue to
be limited. A new report of the OECD criticises in particular the low number of
investigations and prosecution of foreign bribery cases, the low awareness within companies
on the risks of foreign bribery as well as a lack of investigations and low sanctions
specifically targeting legal persons.48
. The prosecution reported only four cases of foreign
bribery registered between 2022 and 202449
.
Some improvements on police integrity are under consideration to address challenges in
preventing corruption within the police. The 181 local police zones maintain disparate
integrity policies and smaller police zones are not maintaining an effective integrity policy50
.
The authorities did not move forward on a Code of Conduct for the entire integrated police,
as recommended by GRECO51
, and overall, the police integrity policy is assessed as
insufficient by stakeholders52
. Nevertheless, several actions are envisaged to address the risk
of corruption within the police. The new Government announced it will allow voluntary
mergers of local police zones so they can operate at a larger scale, which may also create
possible opportunities to improve integrity policy. There are plans to introduce screening and
integrity checks during the entire career of a police officer, a proposal that had previously not
moved forward.53
Committee P has overall signalled a lack of attention to integrity during the
recruitment, selection and training of new police officers54
.
41
In particular considering the increasing number of complex cases. Country visit Belgium, Transparency
International and 2024 Rule of Law Report, Belgium, pp. 13-14.
42
The acting chief of the CDBC/OCRC was questioned and his offices searched by the General Inspection
following allegations of information leaks. Following that, complaints were filed with Committee P
concerning political interference into the investigations led by CDBC/OCRC by superiors of overarching
departments. Investigations remain ongoing.
43
Country visit Belgium, Transparency International.
44
Ministry of Justice (2025a).
45
Out of which 6 concerned corruption in the private sector, with 361 related to the public sector (including
102 cases related to bribery in the public sector and 82 related to abuse of function in the public sector).
46
Others remain at various stages of the criminal procedure. Public prosecution service (2025a).
47
EPPO (2025a), p. 16.
48
A clear strategy on combating foreign bribery and sufficient resources for the investigative and
prosecutorial bodies are recommended. There are no measures that promote self-investigation and self-
reporting of companies. OECD (2025), pp. 7-8.
49
One in 2022; one in 2023 and two in 2024. Public prosecution service (2025a).
50
As reconfirmed by Federal Police (2025a). See also 2023 Rule of Law Report, Belgium, pp. 10-12.
51
Federal Police (2025a) and GRECO (2022), recommendation xvi, paras 75-81. See also 2022 Rule of Law
Report, Belgium, p. 10.
52
Country visit Belgium, Committee P and 2024 Rule of Law Report, Belgium, pp. 14-15.
53
Belgian Government (2025a), p. 139 and pp. 141-142 and Country visit Belgium, Committee P.
54
Committee P (2024); Country visit Belgium, Committee P and Federal Police (2025a). Committee P
expects to publish recommendations on this topic in the future.
8
There is still a lack of monitoring and enforcement of existing integrity policies
concerning Ministers, their private offices and members of Parliament. Gaps remain in
existing integrity policies55
, particularly due to the absence of any monitoring and
enforcement mechanism56
. Increased checks on the application of the Code of Conduct for
federal public office holders are a priority of the new Minister of Public Administration.
However, in the absence of a monitoring mechanism, it is unclear how these checks will be
carried out in practice57
. Training and awareness raising in relation to integrity remain to be
enhanced.58
. The Federal Deontological Commission has voiced concerns that powers
concerning integrity policy are dispersed across various bodies and recommended that its
own role as an advisory body be strengthened.59
As regards the federal civil service, the
Integrity Bureau continues the work with the Federal Network of Integrity Coordinators with
all Ministries now having established an Integrity Coordinator60
.
The system of asset and interest declarations has shortcomings in terms of verification
and transparency. As outlined in previous Rule of Law Reports, the system of asset
declarations does not ensure adequate verification and transparency, as the Court of Audit
receives the declarations in sealed envelopes and declarations are only accessible by
investigating judges in the context of criminal investigations61
. Parliament declared its
intention to work towards more comprehensive rules on declarations of parliamentarians’
assets over the long term62
, but no immediate plans by either Government or Parliament were
tabled63
. Compliance with the requirement to submit declarations is very good with 99% of
those required to do so64
submitting their assets and mandates declarations on time. Due to a
lack of adequate verification, the correctness of these declarations remains solely the
individual responsibility of the person declaring them65
. Civil society organisations continue
to criticise the lack of transparency of asset declarations as well as the set-up of the whole
system66
.
55
The updated Code of Conduct for federal public office holders remains in place and since 2023 covers all
staff members of the Federal Government (i.e. including the ministerial private offices). A specific Code of
Conduct remains in force for Ministers, as these are not covered in the Code of Conduct for federal public
office holders. 2024 Rule of Law Report, Belgium, pp. 15-16.
56
As recommended multiple times by GRECO – a number of GRECO recommendations remain
unimplemented. GRECO (2022a), recommendation iii and paras. 115-120 and GRECO (2022b), paras. 60-
62.
57
Ministry of Public Administration (2025), p. 19.
58
Country visit Belgium, Federal Deontological Commission.
59
Federal Deontological Commission (2025) and Country visit Belgium, Federal Deontological Commission.
60
The first round of Integrity Action Plans from all Ministries was received in 2024. Belgian Government
(2025a), p. 9 and Country visit Belgium, Integrity Bureau.
61
2024 Rule of Law Report, Belgium, pp. 16-17.
62
Ministry of Justice (2025a).
63
This remains subject to an open GRECO recommendation. Asset Declarations are submitted in closed
envelopes only accessible in the course of criminal investigations. GRECO repeated the previous remarks
(as mentioned in the 2022 Rule of Law report) from the Fifth Round Evaluation Report in its most recent
compliance report. 2024 Rule of Law Report, Belgium, pp. 16-17 and GRECO (2024a), recommendations
xii and xiii.
64
538 persons out of 543 required to submit asset declaration, 9 543 out of 9 568 persons required to submit
mandate declarations. Court of Audit (2025).
65
Court of Audit (2025).
66
Country Visit Belgium, Transparency International and Cumuleo (2025).
9
There has been no further progress on completing the reform of lobbying legislation as
the new Government has not yet taken a decision on draft lobbying rules for
Government members67. The previous Government had presented a draft law and decree68
envisaging rules for contacts between lobbyists and members of the federal executive69
and it
had also gathered advice from the Council of State and the Data Protection Authority70
. The
new Government is now examining these drafts and has yet to decide whether it would
continue with this reform71
. Civil society does not expect a decision soon and has criticised
the Government lacking ambition in this area72
. The outgoing Parliament had committed to
its own reform using similar definitions as the Government to avoid duplication of
registrations73
, but it is unclear whether the new Parliament intends to take the same
approach. As no further steps have been taken by either Government or Parliament, there has
been no further progress on the recommendation made in the previous years.
There has been some progress in relation to the rules on gifts and benefits for members
of Parliament through a minor update of the House’s Deontological Code74. Members of
both the Senate and House of Representatives are covered by a general prohibition on
receiving gifts in return for actions taken in the course of their mandate75
. In line with advice
from the Federal Deontological Commission, the House of Representatives clarified an
inconsistency between its Deontological Code and the applicable legislation on political party
financing in March 2024, ensuring that donations of citizens to a political party are not
classified as gifts76
. Shortcomings identified in previous Rule of Law Reports77
have not been
fully addressed as there is no concrete guidance to members of Parliament on what type of
gifts would be acceptable (i.e. a monetary threshold). Information about gifts accepted and
their origin is not registered, and, as a consequence, also not visible to the public. While there
is a stated intention of both Houses of Parliament to further address these issues, no further
concrete actions or texts were tabled, and the House of Representatives explicitly decided not
to introduce a gifts register78
. Ministers and members of ministerial private offices remain
covered by separate policies on gifts79
, while the Federal Deontological Commission
continues to offer individual advice – upon request – to Members of Parliament, Government
and high public office holders on potential conflicts of interest. Given some efforts to clarify
the rules for members of Parliament regarding gifts and benefits for members of Parliament,
67
The 2024 Rule of Law Report recommended to Belgium to ‘complete the legislative reform on lobbying,
establishing a framework including a transparency register and a legislative footprint, covering both
members of Parliament and Government’.
68
The draft law regulates the substance of the reform, while the draft decree foresees the necessary rules on
data protection for data included in the transparency register.
69
Draft legislation foresees a transparency register, managed by the Prime Minister’s Office, with registration
obligations for lobbyists and all ministerial private offices. 2024 Rule of Law Report, Belgium, p. 17.
70
2024 Rule of Law Report, Belgium, p. 17.
71
Ministry of Justice (2025a).
72
Country visit Belgium, Transparency International.
73
2024 Rule of Law Report, Belgium, p. 17.
74
The 2024 Rule of Law Report recommended to Belgium to “Strengthen the integrity framework, including
by adopting rules on gifts and benefits for members of Parliament and rules on revolving doors for
government and their private offices.”
75
2022 Rule of Law Report, Belgium, pp. 12-13.
76
Belgian Government (2025), written input, p. 10.
77
2022 Rule of Law Report, Belgium, pp. 12-13.
78
GRECO (2024b), recommendation i, paras 10-14.
79
The Ministerial Code of Conduct, as adopted on 16 June 2023; and the extension of the Code of Conduct
for public mandate holders. See 2023 Rule of Law Report, Belgium, p. 16.
10
some progress has been made on this part of the recommendation of the 2024 Rule of Law
Report.
There has been limited progress on rules on ‘revolving doors’80. In a June 2024
‘circular’, the outgoing Minister of Public Administration raised attention to the risk of post-
employment conflicts of interest and ‘revolving doors’ in the federal public sector and
provided an overview of the existing measures81
. The ‘circular’ also outlined the possible
elements for implementing a preventive policy around post-employment conflicts of interest
and revolving door situations – including the existing legal prohibition of former civil
servants to be involved in public tenders in the two years following their employment82
.
While important to raise awareness on the issue, this non-binding ‘circular’ did not introduce
any new rules nor address the existing gaps for either members of Government or their
private offices or civil servants more broadly. The Federal Internal Audit Service is
conducting a thematic audit on how the various ministries and agencies within the Federal
Public Service address the issue of revolving doors in public procurement procedures83
. The
recommendations contained in the own initiative opinion of the Federal Deontological
Commission on the topic have not been taken forward by any institution84
. Therefore, as
preliminary steps were taken to address these gaps, limited progress has been made on this
part of the recommendation made in the 2024 Rule of Law Report.
There are no further plans to reform the political party financing architecture. The
outgoing Government and Parliament did not secure agreement on a reform of political party
financing, despite lengthy preparations85
and stakeholder concerns86
. Lacking such an
agreement, the new Government is not intending to further discuss the matter87
.
Whistleblower protection is largely in place whilst specific rules for certain categories of
public employees remain to be adopted. Whilst whistleblower protection rules have been
largely put in place88
, specific rules applying to employees working in the judiciary and the
state security services are still pending89
. In 2025, a law has been adopted regulating
whistleblowing protection within the House of Representatives and the Senate90. The
80
The 2024 Rule of Law Report recommended to Belgium to ‘strengthen the integrity framework, including
by adopting […] rules on revolving doors for Government and their private offices’.
81
There are some rules on ‘revolving doors’ for members of Parliament and public officials. However, these
do not include clear or binding rules regarding cooling-off periods or transitory restrictions for either
ministers, their staff, or members of Parliament.
82
Ministry of Public Administration (2024) and Belgian Government (2024), written input, p. 10.
83
Federal Internal Audit Service (2025).
84
Recommendations from the Commission include, inter alia, introducing legally binding general rules on
revolving doors, including a cooling-off period for particular high-level functions (ministers, heads of
private offices, high-level civil servants), among other measures such as lobbying bans for former ministers
and better preventative action on conflicts of interest. 2024 Rule of Law report, Belgium, pp. 18-19.
85
2024 Rule of Law Report, Belgium, p. 19.
86
2024 Rule of Law Report, Belgium, p. 19.
87
Ministry of Justice (2025a) and Belgian Government (2025a), p. 6.
88
Several separate laws, one for the private sector, one for the federal public sector, as well as laws for the
regional employees in the public sector, have been adopted in 2022, 2023 and 2024.
89
See also Country Visit Belgium, Federal Institute of Human Rights; and FIRM/IFDH (2025).
90
On 13 March 2025, the House of Representatives adopted the Private Member's bill DOC 56-0656/001
which seeks to transpose EU Directive 2019/1937 on whistleblower protection with regard to the House of
Representatives and the Senate: DOC 56-0656/005. The text adopted by the House has been sanctioned by
the King on 27 March 2025 giving it the status of a federal law. That law will be published in the Belgian
Official Gazette in due course. On 13 March 2025, the House also adopted the proposal to amend the House
11
material scope of that law has been limited to breaches of Union law in view of the
peculiarity of the parliamentary activities and to prevent abuses.91
The Federal Human Rights
Institute and stakeholders have criticised the limited scope of this law since it foresees a
narrower material scope for civil servants working in Parliament than the general regime
applicable to the civil servants working at the federal government level92
. The Federal
Ombudsperson and the Federal Human Rights Institute have issued a practical guide for
whistleblowers to help them navigate through the legislation and various systems93
. The
Federal Ombudsperson (as the external whistleblowing reporting channel) indicates that
complaints from the private sector are generally declared non-admissible (currently 87%)
because they concern issues outside the scope of the law. Moreover, whistleblowing
mechanisms for the public sector appear to function well94
.
Increased attention is paid to addressing high risks of corruption both at local level and
linked to organised crime. Businesses’ attitudes towards corruption in the EU show that
27% of companies in Belgium (EU average 25%) think that corruption has prevented them
from winning a public tender or a public procurement contract in practice in the last three
years95
. 67% perceive the level of independence of the public procurement review body
(Council of State) as very or fairly good96
. The Single Market and Competitiveness
Scoreboard on access to public procurement in Belgium reports 26% of single bids for
2023(EU average 29%). Public procurement remains an area at high risk of corruption and
stakeholders continue to signal low transparency of government contracts97
. The limited
awareness of the concept of conflict of interest at local level continues to represent an
increased risk of corruption, following a number of allegations of conflicts of interest
involving mayors and aldermen, often linked to real estate transactions, detected in the period
2022-202598
. The incoming Flemish government has made it a priority to address such
cases99
. Civil society highlights differences of auditing capacities at regional level100
. The
authorities recognise that cases of corruption concerning public officials are often linked to
organised crime groups and drug-related crimes. A type of case often cited is the
unauthorised access to databases by public officials to obtain specific data for criminal
Rules DOC 56-0657/001 which aims to harmonize the House Rules with the provisions of the
abovementioned federal law of 27 March 2025. That amendment to the House Rules has been published in
the Belgian Official Gazette on 30 April 2025.
91
See the parliamentary preparation of the law: DOC 56-0656/002, p. 4-5.
92
FIRM/IFDH (2025) and country visit Belgium, Ombudsperson, Transparency International and Federal
Institute of Human Rights.
93
Ombudsperson (2024).
94
Country visit Belgium, Ombudsperson.
95
Flash Eurobarometer 557 on Businesses’ attitudes towards corruption in the EU (2025). This is 1
percentage points above the EU average.
96
Figure 59, 2025 EU Justice Scoreboard.
97
Stichting Overheidsopdrachten (2024).
98
Separate allegations of conflicts of interest were detected in around 10 municipalities in Belgium, in
particular in Flanders, mostly involving possible conflicts of interest of mayors in relation to real estate
transactions. In at least two of these cases, the (former) mayors were convicted in a subsequent criminal
case. Audit Vlaanderen (2024), see also 2024 Rule of Law Report, Belgium, pp. 20-21.
99
Flemish Minister of Domestic Administration (2025). No corresponding information was made available by
the Walloon Region and the Brussels Region.
100
Country visit Belgium, Transparency International.
12
groups, in return for substantial payments101
. The police highlights the need for increased
screening of employees102
.
III. MEDIA PLURALISM AND MEDIA FREEDOM
Media regulatory authorities across Belgium have made progress in adapting their
strategies, while maintaining a strong legal foundation for their independence. In
Flanders, the Flemish Regulator for the Media (VRM) continues to operate as an independent
external agency with strengthened legal, financial, and operational guarantees103
. It has been
designated as a competent authority under the Digital Services Act (DSA) and will play a key
role in overseeing the European Media Freedom Act (EMFA) implementation, including in
areas such as media ownership transparency and platform regulation104
. While no new
funding has yet been allocated for EMFA implementation, VRM’s staffing was increased in
late 2023 to manage new tasks related to the DSA and other responsibilities105
. A recent legal
change also introduced a six-month extension mechanism to ensure the continuity of VRM’s
chambers, reinforcing its decision-making autonomy106
. In the French-speaking Community,
the Conseil Supérieur de l’Audiovisuel (CSA) remains an independent and adequately
resourced body107
, benefiting from increased powers under the DSA and playing a pivotal
role in the preparation for EMFA enforcement108
. The Medienrat of the German-speaking
Community has undergone significant structural reinforcement109
. In 2024, the French-
speaking Conseil de Déontologie Journalistique (CDJ) launched its first public awareness
campaign to improve recognition among the general public and highlight the importance of
ethical journalism110
. A growing point of concern is the relationship between the CDJ and the
regulator CSA111
. Although their respective competences are formally defined in the 2009
decree112
, overlapping mandates in practice have led to legal and procedural tensions
prompting a case before the Council of State113
. Ongoing discussions are being held at
ministerial level to address the articulation between journalistic self-regulation and
101
The police indicated that the main targets of bribery by drugs-related organised crime groups are the police,
customs, port and local officials. See also 2024 Rule of Law report, Belgium, p. 14.
102
Federal Police (2025a).
103
Act of 27 March 2009 on Radio and Television Broadcasting Link to the Media Decree.
104
Country visit Belgium, Belgian Government.
105
VRM (2025), written input, p. 1.
106
VRM (2025), written input, p. 4-5.
107
Belgian Government (2025), written input, second batch, p. 11: “To quote some figures, the financial
resource of the CSA is about 3,7 million euros for 2024. Their budget has increased by more than 30% in 5
years”.
108
Country visit Belgium, Government.
109
Since 2024, it directly manages its own staff, marking a notable improvement in operational autonomy. The
Medienrat has seen a substantial increase in funding and staffing Belgian authorities (2025), written input,
second batch, p. 11.
110
The Belgian press council (CDJ) launches its first campaign aimed at the general public to (re)affirm the
link between journalistic ethics and trustworthy information, CDJ website.
111
Country visit, Conseil de déontologie journalistique (CDJ) and CDJ (2025), written input, p. 5.
112
Décret du 4 fevrier 2021 relatif aux services de medias audiovisuels et aux services de partage de videos.
113
In July 2024, the CDJ joined a proceeding against the CSA before the Council of State, initiated by the
French-speaking public media RTBF. The CDJ argues that the CSA is impeding on the competences of the
CDJ - Federal Institute for the Protection and Promotion of Human Rights (2025), written input, pp. 21-22
and CDJ press statement.
13
audiovisual regulation114
. In Flanders the relationship between the Dutch-speaking Raad voor
de Journalistiek (RvJ) and the VRM is more clearly delineated and has not raised the same
issues. Greater recognition is considered crucial by the RvJ and the VRM to safeguard press
freedom and support trustworthy information in an increasingly challenging information
environment115
.
Public service media in Belgium face various challenges across the three communities
including governance structures and budgetary pressures. In Flanders, the Vlaamse
Radio- en Televisieomroeporganisatie (VRT) has received additional resources under the
2024–2029 Media Policy Plan116
. The Flemish government has reaffirmed VRT’s mandate,
with an emphasis on journalistic independence, impartiality, and editorial autonomy.
However, concerns have emerged over the composition of the new Board117
and growing
political scrutiny, including parliamentary interpellations on internal matters. VRT also cites
an increasing regulatory burden that affects its ability to remain competitive118
. In the
Wallonia-Brussels Federation, the new Government adopted a policy declaration in July 2024
that foresees an early revision of the Radio-Télévision Belge de la communauté Française
(RTBF)’s legal framework119
to refocus on public service missions such as information,
culture, and lifelong education120
. Budgetary constraints will freeze RTBF’s funding at 2024
levels until 2029, resulting in a projected EUR 78 million shortfall and a corresponding
savings plan. In the German-speaking Community, the Belgischer Rundfunk (BRF) continues
to operate under a stable framework, with its management contract extended pending new
negotiations121
. While its Board remains politically composed, BRF is open to governance
reform, including the possible introduction of independent directors, inspired by the VRT
model122
. Across all three communities, public broadcasters underline the need for regulatory
clarity, financial sustainability, and autonomy to maintain their public service remit123
. The
Media Pluralism Monitor 2025 (MPM) reports a low risk (17%) for the political
independence of public service media124
, up from an even lower level (3%) in 2024.
Recent legislative developments led to some progress regarding access to public
documents125, while procedural improvements are still needed. In 2024, a federal law
amending the 1994 framework on administrative transparency126
was adopted and partially
entered into force in July 2024. Additionally, Belgium has signed but had not ratified the
Council of Europe Convention on Access to Official Documents. However, the publication of
the federal law remains pending, and the Walloon Region has yet to adopt enabling
114
In March 2025, a meeting between the CDJ/AADJ and the Media Minister’s cabinet appeared to confirm
the Minister’s intention to invite Parliament to consider revising the 2009 decree, depending on the
forthcoming decision of the Council of State and as reported by the CDJ.
115
Country visit Belgium, Conseil de déontologie journalistique (CDJ) and Raad voor de Journalistiek (RvJ).
116
Flemish Government's 2024-2029 Policy Plan for media.
117
VVJ [The Flemish Association of Journalists] advocates essential pluralism for VRT board of directors.
118
VRT (2025), written input, p. 2.
119
Décret portant statut de la Radio-Télévision belge de la Communauté française (RTBF), 14 Juillet 1997.
120
RTBF (2025), written input, p. 1.
121
BRF (2025), written input, p. 3.
122
BRF (2025), country visit Belgium and written input, p. 1.
123
VRT, RTBF and BRF (2025), country visits Belgium and written inputs.
124
2025 Media Pluralism Monitor, country report for Belgium, p. 25.
125
2024 Rule of Law Report, Belgium, p. 2.
126
Belgian Government (2025), written input, p. 9.
14
legislation127
. While these steps mark a positive trend, stakeholders128
highlight some
persistent shortcomings. At the federal level, three parallel publicity regimes and two non-
binding appeal bodies (including a federal Commission for Access to Administrative
Documents, CADA) create uncertainty and limit effectiveness. Given their non-binding
nature, decisions issued by these bodies are often not followed by public authorities. Civil
society continues to call for simplified procedures, the merger or reform of appeal bodies, and
the empowerment of the federal CADA with binding authority, adequate resources, and
systematic publication of decisions129
. Human rights and journalists’ organisations have also
expressed concerns about what they see as unclear definitions of the offence of disclosing
state secrets in which is part of a broader revision of the Criminal Code in March 2024130
.
Government representatives, however, have defended the new provision, stating that it aims
to modernise outdated definitions and that safeguards are in place to ensure proportionality
and protect legitimate journalistic activity131
. In October 2024, journalist unions and the
Ligue des droits humains challenged this provision before the Constitutional Court, arguing
that it could criminalise public interest reporting132
. Overall, some progress has been made on
the recommendation made in the 2024 Rule of Law Report.
The Government took steps to strengthen legal protections for journalists. It notably
decriminalised defamation133
and introduced harsher penalties for crimes committed against
journalists, recognising their public interest role134
. Progress was also made on strategic
lawsuits against public participation (SLAPPs), with Belgium actively working on
transposing the EU anti-SLAPP Directive. The Minister of Justice is planning to submit a
legislative proposal transposing the EU SLAPP Directive for discussion within the
Government and, subsequently, for adoption in Parliament. The draft law proposes broad
protections, covering civil and criminal procedures, and includes support mechanisms135
. It
has been developed with input from journalist associations, using the national SLAPP
working group as a source of inspiration136
. Meanwhile, journalist associations and public
broadcasters report growing legal intimidation and political interference137
. Lawsuits
targeting major media outlets have raised concerns about press freedom and misuse of
127
The Council of Europe Convention on Access to Official Documents (CETS No. 205), also known as the
Tromsø Convention, entered into force on 1 December 2020. The bill assenting to the Council of Europe
Convention on Access to Public Documents, was unanimously adopted on 14/03/2024 in the plenary
session of the Chamber and submitted for Royal Assent. However, the law has still not been published in
the Belgian Official Gazette and the file will be handled by the new cabinet of the Minister of Security and
the Interior. Belgian Government (2025), second batch, written input, pp. 9-10
128
FIRM-IFDH, journalists associations, and Cumuleo – as expressed during the Country visit andin their
written contributions.
129
FIRM-IFDH (2025), written input, pp. 25-26.
130
FIRM-IFDH (2025), written input, pp. 27-28.
131
Belgian authorities, written input, second batch, pp. 16-17.
132
A ruling is expected early 2026.
133
Belgian Government (2025a), written contribution, p. 17.
134
The Law of 18 January 2024 officially recognizes journalists as holding a "societal role", meaning that
crimes like violence or threats committed against them can now trigger aggravated penalties, similar to
those protecting police officers or healthcare workers. This legal recognition strengthens protection for
journalists facing intimidation or attacks, Belgian authorities, written contribution, second batch, p. 17.
135
The anti-SLAPP working group has a website where notes and the draft law can be consulted.
136
The Government indicated that the working group will be once again consulted during the upcoming
processes.
137
Conseil de déontologie journalistique (CDJ)(2025), written input, p. 5; BRF (2025), written input, p.3;
FIRM-IFDH (2025), written input, pp. 23-24.
15
judicial procedures138
. The climate for journalists is reportedly becoming increasingly
difficult, particularly online and during demonstrations139
, with media outlets citing
increasing harassment, including threats and pressure targeting journalists and, in some
instances, their families140
. While initiatives like PersVeilig.be141
offer support, stakeholders
stress the need for greater institutional backing, stronger safeguards, and better law
enforcement cooperation to ensure journalists can work safely and independently. Since the
2024 Rule of Law Report, six new alerts concerning Belgium have been registered on the
Council of Europe’s Platform to promote the protection of journalism and safety of
journalists142
. The Media Freedom Rapid Response mechanism has identified 17 alerts
including threats such as SLAPPs, political interference, smear campaigns, arbitrary arrests,
cyberattacks, and restrictions on journalists’ access to events143
.
IV. OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES
Stakeholders are mostly satisfied with the opportunities to engage with policymaking.
Representatives of business associations indicate that they are generally satisfied with the
way in which they are consulted, though they are concerned about the fragmentation and
inconsistencies between the legal framework at federal and regional level144
. The Federal
Human Rights Institute also points to a complex institutional environment. It is frequently
asked by the Government or the federal Parliament to provide advice on legislative
initiatives. However, in absence of a clear obligation to consult the Institute, the frequency
and nature of this contact can vary depending on the individual office holder145
.
Over half of the companies surveyed in Belgium express confidence in the effectiveness
of investment protection. 60% of companies are very or fairly confident that investments are
protected by law and courts146
. Stakeholders confirmed that they do not see an issue with
investment protection in Belgium. As regards authorities relevant for economic operators,
53% of companies perceive the level of independence of the national competition authority
(Belgian Competition Authority) as very or fairly good147
. A number of judicial mechanisms
are in place at the level of the Council of State to ensure the implementation of administrative
court judgments, including disciplinary actions against the responsible officials, the
possibility to substitute annulled administrative acts, and to award direct and consequential
damages and compensation148
.
138
European Federation of Journalists (2024)
139
FIRM-IFDH (2025), written input, pp. 23-24
140
BRF (2025), written input, p. 2; RTBF (2025), written input, p. 2.
141
Vlaamse Vereniging van Journalisten (2024).
142
Platform to promote the protection of journalism and safety of journalists, Belgium. These include
allegations of police action involving the seizure of journalistic materials, judicial gag orders and legal
proceedings against media outlets, and political interference affecting the editorial independence of the
public broadcaster RTBF. Out of six alerts, Belgium replied to five, with one more reply expected by July.
143
European Centre for Press and Media Freedom, Media Freedom Rapid Response – Belgium.
144
Country visit Belgium, Federal Business Association.
145
FIRM-IFDH (2025), written input, p. 14.
146
Figure 54, 2025 EU Justice Scoreboard.
147
Figure 60, 2025 EU Justice Scoreboard.
148
Figure 49, 2025 EU Justice Scoreboard. The data presented reflects exclusively the mechanisms in place at
the level of the highest administrative jurisdictions; the same or other mechanisms may be in place at lower
instance administrative courts.
16
The Federal Human Rights Institute raised concerns regarding the budget of the
interfederal equality body. The Government Agreement announced a 25% budget cut to the
Interfederal Centre for Equal Opportunities and Opposition to Racism and Discrimination
(Unia)149
. FIRM-IFDH warns that this budget cut will lead to a reduced level of human rights
protection150
. The Government aims to achieve an A-status for FIRM-IFDH, which requires
establishing a structure that is competent for human rights matters across federated entities as
well as the federal level. Furthermore, the Human Rights League reiterated its call on the
Belgian authorities to make sure that all human rights monitoring bodies comply with the
Paris Principles on independence and effectiveness, especially the Data Protection Authority,
Standing Police Monitoring Committee and Policy Information Monitoring Body151
.
There has been limited progress to ensure compliance by public authorities with final
rulings of national courts, while supervision by the Council of Europe on structural
issues identified by the European Court of Human Rights continues152
. Compliance by
the Government with final rulings of national courts and orders imposing periodic penalty
payments153
remains an issue, despite a joint memorandum of the three highest courts
(Constitutional Court, Court of Cassation and Council of State) issued in July 2024 requiring
it to respect court judgments154
. In November 2024, FIRM-IFDH launched an investigation
into the non-implementation of court rulings issued against Belgian authorities155
. The
Government remains under supervision by the Committee of Ministers of the Council of
Europe on structural issues identified by the European Court of Human Rights156
. It has
engaged in this process and underlined its commitment to remedy the violation found both at
individual and general level in judgments of the European Court of Human Rights without
delay, as specified in the action plans which are periodically updated and sent to the
Committee of Ministers157
. However, in September 2024, the Committee of Ministers found
that the Belgian Government had taken insufficient action to address the systematic problems
149
Unia functions as the equality body at the federal regional and community levels, except on the Flemish
level, where the Flemish Human Rights Institute functions as the equality body.
150
Country visit Belgium, FIRM-IFDH.
151
League of Human Rights (2025), written input, p. 23. UN General Assembly (1993).
152
In its 2024 Rule of Law Report the Commission recommended Belgium to ‘Take measures to ensure
compliance by public authorities with final rulings of national courts and the European Court of Human
Rights’.
153
Council of State Judgment No 257.300 of 13 September 2023; Flemish Refugee Council (2025); Judgment
by the Brussels Court of Appeal of 30 January 2025 ordering the Belgian state to as soon as possible
consult with the US to allow Nizar Trabelsi to return to Belgium at least temporarily and to provide him
with a laissez passer; The Council of State has on several cases suspended and cancelled arms export
licenses, ruling that their issue was contrary to international humanitarian law; Country visit Belgium,
FIRM-IFDH, Bar Associations, Human Rights Leagues.
154
Country visit Belgium, Court of Cassation, Constitutional Court and Council of State; Joint memorandum
of the three highest courts of Belgium of 19 July 2024.
155
The investigation focuses on decisions handed down by Belgian courts against the authorities from 2014-
2024, which are not implemented by Belgian authorities.
156
Judgment of the European Court of Human Rights of 18 July 2023, Camara v Belgium (application no.
49255/22); judgment of the European Court of Human Rights of 25 November 2014, Vasilescu v Belgium
(application no. 64682/12); judgment of the European Court of Human Rights of 2 October 2012, L.B. v
Belgium (application no.22831/08).
157
Country visit Belgium, Government. The action plans submitted by the Government and decisions by
Committee of Ministers are presented in the regularly updated Factsheet ‘Belgium - Overview of main
issues before the Committee of Ministers - Ongoing Supervision’, prepared by the department for the
execution of judgments.
17
identified in the Camara v. Belgium judgment158
. Overall, limited progress has been made on
the 2024 recommendation.
On 1 January 2025, Belgium had 17 leading judgments of the European Court of
Human Rights pending implementation, a decrease of 4 compared to the previous
year159. At that time, Belgium’s rate of leading judgments from the past 10 years that had
been implemented was 70% (compared to 61% in 2024; 30% remained pending), and the
average time that the judgments had been pending implementation was 4 years and 9 months
(compared to 3 years and 11 months in 2024)160
. The oldest leading judgment, pending
implementation for 16 years, concerns the excessive length of civil proceedings at first
instance level161
. As regards the respect of payment deadlines, on 31 December 2024 there
were 4 cases in total awaiting confirmation of payments (compared to 5 in 2023)162
. On 16
June 2025, the number of leading judgments pending implementation had increased to 18163
.
Despite a high level of protection under the law, civic space remains narrowed164
, and
stakeholders are raising concerns regarding new obstacles to the right to demonstrate.
Stakeholders continue to raise concerns regarding disproportionate preventive and repressive
actions undertaken by public authorities undermining the right to demonstrate165
. To prevent
disruptions of public order and ensure public safety, the Government intends to introduce the
possibility in the criminal code to impose an additional sanction of a prohibition to take part
in demonstrations on individuals convicted of illegal acts committed during previous
manifestations166
. The Federal Human Rights Institute referred to a negative opinion it issued
on an earlier draft for a judicial demonstration ban under the previous Government which,
according to FIRM-IFDH, already raised questions as to its proportionality and practical
enforceability167
. On 7 October 2024, trade unions and several CSOs lodged a constitutional
complaint related to the criminal offence of ‘malicious attack on government authority’168
.
The Constitutional Court issued two judgments of particular relevance to civic space. On 19
September 2024, the Constitutional Court annulled a provision of a Flemish Community
decree on the subsidising of social-cultural work, which excluded certain organisations from
eligibility for subsidies169
. On 14 November 2024, the Court pointed to the need to restrict
recourse to the civil law procedure based on which Presidents of first instance courts may
158
Council of Europe, Committee of Ministers (2024b).
159
For an explanation of the supervision process, see the website of the Council of Europe.
160
All figures calculated by the European Implementation Network (EIN) and based on the number of cases
that are considered pending at the annual cut-off date of 1 January 2025. EIN (2025), written input, p. 1.
161
Judgment of the ECtHR, 44826/05, Bell v. Belgium, pending implementation since 2009.
162
Council of Europe (2025), p. 156.
163
Data according to the online database of the Council of Europe (HUDOC).
164
Rating given by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed,
repressed and closed.
165
League of Human Rights (2025), written input, p. 26.
166
Coalition agreement, pp. 133-134.
167
FIRM-IFDH (2023).
168
Article 547 Criminal Code; Constitutional Court, case number 8339, Greenpeace Belgium and others, 7
October 2024 (pending).
169
The Court concluded that the contested subsidy condition does not meet the requirements of the principle of
legal certainty due to its ambiguous character; judgment of the Constitutional Court of 19 September 2024
in case number 93/2024; 2024 Rule of Law Report Belgium, pp. 29, 30.
18
issue an urgent court order without hearing the opposing party, to a limited number of cases,
excluding its use to challenge a strike170
.
170
Judgment of the Constitutional Court of 13 November 2024, case 123/2024. NGOs welcomed this decision;
League of Human Rights (2025), written input, p. 5; 2024 Rule of Law Report Belgium, pp. 30-31.
19
Annex I: List of sources in alphabetical order*
* The list of contributions received in the context of the consultation for the 2025 Rule of Law report
can be found at https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en
Belgian Government (2025a), Federal government agreement 2025-2029 (Accord de coalition
fédérale 2025-2029/ federal regeerakkoord 2025-2029),
https://www.belgium.be/sites/default/files/resources/publication/files/Regeerakkoord-
Bart_De_Wever_nl.pdf,
https://www.belgium.be/sites/default/files/resources/publication/files/Accord_gouvernemental-
Bart_De_Wever_fr.pdf.
Audit Vlaanderen (2024), Thematic Audit – Analysis of the Integrity System of local government
(Thema-audit Analyse van het integriteitssysteem van lokale besturen),
https://www.auditvlaanderen.be/lokale-besturen/auditplanning/thema-audit-analyse-van-het-
integriteitssysteem-van-lokale-besturen.
Committee P (2024), Investigative Report on the recruitment, selection and training within the police
(Rekrutering, selectie en opleiding binnen de politieorganisatie),
https://comitep.be/document/onderzoeksrapporten/onderzoeksrapport%20over%20de%20rekrutering,
%20selectie%20en%20opleiding%20binnen%20de%20politieorganisatie.pdf.
Constitutional Court (2024), Judgment of the Constitutional Court of 13 November 2024 in case
number 123/2024, https://www.const-court.be/public/n/2024/2024-123n.pdf.
Council of Europe, Committee of Ministers (2024a), H46-6 Bell group v. Belgium (Application No.
44826/05), Supervision of the execution of the European Court’s judgments, 11-13 June 2024,
https://hudoc.exec.coe.int/eng#{%22execidentifier%22:[%22004-1201%22]}.
Council of Europe, Committee of Ministers (2024b), H46-6 Camara v. Belgium (Application No.
49255/22, Supervision of the execution of the European Court’s judgments, 17-19 September 2024,
CM/Del/Dec(2024)1507/H46-6.
Council of Europe (2025), Factsheet ‘Belgium - Overview of main issues before the Committee of
Ministers - Ongoing Supervision’, https://rm.coe.int/mi-belgium-eng/1680a23c80.
Council of Europe: Committee of Ministers (2025), Supervision of the execution of judgments and
decisions of the European Court of Human Rights, 18th
Annual Report of the Committee of Ministers,
https://rm.coe.int/gbr-2001-18e-rapport-annuel-2024/1680b4d77d.
Council of Europe, Platform to promote the protection of journalism and safety of journalists –
Belgium.
Court of Audit, Federal steering policy for the digital transformation of the justice system, December
2024, https://www.ccrek.be/en/publication/federal-steering-policy-for-the-digital-transformation-of
Court of Audit (2025), large majority of public officials submitted their assets and mandates
declarations with the Court of Audit (Overgrote meerderheid mandatarissen diende in 2024
mandatenlijsten en vermogensaangiften in bij het Rekenhof),
https://www.ccrek.be/sites/default/files/PDF/20250214_Persbericht.pdf.
Cumuleo (2025), Written contribution received following the country visit.
20
Declaration by representatives of the judiciary (2025), Declaration by representatives of the judiciary
and call on the executive and legislative powers, 27 June 2025, available here:
https://courdecassation.be .
EPPO (2025a), Annual Report 2024, https://www.eppo.europa.eu/assets/annual-report-
2024/index.html.
EPPO (2025b), Written contribution for the 2025 Rule of Law Report.
European Centre for Press and Media Freedom, Media Freedom Rapid Response – Belgium.
European Federation of Journalists (2024), Belgium: Serious concerns over cases of preventive
censorship involving four media outlets, Belgium: Serious concerns over cases of preventive
censorship involving four media outlets – European Federation of Journalists.
European Implementation Network (EIN) (2025), written input for the 2025 Rule of Law Report.
Federal Deontological Commission (2025), Written contribution received following the country visit
Federal Police (2025a), Written contribution received following the country visit.
Federal Internal Audit Service (2025), Written contribution received following the country visit.
FIRM/IFDH(2023), Advice of 20 February 2023 on the judicial ban on demonstrations, FIRM -
IFDH Advies 05-2023 Betogingsverbod_0.pdf; FIRM - IFDH Advies 05-2023
Betogingsverbod_fr.pdf.
FIRM/IFDH (2025), Letter to the Chamber of Representatives on legislative proposal 656/1 on
whistleblower protection for the Chamber of Representatives and the Senate (Brief FIRM/IFDH aan
de Kamer over het Wetsvoorstel nr. 656/1 tot omzetting van Richtlijn (EU) 2019/1937 (…) inzake de
bescherming van personen die inbreuken op het Unierecht melden, wat de Kamer van
volksvertegenwoordigers en de Senaat betreft / Lettre FIRM/IDFH au Chambre concernant la
Proposition de loi n° 656/1 visant à transposer la directive (UE) 2019/1937 (…) sur la protection des
personnes qui signalent des violations du droit de l’Union, en ce qui concerne la Chambre des
représentants et le Sénat), 25 February 2025.
Flemish Minister of Domestic Administration (2025), Additional measures to improve integrity and
deontology for local governments (Extra maatregelen om integriteit en deontologie bij lokale
besturen te verbeteren),
https://www.hildecrevits.be/extra_maatregelen_om_integriteit_en_deontologie_bij_lokale_besturen_t
e_verbeteren.
Flemish Refugee Council (2025), Dashboard Non-reception policy (Dashboard niet-opvangbeleid),
https://www.caritasinternational.be/wp-content/uploads/2025/03/NL-Dashboard-Beleid-van-niet-
opvang-maart-2025.pdf?x24972.
GRECO (2022a), Fifth Evaluation Round – Compliance Report, Belgium, https://rm.coe.int/fifth-
evaluation-round-preventing-corruption-and-promoting-integrity-i/1680a53b99.
GRECO (2022b), Fourth Evaluation Round – 3rd
Interim Compliance Report, Belgium,
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-members-
of/1680a7eada.
21
GRECO (2024a), Fifth Evaluation Round – Second Compliance Report, Belgium,
https://rm.coe.int/grecorc5-2024-3-final-eng-2nd-compliance-report-belgium-conf-2775-
2677/1680af94d7.
GRECO (2024b), Fourth Evaluation Round – Addendum to the Second Compliance Report, Belgium,
https://rm.coe.int/grecorc4-2024-1-final-eng-add-to-the-2nd-compliance-report-belgium-
con/1680af9498.
Ministry of Justice (2025a), Written contribution received following the country visit.
Ministry of Justice (2025b), Policy Statement – Justice, 13 March 2025, doc. 56 0767/017.
Ministry of Public Administration (2024), Circular of 16 June 2024 – Conflicts of Interest
(Omzendbrief Belangenconflicten), https://bosa.belgium.be/nl/news/omzendbrief-belangenconflicten.
Ministry of Public Administration (2025), Policy Statement – Budget, 11 March 2025, doc. 56
0767/011.
OECD (2025), Anti-Bribery Convention Phase 4 Report on Belgium, 25 March 2025,
https://www.oecd.org/en/publications/2025/03/oecd-anti-bribery-convention-phase-4-report-on-
belgium_39a2856e.html.
Ombudsperson (2024), Guide for Whistleblowers, December 2024 (Guide du lanceur d'alerte/ Gids
voor klokkenluiders), https://www.federaalombudsman.be/fr/guide-du-lanceur-dalerte/
https://www.federaalombudsman.be/nl/gids-voor-klokkenluiders.
Public prosecution service (2025a), Written contribution received following the country visit.
Stichting Overheidsopdrachten (2024), Memorandum 2024 – 8 points of action for better public
procurement as of the next legislature (8 actiepunten om performanter aan te besteden tijdens deze
legislatuur), https://www.stichtingoverheidsopdrachten.org/initiatieven/memorandum/.
UN General Assembly (1993), Principles relating to the Status of National Institutions (The Paris
Principles), adopted by the United Nations General Assembly resolution 48/134 of 20 December
1993, https://ganhri.org/paris-principles/.
Vlaamse Vereniging van Journalisten (2024), Persveilig.be: annual review 2024, Persveilig.be:
annual review 2024 | Flemish Association of Journalists.
Voorhoof Dirk (2025), Belgium: A model for the transposition of the EU anti-SLAPP Directive,
Belgium: A model for the transposition of the EU anti-SLAPP Directive – Dirk Voorhoof – Inforrm's
Blog.
VRTNWS (2025a), House search of anti-corruption investigator (Huiszoeking bij anti-corruptiedienst
van federale politie, topman verhoord), https://www.vrt.be/vrtnws/nl/2025/02/06/huiszoeking-bij-
anticorruptiespeurder-federale-politie/.
VRTNWS (2025b), Head Anti-Corruption Investigator goes to Committee P out of fear of political
influence in sensitive files (Hoofd anti-corruptiespeurders stapt naar Comité P, uit angst voor
politieke inmenging bij gevoelige dossiers), https://www.vrt.be/vrtnws/nl/2025/02/12/speurders/.
22
Annex II: Country visit to Belgium
The Commission services held virtual meetings in March 2025 with:
• Amnesty International Belgium
• Bureau of Integrity
• College of Courts and Tribunals
• Committee P
• Community Authorities for Media
• Constitutional Court
• Council of State
• Court of Cassation
• Federal Deontological Commission
• Federal Human Rights Institute
• Federal Ombudsmen
• Federal Police
• Federation of Belgian Enterprises (VBO-FEB)
• Flemish Association of Journalists (VVJ)
• Flemish Bar Association
• Flemish Media Regulator
• French- and German-speaking Order of the Belgian Bar
• High Council for Justice
• High Council for the Audiovisual
• Journalistic Ethics Council
• Liga voor Mensenrechten
• Ligue des Droits Humains
• Ministry of the Interior
• Ministry of Justice
• Prosecution Service
• Public Service Media
• Transparency International Belgium
* The Commission also met the following organisations in a number of horizontal meetings:
• Amnesty International
• Araminta
• Civil Liberties Union for Europe
• Civil Society Europe
• European Civic Forum
• European Partnership for Democracy
• European Youth Forum,
• International Commission of Jurists
• International Federation for Human Rights (FIDH)
• JEF Europe
• Philea – Philanthropy Europe Association.
• Transparency International