COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report Country Chapter on the rule of law situation in the Netherlands 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) 919 final
COMMISSION STAFF WORKING DOCUMENT
2025 Rule of Law Report
Country Chapter on the rule of law situation in the Netherlands
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) 901 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) 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 perception of the level of judicial independence in the Netherlands is very high.
Nevertheless, judicial bodies and stakeholders note that some safeguards for judicial
independence rest on practice and culture alone. The procedure for appointing members of the
Council for the Judiciary and the executive’s power to give instructions to prosecutors in
individual cases continue to be under discussion. A proposal introducing visual supervision of
all lawyer-client conversations in high-security prisons was tabled as part of the measures to
fight organised crime. Some steps have been taken to address staff shortages and a high
workload in the judiciary. An independent review recommended increasing legal aid lawyers’
fees. The level of digitalisation has further improved. The efficiency of the justice system
continues to be high.
A first national anti-corruption policy was adopted by the Government. The investigation and
prosecution of corruption offences remains effective, and measures are taken to deal with
unauthorised access to data by civil servants and police officials and fight corruption linked to
organised crime. Plans were announced to improve coordination of integrity for civil servants
to address Court of Audit recommendations, and the draft Political Parties Act is being revised,
following advice from the Council of State. The Government had announced its intention to
review the rules related to transparency and the asset declaration regime of ministers and state
secretaries in the future. Steps taken to increase the transparency of lobbying remain
insufficient. Revised rules on revolving doors for former ministers and state secretaries were
adopted by the House of Representatives. Work continues on targeting bribery of government
officials by organised crime groups and on the identification of other priority sectors in the
fight against corruption.
The media regulator operates efficiently and independently. Steps have been taken to address
certain concerns about the adequacy of the Press Council, the self-regulatory body for the press
sector, such as clarifying its role, and streamlining its complaint-handling procedures.
Preparatory work is underway for a legislative proposal on the reform of public service media.
Challenges related to a high level of media market concentration, and limited media ownership
transparency remain. Efforts to improve transparency and access to information continue and
the safety of journalists has improved.
A series of initiatives were taken by state authorities to follow up on the proposals of the State
Commission on the Rule of Law. Shortcomings in the consultation of stakeholders on a
legislative package with important legal and social consequences have given rise to serious
concerns. The Netherlands Institute for Human Rights has taken measures to address its
governance issues. The space for civil society organisations has narrowed and is affected by a
combination of funding cuts and a risk of new legal obstacles.
2
RECOMMENDATIONS
Overall, concerning the recommendations in the 2024 Rule of Law Report, the Netherlands has
made:
• Some progress on efforts to address shortages in human resources and challenging working
conditions in the justice system.
• Significant progress on completing the revision of rules on revolving doors involving
former ministers and state secretaries, including a two-year cooling-off period and
restrictions on paid activities.
• Limited further progress on establishing stricter transparency rules on lobbying for
members of the Government and Parliament.
• Some progress on enhancing the governance of public service media and its ability to
uphold journalistic standards, taking into account European standards on public service
media.
• Some progress on ensuring an adequate follow-up to the recommendations of the State
Commission on the Rule of Law, strengthening the legal protection of citizens.
On this basis, and considering other developments that took place in the period of reference, it
is recommended to the Netherlands to:
• Continue efforts to improve challenging working conditions in the justice system and
address shortages in human resources.
• Establish stricter transparency rules on lobbying for members of the Government and
Parliament.
• Take forward the planned reform of public service media to enhance its governance and its
ability to uphold journalistic standards, taking into account European standards on public
service media.
• Take forward the proposal of the State Commission on Rule of Law to strengthen a rule of
law culture, including by setting up a structured dialogue between the state powers based
on a ‘rule of law agenda’.
3
I. JUSTICE SYSTEM1
Independence
The level of perceived judicial independence in the Netherlands is very high among both
the general public and companies. Overall, 76% of the general population and 75% of
companies perceive the level of independence of courts and judges to be ‘fairly or very good’
in 20252
. Among the general public, this figure has increased in comparison with 2024 (70%)
but is slightly lower in comparison with 2021 (77%). The perceived judicial independence
among companies has slightly increased in comparison with 2024 (74%), although it remains
lower in comparison with 2021 (82%).
Judicial bodies and stakeholders note that some safeguards for judicial independence rest
on practice and culture alone. The Council for the Judiciary, the Council of State, the Dutch
Association for the Judiciary, some Court Presidents, the Bar Association and the Meijers
committee emphasised that current rule of law safeguards based on legal culture need to be
strengthened and anchored in the Constitution and statutory law to protect the independence of
the judiciary. They argue that a continuation of a strong rule of law culture can no longer be
taken for granted, given the political climate of increasing polarisation and pressure (3
). Online
threats against a judge sparked further concerns and led to a complaint filed with the Public
Prosecution Service4
.
The procedure for appointing members of the Council for the Judiciary and court
management boards continues to be under discussion. Parliament, the Council for the
Judiciary and the Dutch Association for the Judiciary reiterated their call to limit the Minister
of Justice’s power in the appointment procedure of candidates to the Council for the Judiciary
and court management boards5
, also in light of the Venice Commission opinion on the scope
on Ministerial powers6
. The Minister for Legal Protection had announced a letter to Parliament
clarifying the Government’s position on the matter7
.
The issue of the executive’s power to give instructions to prosecutors in individual cases
remains unresolved, awaiting Parliamentary debate. Parliament, the Dutch Association for
the Judiciary and the Bar Association reiterated their plea to abolish the Minister of Justice’s
1
An overview of the institutional framework for all four pillars can be found here.
2
Figures 51 and 53, 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
Council for the Judiciary (2025a, b), written input, pp. 1-2; Council of State (2024); Country visit the
Netherlands, Council for the Judiciary, Dutch Association for the Judiciary, and Meijers Committee; Dutch
Association for the Judiciary (2025), written input, pp. 7, 21; Bar Association (2025), written input, pp. 2-3;
Meijers Committee (2025), written input pp. 1-2; for the appointment procedure of Supreme Court judges see
2024 Rule of Law Report, the Netherlands, p. 4.
4
On 24 February 2025 the Amsterdam district court filed a complaint regarding the dissemination of personal
data of a judge for the purpose of intimidation.
5
Country visit, Administration of Parliament, Council for the Judiciary, Dutch Association fpr the Judiciary;
2024 Rule of Law Report, the Netherlands, p. 5; The justification for the Parliamentary motion is that from
the point of view of the separation of powers it is [deemed] undesirable for members of the Council for the
Judiciary to be nominated by the Minister; Motion by Member Sneller on legislating to minimise the
Minister's role in the appointment procedure for members of the Judicial Council, adopted on 12 March 2024.
6
Venice Commission (2023), paragraph 45.
7
State Secretary for Legal Protection (2025).
4
power to give instructions to prosecute or not to prosecute in individual cases8
. A Parliamentary
Bill9
is awaiting to be discussed in Parliament. According to the Public Prosecution Service,
the current law on judicial organisation already contains adequate guarantees against abuse10
.
In 2023, while acknowledging the importance of informal norms, the Venice Commission had
nonetheless recommended introducing more formal safeguards by removing the Minister’s
power to give instructions not to prosecute in specific cases, or at least to limit this prerogative
to clearly defined exceptional circumstances11
. The Government had indicated that it would set
out its position once the parliamentary debate was scheduled12
.
Quality
A proposal introducing visual supervision of all lawyer-client conversations in high-
security prisons was tabled as part of the measures to fight organised crime. As reported
last year, the Government has started to fundamentally review the monitoring and security
system for persons who are threatened by organised crime, under the direction of the National
Coordinator for Counterterrorism and Security. The Government proposed strengthened
security measures to enhance the resilience of the justice system against organised crime and
was preparing amendments to the key witness scheme13
. The Government put forward a revised
proposal for visual supervision of lawyer-client conversations in high-security prisons14
. It
indicates that the purpose is to help protect lawyers from pressure, coercion or threats, without
compromising access to a lawyer and lawyer-client confidentiality. According to the
Government, the measure should apply to all detainees in high-security prisons, because of
their particular dangerousness. On 4 February 2025, the House of Representatives approved
the revised proposal. The Bar Association continues to consider that the proposal violates the
principles of necessity and proportionality, and called for further amendments to ensure that
supervision will only take place following an individual assessment15
. The draft legislation is
now pending in the Senate.
The level of digitalisation of the justice system has further improved. The digitalisation of
justice is overall advanced16
. The digitalisation of legal proceedings through the electronic
exchange of documents and secure electronic communications via digital portals improved17
.
Legislation is being prepared for the conduct of online hearings18
. The availability of electronic
8
2024 Rule of Law Report, the Netherlands, p. 5; Meijers Committee (2025), written input, pp. 2, 3.
9
Bill by Member Sneller (Expiration of Special Powers of Instruction of the Public Prosecution Service Act),
House of Representatives, 2021-2022 session, 36 125, no 2. A previous version of the Bill was tabled in 2021;
2024 Rule of Law Report, The Netherlands, pp. 5, 6.
10
Country visit, Public Prosecution Service.
11
Venice Commission (2023), paras. 67, 71 72; See also Council of Europe (2000), para. 13(f); Figure 55, 2020
EU Justice Scoreboard.
12
Country visit the Netherlands, Government.
13
Country visit the Netherlands, Government; The Bar Association considers that the key witness scheme
should not be expanded until the safety of all persons concerned, including lawyers, is guaranteed; Country
visit, Bar Association; 2024 Rule of Law Report, the Netherlands, pp. 6, 7.
14
Amendment of the legislative proposal amending the Penitentiary Principles Act in connection with
additional measures against organised crime during detention, 26 June 2024. The revision followed an opinion
by the Council of State expressing concerns regarding compliance of certain Parliamentary amendments (also
calling for auditory supervision) with lawyer-client confidentiality; Council of State. Alleged abuse by some
lawyers suspected of passing on messages to third parties in breach of the law has already led to criminal
proceedings. Country visit, Dutch Association for the Judiciary.
15
Country visit the Netherlands, Bar Association.
16
Figures 41-49, 2025 EU Justice Scoreboard.
17
Dutch Government (2025), written input, p. 3.
18
Country visit, Council for the Judiciary, Bar Association.
5
communication tools in courts continues to be high19
. The Dutch Recovery and Resilience Plan
includes measures to further digitalise the criminal justice chain, which aim at improving the
efficiency by replacing paperwork in criminal cases with digital files and by ensuring
permanent digital access to relevant information on criminal proceedings20
. The Council for
the Judiciary continues to work on increasing the number of published judgments, and a
legislative proposal for the publication of judgments is under preparation21
.
Some progress has been made on the recommendation to address staff shortages and a
high workload in the judiciary22
. The number of training places for judges were gradually
increased to 140, which is expected to be sufficient to compensate for the retirement of
experienced judges23
. The Dutch Association for the Judiciary pointed out that in 2022, the
Public Prosecutors Office announced that 250 new officers would be trained in three years. In
2023, 82 officers started training. It also noted that due to their workload, experienced judges
have a limited capacity to train new applicants24
. Investments are also being made in judicial
support staff25
. In April 2024, an independent expert presented recommendations to the
Minister for Legal Protection and the Dutch Association for the Judiciary on how to reduce the
workload of the judiciary and public prosecution services26
. The Council for the Judiciary is
implementing these recommendations, which relate to working conditions, deployment of
support staff27
, improved pre-trial management, as well as to innovation projects28
. An
employee satisfaction survey will be conducted in 2025 to determine the effectiveness of the
measures29
. Overall, there has been some progress on addressing shortages in human resources
and challenging working conditions in the judiciary.
An independent review recommended increasing the legal aid lawyers’ fees. The Council
for the Judiciary and the Bar Association called for a robust, stable and independent funding
for the judiciary in general and for legal aid in particular, underlining their importance for the
rule of law and access to justice30
. This has been an important subject of debate in Parliament31
.
The budget in the Netherlands is organised in such a way that a political discussion must take
place every year about the amount to be allocated to the legal aid scheme. The Bar Association
argued for a system by which fee adjustments would be more automatic32
. It supported its
claims by pointing to the results of a survey among legal aid lawyers which points to a shortage
of legal aid lawyers in several regions and areas of law in the Netherlands33
. An independent
19
Figure 43, 2025 EU Justice Scoreboard.
20
Dutch RRP, 8 July 2022.
21
Country visit the Netherlands, Council for the Judiciary.
22
The 2024 Rule of Law Report recommended the Netherlands to ‘Continue efforts to address shortages in
human resources and challenging working conditions in the justice system’.
23
Dutch Government (2025), written input, p. 1; Country visit, Council for the Judiciary.
24
Country visit the Netherlands, Dutch Association for the Judiciary.
25
Country visit the Netherlands, Government.
26
J. Winter (2024).
27
Country visit the Netherlands, Government.
28
Council for the Judiciary (2025), written input, p. 3.
29
Country visit the Netherlands, Council for the Judiciary.
30
2024 Rule of Law Report, the Netherlands, pp. 9, 10; Council for the Judiciary (2025), written input, p. 1.
31
Country visit, Parliament; during a legislative debate on the amendment of the Judiciary Organisation Act a
resolution was submitted that introduced a separate budgetary chapter for the judiciary. The vote on this
resolution has been postponed awaiting the opinion of the Council of State. The House of Representatives
Justice Committee debated subsidised legal aid on March 13, 2025.
32
Country visit, Bar Association.
33
Bar Association (2024). The study concludes that in the past five years 900 legal aid lawyers have stopped
practicing, which represents 13%. 2 500 legal aid lawyers will retire. There is also evidence of justice seekers
unable to find a legal aid lawyer.
6
review of the compensation system for legal aid lawyers published on 3 March 2025 made
several recommendations to increase the compensation of legal aid lawyers. The review also
recommended providing periodic recalibration and indexation of fees and an office allowance
to train new colleagues34
.
The decision of the prosecution service to make more extensive use of the possibility to
decide on certain criminal cases without involving a judge has raised concerns. The
prosecution service can settle a crime punishable by less than six years' imprisonment out of
court, through a penalty order issuing a community service or a fine35
. This possibility has so
far been used for less serious crimes. In 2025 the prosecution service decided to temporarily
extend its use to the full spectrum of offences, within the limits specified by law, with the aim
to alleviate criminal courts’ caseload so that judicial capacity is utilised for the more serious
criminal cases and to reduce the frequency of short-term custodial sentences allowing them to
be enforced more effectively. The Council for the Judiciary criticised the new approach,
considering that it sidelines criminal courts and undermines the rule of law36
. The Supreme
Court’s attorney general had already pointed to a lack of safeguards in the execution of this
policy by the Public Prosecution Service37
. Police Unions have also contested the new
approach, warning that ‘officers who work hard to bring cases forward will see their efforts
reduced to mere fines or community service orders’38
. The Bar Association called to ensure
legal assistance and legal aid in this out-of-court settlement procedure39
. In response to these
concerns, the Public Prosecution Office has communicated that the expansion of the application
of the criminal order will be limited to common shoplifting offences, such as shoplifting and
receiving stolen goods. In the coming year, the Public Prosecution Office will assess the impact
of this decision on the judiciary and victims40
. In addition, the Procurator General at the
Supreme Court announced a follow-up study on this matter41
. The WODC is also conducting
research on this matter. The Board of Procurators General awaits the results of these studies
and will not issue new instructions to further intensify the use of the penalty order42
.
Efficiency
The efficiency of the justice system continues to be high. The duration of proceedings in
first instance civil, commercial, administrative, and other cases remains short43
, and the
clearance rate is effective44
. The estimated time to resolve administrative cases at first instance
courts rose (267 days in 2023, compared to 257 in 2022)45
. The rate of resolving civil,
commercial and other cases at first instance increased to 100% in 202346
. The rate of resolving
34
Van der Meer II Committee (2025); The Government was also taking various initiatives related to education,
the professional training and contribution of commercial lawyers. It also announced a project to develop a
vision on the future of legal aid lawyers. This project is expected to finish in the third quarter of 2025.
35
Based on Article 257a of the Dutch Code of Criminal Procedure.
36
Council for the Judiciary (2025b)
37
Supreme Court (2022).
38
Dutch prosecutors push for more fines, community service instead of prison, NLTimes (2025).
39
Bar Association (2025).
40
Public Prosecution Office (2025a).
41
Supreme Court (2025).
42
Country visit the Netherlands, Government.
43
Figure 4, 2025 EU Justice Scoreboard.
44
Figure 9, 2025 EU Justice Scoreboard.
45
Figure 7, 2025 EU Justice Scoreboard.
46
Figure 9, 2025 EU Justice Scoreboard.
7
administrative cases at first instance decreased to 88% in 202347
. Data on the efficiency of
litigious civil and commercial cases is still lacking48
.
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, the Netherlands scores 78/100 and ranks 5th
in the
European Union and 9th
globally49
. This perception has deteriorated50
over the past five years.
The 2025 Special Eurobarometer on Corruption shows that 56% of respondents consider
corruption widespread in their country (EU average 69%) and 11% of respondents feel
personally affected by corruption in their daily lives (EU average: 30%). As regards businesses,
52% of companies consider that corruption is widespread (EU average 63%) and 15% consider
that corruption is a problem when doing business (EU average 35%). Furthermore, 47% of
respondents find that there are enough successful prosecutions to deter people from corrupt
practices (EU average 36%), while 45% of companies believe that people and businesses
caught for bribing a senior official are appropriately punished (EU average 33%)51
.
A first national anti-corruption policy was adopted by the Government. Following
consultations launched in 202252
, an initiative focused on preventing and combating corruption
was adopted by the government in June 2025. The policy sets out four pillars to guide the anti-
corruption work: addressing the main vulnerabilities (by completing the pending national risk
assessment), strenghtening governmental processes and systems, promoting preventive
measures in the private sector and ensuring an efficient criminal justice response53
. The lack of
an anti-corruption strategic framework had been noted in the past54
.
Public debate over the criminalisation of trading in influence intensified55. A number of
high-profile corruption cases gave new impetus to the debate on the criminalisation of trading
in influence56
. The Public Prosecution Service and the NIID have however not suggested any
changes to the current rules, while civil society organisations strongly reiterated their call to
strengthen the existing legal framework57
. The Government indicated that it would reassess the
issue after the adoption of the EU Directive on combating corruption58
. Legislation on the
47
Figure 11, 2025 EU Justice Scoreboard.
48
Figure 5, 2025 EU Justice Scoreboard.
49
The level of perceived corruption is categorised as follows: low (the perception among experts and business
executives of public sector corruption scores above 79); relatively low (scores between 79-60), relatively high
(scores between 59-50), high (scores below 50).
50
In 2020, the score was 82 while in 2024, the score is 78. 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.
51
Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025).
52
Dutch Government (2025), written input, pp. 4-5 and Country visit the Netherlands, Ministry of Justice.
53
Dutch Government (2025f), pp. 1-8.
54
2024 Rule of Law Report, the Netherlands, pp. 11-12. As the Netherlands lacked an anti-corruption strategic
framework, for example, it scores low on the OECD (2025) Public Integrity Indicator for Quality of the
Strategic Framework.
55
Ensuring the criminalisation of “trading in influence” is a long-standing objective of civil society
organisations, on which no action has been taken so far. 2022 Rule of Law report, the Netherlands, p. 9.
56
Trouw (2025) and NRC (2025).
57
Country visit the Netherlands, Public Prosecution Service and NIID, TI, NHC, FPU;NJC(2025), written input,
p. 13, Civil Liberties Union for Europe (2025), p. 742 and Trouw (2025).
58
Ministry of Justice (2025a), p. 4. Proposal for a Directive on Combating Corruption COM(2023) 234 final.
8
procedure for the prosecution and trial of Ministers and Members of Parliament, which is
considered out of date, is also being updated59
.
The investigation and prosecution of corruption offences remains effective and
cooperation to address corruption linked to organised crime continues. The investigation
and prosecution of domestic corruption offences continue to function properly, including in
high-level cases, without specific obstacles signalled by the investigators and prosecutors. The
Government committed to allocate an additional 5 million EUR to the NIID, the Anti-
Corruption Centre of the Fiscal Intelligence and Investigation Service (FIOD) and the judiciary
and to fighting corruption in the public sector60
. In 2024, 29 persons were indicted by the
prosecution on charges of corruption (41 in 2023)61
. Additionally, in 2024, courts imposed final
convictions in 8 cases in first instance and in 30 cases in second instance62
. None of the EPPO’s
cases in 2024 involved corruption offences63
. The National Cooperation against Subversive
Crime (NSOC) was closed in December 2024 as it did not lead to more effective cooperation64
.
According to the Public Prosecution Service and the responsible ministries, existing
cooperation works well in practice65
. A new Serious Crime Taskforce seeks to stimulate
cooperation between law enforcement and the banking sector to target facilitators of organised
crime66
. The FIOD has reassigned posts internally in order to increase capacity to investigate
foreign bribery. It is fully operational since May 2025, but this only partially addresses
concerns on the effective enforcement of foreign bribery cases67
. An overall increase of the
capacity of the Public Prosecution Service should also have a positive effect. Guidelines for
self-monitoring and self-reporting financial economic crimes (including foreign bribery)
entered into force on 1 January 2025, providing more clarity for companies. The Public
Prosecution Service amended their Directive on the Investigation and Prosecution of Foreign
Bribery including on out-of-court settlements, but civil society still consider them too opaque68
.
Measures have been introduced to detect and prevent unauthorised access to official
databases. The police has introduced a new monitoring programme to better flag cases of
potential unauthorised access to official databases by corrupt civil servants and police officials
59
The legislation is in public consultation since January 2025 and is expected to be announced in 2025. It
concerns a change of both constitution and law to ensure the prosecution of MP and ministers is conducted
with greater independence and led by the prosecutor general. Dutch Government (2024).
60
Circa 3 million EUR will go to NIID, FIOD, and the judiciary (including the public prosecution service). 1
million is yet to be divided, but is destined for the anti-corruption policy, which is focused on both public and
private sector corruption. 1 million is to be divided between the police, FIOD, NIID and judiciary (including
the public prosecution service) for implementing the upcoming EU Directive on combating
corruption.Country visit the Netherlands, Public Prosecution Service and law enforcement, Dutch
Government (2025), written input, p. 6 and Dutch Government (2025d)
61
Only data linked to bribery cases. There are no data available on the number of investigations.
62
This concerns cases in which breaches of one or several corruption crimes have been proven. The number on
final convictions only refers to the number of cases in which convictions were handed down, not to the number
of defendants convicted in each case. Dutch Government (2025), written input, pp. 13-14.
63
EPPO (2025), p. 47.
64
Following a motion by the House of Representatives. Dutch Government (2025), written input, pp. 7-8, and
Motion MP Michon-Derkzen c.s. Parliamentary Papers II 2023-2024, 36 560 VI nr. 15.
65
Ministry of Justice (2025a), pp. 7-8 and, country visit the Netherlands, Public prosecution office and MFA.
66
Dutch Government (2025a).
67
Fiscal Intelligence and Investigation Service (FIOD) with its Anti-Corruption Centre (ACC). Country visit
the Netherlands, Public prosecution office, and 2024 Rule of Law Report, the Netherlands, pp. 14-15.
68
Dutch Government (2025), written input, p. 7, and TI, NHC, FPU and NJC (2025), pp. 13, 20-21.
9
69
. In 2024, the NIID investigated 15 cases of information leakage and 20 cases of corruption
in the authorities70
. The NIID and the Public Prosecution Service continue to issue reports to
the relevant authorities on the issuance of data-secure identification documents and on access
management in governmental information systems71
.
Plans were announced to improve the coordination of integrity for civil servants to
address Court of Audit recommendations. A revised Code of Conduct for civil servants is
expected to enter into force on 1 January 2026. It will summarise all integrity rules, provide
guidance in decision-making and highlight the importance of a culture of integrity. An external
independent integrity committee will also be set up to which civil servants can report suspicions
of integrity violations and abuses directly72
. The Court of Audit identified deficiencies, such as
a reluctance to report suspected wrongdoing and a lack of effectiveness of coordination and
preventive mechanisms73
. In response, the Government had announced an intention to
strengthen the coordinating role of the Minister of Internal Affairs, enhance the role of integrity
coordinators in individual ministries and monitor the integrity policy within the central
government74
. The police is also further expanding its integrity department and reflecting on
ways to implement GRECO’s outstanding recommendation on the registration of gifts within
the police75
.
The Government had announced its intention to review the asset and interest declaration
regime of ministers and state secretaries in 2027. Under the 2022 Code of Conduct76
,
ministers must report any acceptance of financial interests to the House of Representatives.
There is however no oversight mechanism and the system relies on self-responsibility and the
principle of parliamentary trust77
, on which stakeholders continue voice doubts78
. A former
Government had introduced new integrity measures, including a self-assessment of new
ministers, the appointment of two high-level integrity advisers for both ministers and state
secretaries, and training sessions on integrity upon taking office79
. This policy was put into
practice in the context of the government formation in 202480
. The Ministry of Internal Affairs
considers this policy to be sufficiently effective, while the resignation of a State Secretary in
relation to his asset declaration highlighted issues with the existing approach81
. In response,
the Government had announced its intention to review the asset declaration rules in 2027, ahead
69
The programme includes algorithmic risk analsyis. Problems on this topic relate to inadequately equipped IT
systems which are not able to track the identity of persons accessing the specific data in an unauthorised
manner. Dutch Government (2025), written input, p. 8, and country visit the Netherlands, police. See also
2024 Rule of Law Report, the Netherlands, pp. 12-13.
70
Public Prosecution Service (2025b), p. 64.
71
Public Prosecution Service (2025b), pp. 64-65.
72
Dutch Government (2025), written input, pp. 6 and 10 and Ministry of Justice (2025a), p. 6.
73
Court of Audit (2024) and country visit the Netherlands, Court of Audit.
74
Minister of Internal Affairs and Kingdom Relations (2025b), pp. 2-4.
75
Dutch Government (2025), written input p. 6, and country visit the Netherlands, police.
76
2024 Rule of Law Report, The Netherlands, p. 16.
77
Government members can be requested to resign from office if they lose the confidence of a parliamentary
majority. See 2024 Rule of Law Report, The Netherlands, p. 16.
78
The effectiveness of the Code of Conduct was criticised previously by GRECO and the Open State
Foundation, and this criticism was once again confirmed by Transparency International . 2024 Rule of Law
report, p. 16.
79
2024 Rule of Law Report, the Netherlands, p. 16.
80
Dutch Government (2025), written input, pp. 9-10, and Ministry of Justice (2025a), p. 5.
81
Country visit the Netherlands, Ministry of Interior and Kingdom Relations; Ministry of Justice (2025a), p. 5,
Transparency International (2024a).
10
of the next elections82
, which was criticised as possible revised rules would only apply as of
the next legislature83
.
The enforcement of the existing system of asset and interest declarations in Parliament is
under public scrutiny. Issues remain with the asset and interest declarations in both houses of
Parliament and with the overall mandate of the College of Investigation of Integrity84
. The
independent integrity adviser of the House of Representatives circulated a memorandum in
March 2024 on members of Parliament’s obligations. In September 2024, the House also
amended the Code of Conduct to allow the College of Investigation of Integrity to consider
failures to comply with an instruction or suspension by the College85
. Stakeholders signalled
that over one third of MPs do not, or only insufficiently, declare their side jobs and interests
and that rules are not enforced86
. While the College of Investigation of Integrity continues to
investigate MP’s failures to declare assets and interests on the basis of individual complaints,
there has so far been no further follow-up concerning the overall functioning of the system87
.
On rules in the Senate, civil society stated that the Presidium of the Senate is not well equipped
to investigate and sanction violations of asset and interest declaration rules88
.
There has been significant progress on the recommendation on rules on revolving doors
as the relevant law was adopted by the House of Representatives89
. The new law introduces
an obligatory period of two years during which former ministers and state secretaries would
have to seek advice from an Advisory Board on their new, paid employment90
was adopted by
the House of Representatives in June 202591
. Civil society criticised the proposed system,
saying that it falls short of international standards, given it would nearly entirely rely on self-
responsibility and a “naming-and-shaming” mechanism, and does not require mandatory
follow-up to the advice received92
. Given the advances made in the legislative process, there
has been significant further progress on rules on revolving doors.
Limited progress has been made on the recommendation on transparency of lobbying93,
as the Government announced some procedural improvements but a substantial reform
of existing rules has not yet taken place. Following calls for a transparency register for
ministers and state secretaries, and a first study on how transparency could be promoted in the
82
Ministry of Justice (2025a), p. 5 and Minister-President’s Office (2025).
83
Country visit the Netherlands, Transparency International.
84
2024 Rule of Law Report, the Netherlands pp. 16-17, Country visit the Netherlands, Transparency
International and Civil Liberties Union for Europe (2025), pp. 746-748.
85
Parliament (2025), pp. 5-6.
86
Following media reports on the matter, Transparency International sent a letter on the matter to GRECO.
2024 Rule of Law report, the Netherlands, p. 16-17.
87
Country visit the Netherlands, Transparency International.
88
Civil Liberties Union for Europe (2025), pp. 746-748.
89
The 2024 Rule of Law Report recommended the Netherlands to ‘Complete the revision of rules on revolving
doors involving former ministers and state secretaries, including a two-year cooling-off period and restrictions
on paid activities’.
90
The Draft Law on Rules follow-up functions of Ministers and State Secretaries 2023 was introduced in
parliamentary procedure in April 2024. See 2023 Rule of Law Report, the Netherlands, pp. 14-15 and 2024
Rule of Law Report, the Netherlands pp. 17-18.
91
House of Representatives (2025)
92
TI, NHC, FPU and NJC input (2025), p. 14 and Civil Liberties Union for Europe (2025), p. 744.
93
The 2024 Rule of Law Report recommended the Netherlands to ‘establish stricter transparency rules on
lobbying for members of the Government and Parliament’.
11
Government94
, a second study was published in 202495
. These studies have questionned the
effectiveness of the existing system96
. The latest study recommends stronger measures to
ensure transparency of lobbying, such as a transparency register97
. As a follow-up, the
Government announced procedural improvements to the existing system, such as simplifying
the page where the agendas are published and providing further guidance to ministers on how
these should be published. It however explicitly ruled out, for the time being, a more substantial
reform of the existing system or the creation of a transparency register98
. While the policy
options have not been decided yet, the government initiated consultations with relevant
stakeholders regarding the establishment of a transparency register, should this option be
considered in the future99
. Civil society organisations have argued that, as shown by the study,
only a transparency register can bring the necessary efficiency and transparency, and continued
to criticise the lack of effectiveness of the existing system100
. Given the procedural
improvements made, but as a substantial reform has not taken place yet, there has been limited
progress as regards transparency of lobbying.
The Political Parties Act was submitted to Parliament, following advice from the Council
of State. The draft new Political Parties Act was submitted to Parliament in May 2025101
. The
Act introduces transparency rules on the organisation of political parties. It would also
incorporate the existing Act on Political Party Financing102
. The Act also enables the financing
of local political parties. The Ministry of Internal Affairs revised the legislation in particular as
regards bans or limits on foreign donations. The Council of State had initially recommended to
further elaborate these provisions103
.
Debate is ongoing over a revision of the whistleblower legislation. Possible amendments to
the whistleblower legislation104
, such as introducing anonymous reporting, and supervisory and
sanctioning powers for the Whistleblower’s Authority , are being considered105
. They were
also called for by civil society106
. The Whistleblower’s Authority and civil society highlighted
the complexity of the legislation and the difficulty to meet the “public interest” criterion, which
is required for protecting persons reporting on wrongdoings, other than violations of EU law,
94
This study concluded that instead of implementing a lobbying register, the Government should strengthen the
rules on transparency already in place, namely the publishing of ministerial agendas and legislative footprints,
see also the 2024 Rule of Law Report, the Netherlands, pp. 18-19.
95
Leiden University (2024).
96
The existing system relies on the publishing of legislative footprints, of an overview of the stakeholders
consulted in the legislative process, of ministerial agendas, of appointments of ministers by disclosing subject
of the appointment and the contact person under the sole responsibility of each member of Government. 2024
Rule of Law Report, the Netherlands, pp. 18-19.
97
Leiden University (2024), pp. 4-8 and pp. 51-52.
98
Ministry of Internal Affairs and Kingdom Relations (2025a).
99
This step was also among the recommendations from the previously mentioned studies. The results of these
consultations will be shared with Parliament immediately after the summer of 2025.
100
Transparency International (2025a, b).
101
Country visit the Netherlands, Ministry of Interior and Kingdom Relations and Dutch Government (2025e).
102
The Political Parties Act aims to regulate, amongst other provisions, foreign parties’ activities and includes a
prohibition on parties that “present a clear and present danger of undermining or abolishing the democratic
rule of law”. 2024 Rule of Law Report, pp. 18-19.
103
Council of State (2024).
104
In force since 2023 and aimed at transposing the EU Directive on whistleblower protection. 2023 Rule of
Law Report, the Netherlands, p. 16.
105
Dutch Government (2025), written input, p. 10.
106
Transparency International (2024b).
12
within the meaning of the whistleblower law107
. Current reports stem mainly from the private
sector108
and concern unsafe environments at work109
. There is no specific data on the number
of reports that relate to corruption.
Work continues on targeting bribery of government officials by organised crime and on
the identification of other priority sectors. The Flash Eurobarometer on Businesses’ attitudes
towards corruption in the EU shows that 19% of companies in the Netherlands (EU average
25%) think that corruption has prevented them from winning a public tender or a public
procurement contract in the last three years110
. The Single Market and Competitiveness
Scoreboard on access to public procurement in the Netherlands reports 19% of single bids for
2023 (EU average 29%) and 64% of businesses perceive the level of independence of the public
procurement review bodies (district courts) as very or fairly good111
. Public procurement is
seen as one of the main areas at high risk of corruption in the country112
. The National Risk
Assessment on Corruption, commissioned in April 2024, is expected to be finalised by the end
of 2025113
. A specific governmental programme on combating subversive organised crime
continues, with corruption considered part of this approach and corruption risks in public and
private bodies being assessed114
. As threats towards local politicians have intensified, an
evaluation recommends reforming the Network of Resilient Governance115
. The proposed
legislation on increased municipal risk screening remains in the legislative process116
. The
health sector remains particularly at risk of corruption. The public private partnership between
FIOD-ACC and the banking sector therefore focuses on the health sector to detect corruption
amongst healthcare professionals117
. The Whistleblower’s Authority is currently screening the
integrity of management systems in hospitals and will issue guidelines for hospitals in 2025118
.
III. MEDIA PLURALISM AND MEDIA FREEDOM
The media regulator continues to operate efficiently and independently. The media
regulator followed up on the recommendations of the Committee119
set-up by the foundation
for public broadcasting (‘NPO’) to investigate misconduct and unsafe working environments
within national public broadcasters. For instance, it reported on the action plans it had asked
107
Whistleblower’s Authority (2025), p. 11, TI, NHC, FPU and NJC input (2025), p. 18, Transparency
International (2024b) and Country visit the Netherlands, Whistleblower’s Authority and Transparency
International.
108
Country visit the Netherlands, Whistleblower’s Authority.
109
Threats, intimidation, abuse of power, etc.
110
Flash Eurobarometer 557 on Businesses’ attitudes towards corruption in the EU (2025). This is 6 percentage
points below the EU average.
111
Figure 59, 2025 EU Justice Scoreboard.
112
2024 Rule of Law Report, the Netherlands, p. 20.
113
The risk assessment will be carried out by the WODC and aims to identify the largest corruption threats, the
overall risk-level of these threats as well as potential resilience against corruption in the public and private
sectors at a local, provincial and national level. This is one of the four different risk assessments that are
ongoing. 2024 Rule of Law Report, The Netherlands p. 12; Ministry of Foreign Affairs (2024a), p. 7 and
Ministry of Justice (2025a), pp. 6-7.
114
2024 Rule of Law Report, the Netherlands, pp. 12-13 and Ministry of Foreign Affairs (2024a), p. 6.
115
Dutch School for Public Administration (2024).
116
Dutch Government (2025), written input, pp. 9-10 and Country visit the Netherlands, Ministry of Justice and
Ministry of Interior.
117
Ministry of Foreign Affairs (2024a), p. 8 and Dutch Government (2025), written input, p. 11, and TI, NHC,
FPU and NJC (2025), p. 19. This follows a large corruption case at a major cardiology department, see 2024
Rule of Law Report, pp. 20-21.
118
Country visit the Netherlands, Whistleblower’s Authority.
119
Investigation Committee on Conduct and Culture of Broadcasters (OGCO).
13
all public broadcasters and their umbrella organisation – the ‘NPO’120
– to submit, emphasising
the need for strong leadership, improved supervision, and renewed ethical standards to support
long-term cultural change121
. It also adopted a Multiannual Strategy 2025-2030, which
focusses on strengthening news services, ensuring a well-functioning public media landscape,
and creating a safer online environment for minors, acknowledging the growing influence of
social media and AI-driven content distribution122
.
Steps have been taken to address certain concerns about the adequacy of the Press
Council123. The Press Council took action in response to concerns from several media outlets
that it was increasingly being used as a preparatory step for legal proceedings, undermining its
role as a self-regulatory, non-judicial body. Questions had also been raised on its ability to
handle complex cases124
. To counter this, the Press Council, for instance, introduced limitations
on the volume and complexity of complaints it will look at, aiming to prioritise cases where its
mediation role can be the most efficient125
. It also introduced a new policy requiring
complainants to waive legal action regarding the same publication if they wish to submit their
case to the Council126
. Whilst complainants and respondents may be assisted by lawyers, the
Council encourages direct participation to avoid hearings becoming more formal than intended
by this ’self-regulatory’, free of charge and voluntary procedure. While it is still too early to
fully assess the impact of these changes, NGOs and the Dutch Journalists’ Association (NVJ)
have expressed cautious optimism. They also underline the importance of broad media
participation in the Council system, which still enjoy support from most major outlets127
.
The Government had prepared a reform of the public service media, marking some
progress on the recommendation to strengthen its governance and capacity to uphold
journalistic standards128. Preparatory work is underway for a legislative proposal on the
reform of public service media to be carried out in line with the European Media Freedom Act
(EMFA) and expected to be tabled in 2026129
. In preparation for this legislative proposal, a
detailed policy letter was issued in May 2025130
. It proposes to reduce the number of public
service media outlets and outlines concrete measures to strengthen editorial independence,
journalistic standards and oversight. New accountability mechanisms would also be
introduced, and the current licensing system abolished. A policy letter providing additional
details is to be issued. In parallel, confirmed annual budget cuts starting in 2027131
have raised
concerns about the ability of the public broadcaster to continue fulfilling its mandate across all
120
Nederlandse Publieke Omroep.
121
Country visit, the Netherlands, Dutch media regulator.
122
NPO (2024).
123
2024 Rule of Law Report, the Netherlands. The Press Council (Raad voor de Journalistiek) monitors
journalistic ethical standards and examines complaints about potential violations of good journalistic practice.
It can issue opinions, which are made public. Unlike courts, it cannot impose rectifications or sanctions.
124
NGOs (2025), written input, p. 23.
125
Press Council (2023).
126
Press Council (2025), written input, p. 11.
127
NGOs (2025), written input, p. 23, and country visit the Netherlands, Dutch Journalists’ Association.
128
The 2024 Rule of Law Report recommended the Netherlands to ‘Enhance the governance of public service
media and its ability to uphold journalistic standards, taking into account European standards on public
service media’.
129
Dutch Government (2025), written input p. 8.
130
Dutch government (2025).
131
As confirmed by the Ministries and NPO during the country visit, the Dutch government announced three
cuts to the NPO’s 2027 budget (i.e. 10% of the current budget): EUR 100 million in early 2024, EUR 6.6
million in October 2024 as part of wider subsidy reductions, and EUR 50 million in December 2024.
14
platforms and audiences132
. Concerns have also been raised following the announcement of
VAT increases on cultural goods, including print and online media, given their potential impact
on the revenue of media outlets133
. In response, Parliament submitted a motion urging the
Government to consider alternatives. Discussions on this matter are still ongoing134
. The
Government is also working on a proposal to support public local and regional news media135
.
Given the preparatory steps taken to reform public service media, some progress is noted on
this recommendation.
Challenges related to a high level of media market concentration and limited media
ownership transparency remain. The Government had announced a legislative proposal for
the implementation of EMFA provisions on the assessment of media market concentrations
with potentially significant impact on media pluralism and editorial independence136
. The
media regulator faces challenges in accessing full information about media ownership,
especially in complex financial structures for the purposes of its Media Monitor137
. The media
regulator sees the requirements under EMFA as positively contributing to increasing ownership
transparency. The merger between DPG Media and RTL Nederland was conditionally
approved by the Dutch Authority for Consumers and Markets (Autoriteit Consument & Markt)
in June 2025, concluding a lengthy investigation into its implications for market dominance
and media diversity. To safeguard editorial independence and ensure continued access to
pluralistic news, the ACM imposed a set of structural conditions138
. Prior to the decision, while
the media regulator noted that the consolidation of the media market would help domestic
media to compete with large international players139
, stakeholders had criticised it inter alia for
its potential negative impact on media pluralism, the ability of other media to compete for
advertising, and the potential increase in uncertainty about working conditions of (freelance)
journalists140
. The Media Pluralism Monitor 2025 observes that while risks to media market
plurality are medium-high, editorial independence continues to be assessed at very low risk141
.
Efforts continued to improve transparency and access to information. A central dashboard
aiming to improve the processing of requests for access to information is publicly available
since 1 January 2025. Additionally, the Government maintains a dialogue with an advisory
board and journalists to identify challenges to access governmental documents and potential
solutions142
. The Government will also conduct a study to gain better insights into the concrete
132
Country visit, the Netherlands, NPO.
133
NGOs (2025), written input, pp. 24-25.
134
Dutch Government (2025), written input, p. 8.
135
Voorstel Wet versterking lokale publieke omroepen; NGOs (2025), written input, p. 27. This reform aims to
professionalise the sector at local level, increase independence, and introduce direct state funding (EUR 18
million).
136
Ministries (2025), written input, pp. 14-15.
137
Country visit the Netherlands, Media regulator. The Media Monitor is the media regulator’s annual
publication that tracks developments in the media landscape, particularly regarding media concentration,
diversity and pluralism.
138
RTL Nieuws and NU.nl must remain free to access online, produced by separate editorial teams with no
content or data sharing, and governed by independent foundations empowered to veto key editorial decisions.
Additionally, DPG Media is required to formalize editorial budget processes and may not sell or discontinue
national news outlets without the consent of a media plurality watchdog, Stichting Democratie en Media. The
ACM also concluded that the deal would not affect the negotiating position of either employed or freelance
journalists. (source: NL Times article, Dutch regulator approves DPG Media-RTL Nederland merger;
Journalism quality must remain, 27 June 2025)
139
Media regulator (2025), written input, p. 4.
140
NGOs (2025), written input, pp. 22-23; Country visit the Netherlands, Dutch Association of Journalists.
141
Media Pluralism Monitor (2025), pp. 17, 18, 21.
142
The repository is known as the ‘Woo index’. Dutch Government (2025), written input, pp. 15-16.
15
administrative burden resulting from the Open Government Act. The results of this study will
be the basis for an evaluation of the Act, foreseen at the end of 2025, and potential improvement
measures. Proactive disclosure is also promoted through a central repository143
. Meanwhile,
some concerns remain notably on delays in processing requests144
due to multiple legal and
political reviews required for the release of information145
.
The safety of journalists has improved. The PersVeilig initiative has been lauded by
stakeholders146
and has continued its important role in enhancing the safety of journalists, both
online and offline. It will receive a structural funding of EUR 500 000 annually and become a
foundation, with a board comprised of representatives of public service media, publishers and
the Dutch Association of Journalists147
. Since the criminalisation of doxing148
, only a few cases
of journalists’ doxing have been reported, and an informal inquiry has shown that the number
of cases decreased149
. Despite these improvements, journalists are still victims of threats150
.
Stakeholders raised concerns about political interference, intimidation and the hardening
political rhetoric towards journalists, especially those working for the public broadcaster. Civil
society organisations warn that this environment can create a chilling effect – discouraging
journalists from covering certain topics or expressing critical views – ultimately affecting press
freedom and contributing to a decline in perceived safety151
. Since the publication of the 2024
Rule of Law report, one alert from May 2024 was registered on the Council of Europe’s
Platform concerning a journalist threatened with death152
. The Mapping Media Freedom
platform has identified 22 alerts153
. The Government is preparing a legal proposal to implement
the anti-SLAPP Directive, aiming for adoption by May 2026. The proposal has been subject to
consultation and advice from the Advisory Division of the Council of State154
. NGOs called
for the inclusion of the Directive’s definition of SLAPPs, stronger safeguards such as early
dismissal and full cost compensation, and an extension to domestic cases155
. While SLAPPs
are not seen as a systemic issue in the Netherlands, concerns persist about their potential
impact, and a full assessment is challenging due to limited reporting mechanisms156
. The
143
Dutch Government (2025), written input, pp. 9-10.
144
NGO investigations reveal that central government authorities take an average of 172 days to respond to
freedom of information (FOI) requests exceeding the legal maximum of 42 days (NGOs (2025), written input,
p. 31).
145
NGOs (2025), written input, p. 31 and country visit the Netherlands, Dutch Association of Journalists.
146
Country visit the Netherlands, Dutch Association of Journalists (NVJ), NPO, and NDP Nieuwsmedia.
147
Country visit the Netherlands, Dutch Government (2024), as also confirmed by the Ministry of Education,
Culture and Science (2025) during the country visit.
148
As defined by Reporters without Borders on their website, Doxing is a form of online harassment in which a
target’s personal and sensitive information is posted publicly on the internet with the intent of causing harm,
intimidating the victim and damaging their reputation, and is regularly used against journalists.
149
Ministries (2025), written input, p. 11.
150
Country visit the Netherlands, NVJ. The Press Council has also noted that more journalists report being
threatened to refrain them from doing their job; Press Council (2025), second badge of written input, p. 1.
151
NGOs (2025), written input, pp. 25, 26, 30.
152
Council of Europe Platform to promote the protection of journalism and safety of journalists (2025). The
national authorities have since replied to the report.
153
As of March 2025, the Mapping Media Freedom Platform has registered 22 alerts concerning the Netherlands,
including cases of intimidation, pre-publication legal warnings or injury. Mapping Media Freedom (2025).
154
Ministries (2025), written input, p. 16.
155
CASE (2024); NGOs (2025), written input, p. 34; Country visit the Netherlands, NGOs, NPO and NDP
Nieuwsmedia.
156
Country visit the Netherlands, NVJ.
16
Government will further monitor developments in dialogue with stakeholders and the Council
for the Judiciary157
.
IV. OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES
Some progress was made on the recommendation to follow up on the proposals of the
State Commission on the Rule of Law, with a series of measures taken by state
authorities158
. The State Commission159
presented its final Report on 10 June 2024, with ten
proposals aimed at strengthening the legal protection of citizens. These proposals notably cover
the strengthening of a rule of law culture among Government officials, politicians and civil
servants, enhanced access to information and justice for citizens, further possibilities for
constitutional review of legislation and significant investments in the judiciary and legal aid.
The State Commission also called for a structured dialogue between the state powers based on
a ‘rule of law agenda’160
. The Government already welcomed the idea of a structured dialogue
between the state powers161
. Parliament established a Temporary Committee on Human Rights
and Constitutional Review and called in November 2024 on the Government to present a plan
of action with proposals for monitoring and strengthening the rule of law162
. On 21 February
2025 the Government put forward an outline of future proposals to enable judicial
constitutional review of legislation, as well as the establishment of a Constitutional Court163
. It
also expressed the intention to restructure the Administrative Jurisdiction Division of the
Council of State164
. The Council for the Judiciary observed a trend of more attention being
dedicated by courts to the legal protection of citizens in administrative cases165
. At the same
time, together with the Bar association, NIHR and several CSOs, it expressed concerns
regarding the Government’s plan to introduce automated decision-making in administrative
processes and to abolish appeal procedures in the areas of asylum and environmental
protection166
. Overall, there has been some progress on ensuring an adequate follow-up to the
recommendations of the State Commission on the Rule of Law, strengthening the legal
protection of citizens.
Shortcomings in the consultation of stakeholders on a legislative package with important
legal and social consequences have given rise to serious concerns. As a general practice, the
Government involved stakeholders by means of online consultations during the drafting
157
Ministries (2025), written input, p. 16.
158
The 2024 Rule of Law Report recommended the Netherlands to ‘Ensure an adequate follow-up to the
recommendations of the State Commission on the Rule of Law, strengthening the legal protection of citizens’.
159
Decree of 10 February 2023, No 2023000364 establishing a State Commission on the rule of law.
160
State Commission on the Rule of Law (2024).
161
Dutch Government (2025), written input, p. 17; The Council for the Judiciary called for this dialogue to focus
on the functioning of the democratic rule of law, for instance on unjust or restrictive legislation. Council for
the Judiciary (2025), written input, p. 3. The Ombudsperson called on the Government to follow up to his
report on ways to repair damages suffered by citizens due to Government action; National Ombudsman,
(2023).
162
Motion tabled on 21 November 2024; Country visit the Netherlands, Parliament.
163
Dutch Government (2025a).
164
Dutch Government (2025b), p. 17. The situation in which some Council of State councillors combine both
advisory and judiciary functions has been phased out; Country visit, Council of State.
165
Country visit the Netherlands, Council for the Judiciary.
166
Council for the Judiciary (2025), written input, p. 2; Bar Association (2025), written input, pp. 1, 2 referring
to the report on the rule of law quality of the Government programme; NIHR (2025), written input, pp. 8, 9;
NJCM indicated that this could be a violation of the Convention on access to information, public participation
in decision-making, and access to justice in environmental matters, Aarhus, 25 June 1998. Country visit the
Netherlands, NJCM.
17
process of legislation167
. In December 2024, the Government bypassed the regular consultation
process regarding important legislative proposals in the area of migration and asylum, only
allowing for a limited consultation with very short deadlines168
. The Council of State strongly
criticised the lack of due consultation of the judiciary and other stakeholders, considering the
limitation of the number of organisations that were given an opportunity to submit their views
and the short deadline that was given to them169
. The Netherlands Institute for Human Rights
emphasised in a letter to the Government and to Parliament the importance of a thorough,
transparent and inclusive procedure for adopting legislation in a democratic state based on the
rule of law and the safeguarding of human rights170
. The Ombudsperson and the Children's
Ombudsperson issued a joint letter arguing that the measures violate children's rights and
demonstrate improper administration171
. Several CSOs warned that the handling of the
consultation process could be considered a worrying precedent for future legislative
processes172
.
The Netherlands Institute for Human Rights has taken measures to address its
governance issues. The Netherlands Institute for Human Rights (NIHR) is accredited with an
A-status173
. To address governance issues, based on the findings of a committee of enquiry174
,
the NIHR has drafted administrative regulations175
and was, as of June 2025, recruiting a new
chairperson and vice chairperson. Further college members were appointed as well176
. The
Government has been preparing amendments to the Act on the NIHR to guarantee the full
implementation of its new mandate of National Prevention Mechanism177
. The NIHR has called
for an expansion of the scope of the Equal Treatment Act to allow it to also examine complaints
on discrimination resulting from unilateral governmental action. It called for additional
resources, also in view of its new mandate to examine complaints on discrimination in the
Caribbean part of the Netherlands178
.
Over two thirds of the companies surveyed in the Netherlands express confidence in the
effectiveness of investment protection. 68% of companies are very or fairly confident that
investments are protected by law and courts179
. Stakeholders confirmed that they do not see an
issue with investment protection in the Netherlands. As regards authorities relevant for
167
VNO-NCW reports to be generally consulted on draft legislation. Country visit, VNO-NCW.
168
Country visit the Netherlands, Council for the Judiciary, Dutch Association for the Judiciary, Bar Association,
and NJCM; DutchNews (2025).
169
Council of State (2025).
170
NIHR (2025), written input, p. 9; NIHR (2024); Country visit the Netherlands, NIHR: ‘From a human rights
perspective, a thorough procedure is required to weigh all interests. It must be clear which impact a proposed
measure will have on human rights, also in its execution’.
171
Ombudsmen (2025).
172
Country visit the Netherlands, NJCM.
173
Accreditation is provided by the Global Alliance of National Human Rights Institutions (GANHRI). The
NIHR was re-accredited in December 2020, see GANHRI (2020). Accreditation is based on the 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.
174
Dutch Government (2025), written input, p. 17. 2024 Rule of Law Report, the Netherlands, p. 28.
175
The regulations were adopted on 17 February 2025. Country visit the Netherlands, Netherlands Human Rights
Institute.
176
Country visit the Netherlands, NIHR; On 24 March 2025, two new college members were appointed.
177
National Preventive Mechanism under the Optional Protocol to the UN Convention Against Torture and other
Cruel, Inhuman or Degrading Treatment or Punishment.
178
NIHR (2025), written input, p. 4.
179
Figure 55, 2025 EU Justice Scoreboard. Only 12% of the surveyed investors perceive the frequent changes
in legislation, or concerns about the quality of the law-making process, and the quality, efficiency or
independence of justice, as a reason for the lack of confidence in investment protection.
18
economic operators, 75% of companies perceive the level of independence of the national
competition authority (the Authority for Consumers and Markets) as very or fairly good180
. 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 the annulled administrative act, and to award
direct and consequential damages and compensation181
.
On 1 January 2025, the Netherlands had 7 leading judgments of the European Court of
Human Rights pending implementation, an increase of 2 compared to the previous
year182. At that time, the Netherlands’ rate of leading judgments from the past 10 years that
had been implemented was at 59% (compared to 67% in 2024; 41% remained pending), and
the average time that the judgments had been pending implementation was 3 years and 2
months (compared to 3 years and 9 months in 2024)183
. The oldest leading judgment, pending
implementation for more than 8 years, concerns the de facto irreducibility of a life sentence
imposed on a prisoner suffering from mental illness184
. As regards the respect of payment
deadlines, on 31 December 2024 there were no cases awaiting confirmation of payments (same
as in 2023)185
. On 16 June 2025, the number of leading judgments pending implementation had
increased to 10186
.
The space for civil society organisations has narrowed and is affected by a combination
of funding cuts and a risk of new legal obstacles. The Netherlands’ civil society landscape
has narrowed187
. Several CSOs point to a change in the general political discourse questioning
their legitimacy, agenda and sources of funding188
. The NIHR and CSOs expressed serious
concerns about the impact of large funding cuts on human rights defenders and civil society,
both nationally and internationally. The NIHR called on the Government to ensure access to
resources for civil society to enable them to perform their function effectively, ensuring respect
for the right of association189
. The draft law on Transparency of CSOs was adopted by the
House of Representatives on 1 April 2025. It is now pending in the Senate. The NIHR and
several CSOs remain concerned about legal certainty and alleged stigmatising effect of
180
Figure 60, 2025 EU Justice Scoreboard.
181
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.
182
For an explanation of the supervision process, see the website of the Council of Europe.
183
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. 7.
184
Judgment of the ECtHR, 10511/10, Murray v. the Netherlands, pending implementation since 2008.
185
Council of Europe (2025), p. 157.
186
Data according to the online database of the Council of Europe (HUDOC).
187
See the rating given by CIVICUS, ratings are on a five-category scale defined as: open, narrowed, obstructed,
repressed, and closed. The CIVICUS Monitor announced in a new report in December 2024 that it has
downgraded the Netherlands’ civic space to "Narrowed" in its annual ratings report. The rating change reflects
a persistent policy of repressing peaceful protests.
188
Netherlands Helsinki Committee, Free Press Unlimited, Transparency International Nederland, NJCM,
Lawyers for Lawyer and PILP (2025), written input, p. 43; Goede Doelen Nederland (2025), written input,
p. 17.
189
NIHR, written input, p. 14, 17; The Government announced a 70% cut of the budget for human rights
programmes. CSOs can only apply for these funds if at least 50% of their income comes from non-state
funding. Further cuts have been announced in the educational, culture and healthcare sector and tax benefits
on corporate donations are under discussion; Netherlands Helsinki Committee, Free Press Unlimited,
Transparency International Nederland, NJCM, Lawyers for Lawyer and PILP (2025), written input, p. 37.
19
reporting requirements190
. The Government is exploring ways to make a sharper distinction
between (peaceful) demonstrations and disruptive actions, while the NIHR voiced the concern
that this could lead to arbitrary decisions on the lawfulness of demonstrations and legal
uncertainty, discouraging demonstrations191
. The NIHR and several CSOs expressed concerns
about measures taken by public authorities192
, such as the use of emergency ordinances to
prohibit or disband protests, considering them to be disproportionate193
. The Government is
also exploring further representativeness requirements for CSOs initiating public interest
proceedings in court194
. The NIHR, the Dutch Association for the Judiciary and Bar
Association pointed out that additional requirements could negatively impact CSOs access to
court195
.
190
The draft aims to introduce transparency requirements to prevent donations undue foreign influence. The
draft provisions introduce the possibility to make targeted enquiries about foreign donations above a certain
threshold and for the Courts to impose penalties; NIHR (2025), written input, p. 11; Netherlands Helsinki
Committee, Free Press Unlimited, Transparency International Nederland, NJCM, Lawyers for Lawyer and
PILP (2025), written input, pp. 36, 37; Goede Doelen Nederland (2025), written input, p. 16; 2024 Rule of
Law Report, the Netherlands, p. 30.
191
Dutch Government (2024), p. 101; NIHR, written input, , p. 12. A study on the right to protest is currently
being conducted by the Scientific Research and Data Centre on the right to protest. The results of this study
are expected in the summer of 2025.
192
NIHR (2025), written input, p. 13; Country visit the Netherlands, Amnesty International; Netherlands
Helsinki Committee, Free Press Unlimited, Transparency International Nederland, NJCM, Lawyers for
Lawyer and PILP (2025), written input, p. 41; Civil Liberties Union for Europe (2025), pp. 781-784.
193
Netherlands Helsinki Committee, Free Press Unlimited, Transparency International Nederland, NJCM,
Lawyers for Lawyer and PILP (2025), written input, p. 40; Goede Doelen Nederland (2025), written input,
p. 17; Ministry of Internal Affairs and Kingdom Relations (2025).
194
Dutch Government (2024), p. 85; A comparative study under the auspices of the Scientific Research and Data
Centre published in June 2025 concluded that the current interpretation of the representativeness requirement
raises concerns under the Convention on access to information, public participation in decision-making and
access to justice in environmental matters, Aarhus, 25 June 1998; E. de Jong et al. (2025); Netherlands
Helsinki Committee, Free Press Unlimited, Transparency International Nederland, NJCM, Lawyers for
Lawyer and PILP (2025), written input, p. 38; Goede Doelen Nederland (2025), written input, p. 9; P.
Veerman, L. Bryk, M.B. Hendrickx (2024); Netherlands Helsinki Committee, Free Press Unlimited,
Transparency International Nederland, NJCM, Lawyers for Lawyer and PILP (2025), p. 38.
195
NIHR (2025), written input, p. 11; Dutch Association for the Judiciary(2025), written input, p. 20; Country
visit the Netherlands, Bar Association; Aarhus Convention, article 9 (access to justice). The Meijers
Committee called for representation requirements to either be eliminated for ideologic action or be adjusted
to incorporate qualitative factors. The Meijers Committee (2025), written input, p. 6.
20
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.
Algemeen Dagblad (2024), Judges are very worried: Dutch rule of law is at risk (Dutch original title in
Italics), https://www.ad.nl/binnenland/rechters-maken-zich-grote-zorgen-nederlandse-rechtsstaat-
loopt-gevaar~ad6e7bf8/.
Algemeen Dagblad (2025), Judge and partner intimidated online for ruling against entry ban on 'hate
preachers' (Dutch original in Italics), https://www.ad.nl/binnenland/rechter-en-partner-online-
geintimideerd-om-uitspraak-tegen-inreisverbod-haatpredikers~a4122c1f/.
Amnesty International (2024), Europe: Under Protected and Over Restricted: The state of the right to
protest in 21 European countries,
https://www.amnesty.org/en/documents/eur01/8199/2024/en/#:~:text=This%20report%20documents
%20an%20array%20of%20trends%20and,right%20to%20protest%20is%20protected%2C%20respect
ed%20and%20fulfilled.
Bar Association (2024), Exploratory study of the shortages in legal aid,
https://www.advocatenorde.nl/english/.
Bar Association (2025), Position Paper Bar Association, Round table out of court settlements, 17
March 2025 (if applicable: original title in Dutch),
https://www.advocatenorde.nl/standpunten/strafrecht-en-strafvordering/zsm.
Council of Europe Platform to promote the protection of journalism and safety of journalists (2025),
The Netherlands, https://fom.coe.int/en/pays/detail/11709554.
Council of Europe: Venice Commission (2023), The Netherlands - Opinion of the Venice Commission
on the legal safeguards of the independence of the judiciary from the executive power,
https://www.coe.int/en/web/venice-commission/-/cdl-ad-2023-029-e.
Council for the Judiciary (2025a), New Year's speech 2025 by the chairman of the Council for the
Judiciary, Henk Naves (Original title in Dutch), https://www.rechtspraak.nl/Organisatie-en-
contact/Organisatie/Raad-voor-de-rechtspraak/Nieuws/Paginas/Nieuwjaarstoespraak-Henk-
Naves.aspx.
Council for the Judiciary (2025b), New approach to prosecutors in handling criminal cases abolishes
imprisonment in certain crimes’ (Original title in Dutch), https://www.rechtspraak.nl/Organisatie-en-
contact/Organisatie/Raad-voor-de-rechtspraak/Nieuws/Paginas/Nieuwe-aanpak-OM-bij-afhandeling-
strafzaken-schaft-celstraf-bij-bepaalde-misdrijven-af.aspx.
Council of State (2024a), Advice on amended bill to amend the Penitentiary Principles Act’ (Original
title in Dutch),https://www.raadvanstate.nl/adviezen/@142806/w16-24-00063-ii/.
Council of State (2024b), Advice on the Law on Political Parties (Original title in Dutch),
https://www.raadvanstate.nl/adviezen/@143141/w04-24-00070/.
Council of State (2025), Advices on the Asylum Emergency Measures Act and the Introduction of the
Dual Status System Act (Original title in Dutch),
https://www.raadvanstate.nl/actueel/nieuws/februari/adviezen-asielnoodmaatregelen-tweestatus/.
21
Council of State (2025), Annual Report 2024 (Original title in Dutch),
https://www.raadvanstate.nl/jaarverslag2024/.
Court of Audit (2024), Integrity at the core (Original title in Dutch),
https://www.rekenkamer.nl/publicaties/rapporten/2024/09/10/integriteit-als-basis.
draft Law on Rules follow-up functions of Ministers and State Secretaries (Original title in Dutch),
https://www.tweedekamer.nl/kamerstukken/wetsvoorstellen/detail?qry=wetsvoorstel%3A36549&cfg
=wetsvoorsteldetails.
Dutch Government (2024), Amendment of the legislative proposal amending the Penitentiary Principles
Act in connection with additional measures against organised crime during detention (Original title in
Dutch),
https://www.tweedekamer.nl/kamerstukken/wetsvoorstellen/detail?cfg=wetsvoorsteldetails&qry=wets
voorstel%3A36372.
Dutch Government (2025a), Serious Crime Task Force makes criminal activities visible (Original title
in Dutch), https://www.nederlandtegengeorganiseerdemisdaad.nl/actueel/verhalen-uit-de-
praktijk/weblog/2024/serious-crime-taskforce-helpt-criminele-activiteiten-zichtbaar-maken.
Dutch Government (2025b), Coalition Agreement between PVV, VVD, NSC and BBB, Hope, Courage
and Pride – Main Line Agreement 2024-2028 (Hoop, Lef en Trots - Hoofdlijnenakkoord 2024 – 2028
van PVV, VVD, NSC en BBB), https://www.parlement.com/9291000/d/pdfs/hoofdlijnen2024.pdf.
Dutch Government (2025c), Outline note on constitutional review (Original title in Dutch),
https://www.rijksoverheid.nl/documenten/kamerstukken/2025/02/21/kamerbrief-over-contourennota-
constitutionele-toetsing.
Dutch Government (2025d), Policy note following WODC investigation on possibilities to fight
financial crime (TK Beleidsreactie WODC onderzoek evaluatie Wet verruiming mogelijkheden
bestrijding financieel economische criminaliteit Wet Finec),
https://www.rijksoverheid.nl/documenten/rapporten/2025/05/30/tk-beleidsreactie-wodc-onderzoek-
evaluatie-wet-verruiming-mogelijkheden-bestrijding-financieel-economische-criminaliteit-wet-finec
Dutch Government (2025e), Explanations on law political parties (Toezegging interne organistie
politieke partijen), https://open.overheid.nl/documenten/174faff6-28a4-46a5-907e-454d2f564152/file
Dutch Government (2025f), Letter to the House of Representatives on the anti-corruption policy
(Kamerbrief anti-corruptieaanpak), 20 June 2026, https://open.overheid.nl/documenten/1cb649ba-
5ebe-43d0-8e37-e82067b3f369/file.
DutchNews(2025), Ministers back "strictest ever" asylum plan despite criticism,
https://www.dutchnews.nl/2025/03/ministers-back-strictest-ever-asylum-plan-despite-criticism/.
Dutch School for Public Administration (2024), Threats and Protection: Mid-term evaluation of
network approach and the Network Resilient Government (Original title in Dutch),
https://www.nsob.nl/denktank/overzicht-van-publicaties/bedreiging-en-
bescherming#:~:text=Het%20NWB%20beschermt%20tegen%20regenachtige,de%20bescherming%2
0van%20het%20NetwerkReference%201,
European Centre for Press and Media Freedom (2025), Mapping Media Freedom, The Netherlands
country profile, https://www.mappingmediafreedom.org/.
European Public Prosecutor’s Office (EPPO) (2025), Annual Report 2024,
https://www.eppo.europa.eu/assets/annual-report-2024/index.html.
22
E. R. de Jong, W.H. van Boom, T.M.C. Arons & E. Erkens (2025), Comparative legal analysis of access
to justice of interest organizations in public interest litigation (Original title in Dutch),
https://repository.wodc.nl/bitstream/handle/20.500.12832/3455/summary-rechtsvergelijking-toegang-
tot-de-rechter-in-algemeenbelangacties.pdf?sequence=3&isAllowed=y.
House of Representatives (2022), Bill by member Sneller, Expiration of Special Powers of Design of
the Public Prosecution Service Act (Wet verval bijzondere aanwijzingsbevoegdheid openbaar
ministerie), 2021-2022 session, 36 125, no 2,
https://www.tweedekamer.nl/kamerstukken/wetsvoorstellen/detail?cfg=wetsvoorsteldetails&qry=wets
voorstel%3A36125#wetgevingsproces.
House of Representatives (2024), Motion by member Sneller on legislating to minimise the minister's
role in the appointment procedure for members of the Council for the Judiciary (Motie van het lid
Sneller over wettelijk regelen dat de rol van de minister bij de benoemingsprocedure voor leden van de
Raad voor de rechtspraak zo klein mogelijk wordt),
https://www.tweedekamer.nl/kamerstukken/moties/detail?id=2024Z03627&did=2024D0850.
1.
House of Representatives (2024), Motion by members Lahlah and others on present a plan of action
with proposals for monitoring and strengthening the rule of law (Dutch title in Italics),
https://www.eerstekamer.nl/behandeling/20241121/motie_van_het_lid_lahlah_c_s_over/document3/f
=/vmijh2s58mti.pdf.
House of Representatives (2025), Law on rules on revolving doors for Ministers and State Secretaries
(Wet regels vervolgfuncties bewindspersonen),
https://www.tweedekamer.nl/kamerstukken/wetsvoorstellen/detail?qry=wetsvoorstel%3A36549&cfg
=wetsvoorsteldetails.
Leiden University (2024), A Mosaic of Interests: Towards better insight in the involvement of externals
in public decision-making (Original title in Italics),
https://open.overheid.nl/documenten/70a1f74e-b1a3-4ea2-a487-65f1decfc065/file..
Minister-President’s Office (2025), Letter of the Minister-President to the Chair of the House of
Representatives (Original Dutch title in Italics).
Ministry of Foreign Affairs (2024a), Cabinet reaction to the European Commission’s 2024 Rule of Law
Report, Dutch Country Chapter, [hyperlink].
Ministry of Internal Affairs and Kingdom Relations (2025a), Cabinet reaction to the report “A Mosaic
of Interests” (Original title in Dutch),
https://www.tweedekamer.nl/kamerstukken/brieven_regering/detail?id=2025Z04230&did=2025D097
26.
Ministry of Internal Affairs and Kingdom Relations (2025b), Reaction to the report of the Court of
Audit “Integrity at the core” (Original Dutch title in Italics),
https://open.overheid.nl/documenten/56277b76-72ff-4178-8fe3-e0bac9c14189/file.
Ministry of Internal Affairs and Kingdom Relations (2025c), The exploration of a legal ban on face-
covering clothing at demonstrations (Original title in Dutch),
https://www.tweedekamer.nl/kamerstukken/brieven_regering/detail?id=2025Z07474&did=2025D169
96.
Ministry of Justice (2025a), Written contribution received following the country visit.
23
Ministry of Justice and Security, Letter to Parliament, Future of Legal Aid (Original Dutch title in
Italics), https://www.tweedekamer.nl/kamerstukken/detail?id=2025D13581&did=2025D13581.
Netherlands Institute for Human Rights (2024), Letter by the NIHR to the Standing committee on
Asylum and Migration of the Dutch Parliament (Original Dutch title in Italics),
https://www.mensenrechten.nl/actueel/nieuws/2024/12/18/index#:~:text=Het%20College%20voor%2
0de%20Rechten%20van%20de%20Mens,mensen%20in%20kwetsbare%20situaties%20zoals%20asie
lzoekers%20en%20statushouders.
NOS (2024), Chamber of Representatives wants clarity over business interests of Idsinga (Original
Dutch title in Italics), https://nos.nl/artikel/2542572-kamer-wil-helderheid-over-zakelijke-belangen-
staatssecretaris-idsinga.
NRC (2025), Public Prosecution and NIID: Dutch law for prosecuting corruption falls short (Original
Dutch title in Italics), https://www.nrc.nl/nieuws/2025/02/03/om-en-rijksrecherche-nederlandse-wet-
voor-vervolging-van-corruptie-schiet-tekort-a4881835.
Ombudsman (2023), National Ombudsman, Offering recovery: A profession, A comparative study of
ten recovery pathways (Original Dutch title in Italics),
https://www.nationaleombudsman.nl/system/files/bijlage/Herstel%20bieden%2C%20een%20vak%20
apart.pdf.
Ombudsman (2025), Ombudsmen warn minister Faber: effect of asylum measures disastrous for entire
society (Original Dutch title in Italics),
https://www.nationaleombudsman.nl/nieuws/artikel/2025/ombudsmannen-waarschuwen-minister-
faber-effect-asielmaatregelen-rampzalig-voor.
Open State Foundation (2024), Cabinet Schoof is not transparent (Original Dutch title in Italics),
https://openstate.eu/nl/2024/09/onderzoek-open-state-kabinet-schoof-is-niet-transparant-2/.
Parliament (2025), Written contribution received following the country visit.
Public Prosecution Service (2025a) Adjustment in the application of the penalty order and timeline for
further intensification, Aanpassing in toepassing van de OM-strafbeschikking en tijdpad verdere
intensivering | Nieuwsbericht | Openbaar Ministerie.
Public Prosecution Service (2025b), annual report 2024 (Original Dutch title in Italics),
https://www.om.nl/documenten/jaarverslagen/om/map/2019-en-verder/om-jaarbericht-2024.
State Commission on the Rule of Law (2024), The broken promise of the rule of law, Ten proposals for
improvement with an eye on the citizen (De gebroken belofte van de rechtsstaat, Tien
verbetervoorstellen met oog voor de burger),
https://www.staatscommissierechtsstaat.nl/onderwerpen/rapport/documenten/rapporten/2024/07/02/in
dex.
State Secretary for Legal Protection (2025), Reply by State Secretary Struyken to Member Lalah’s
questions on judicial independence (Original Dutch title in Italics),
https://www.rijksoverheid.nl/documenten/kamerstukken/2025/02/20/antwoorden-kamervragen-over-
de-onafhankelijkheid-van-de-rechtspraak.
Supreme Court (2022), Attorney General at the Supreme Court, Out of court, On the compliance of the
Public Prosecutor's Office with the law when issuing criminal summons (Original Dutch title in Italics),
https://www.hogeraad.nl/actueel/publicaties/toezicht-openbaar/.
24
Supreme Court (2025), Follow-up investigation by AG at the Supreme Court into the Public Prosecution
Service penalty order (Original Dutch title in Italics),
https://www.hogeraad.nl/actueel/nieuwsoverzicht/2025/maart/vervolgonderzoek-pg-hoge-raad-
strafbeschikking/.
Transparency International (2024a), Resignation Idsinga cause for concern and disappointing,
November 2024 (Original Dutch title in Italics),
https://www.transparency.nl/nieuws/2024/11/opstappen-idsinga-zorgelijk-en-teleurstellend/.
Transparency International (2024b), Commission debate Whistleblowing – promises of the minister
and expectations for 2025 (Original Dutch title in Italics),
https://www.transparency.nl/nieuws/2024/12/commissiedebat-klokkenluiders-toezeggingen-door-
minister-bzk-en-verwachtingen-voor-2025.
Transparency International (2024c), Prime Minister Schoof should take the lead in country-wide fight
against corruption (Original Dutch title in Italics),
https://www.transparency.nl/nieuws/2024/08/transparency-premier-schoof-moet-leiding-
nemen-in-rijksbrede-bestrijding-van-corruptie/.
Transparency International (2025a), Study University of Leiden – Cabinet has to go for a transparency
register (Original Dutch title in Italics), https://www.transparency.nl/nieuws/2025/01/rapport-
universiteit-leiden-kabinet-kan-niet-meer-om-lobbyregister-heen/.
Transparency International (2025b), Cabinet chooses status quo above lobby transparency (Original
Dutch title in Italics), https://www.transparency.nl/nieuws/2025/03/kabinet-verkiest-status-quo-boven-
transparantie-rond-lobby/.
Trouw (2025), Why the “polder model” hinders anti-corruption policy (Original Dutch title in Italics),
https://www.trouw.nl/binnenland/waarom-het-poldermodel-het-anti-corruptiebeleid-
bemoeilijkt~b2b16fb3/.
UN General Assessembl (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/.
van der Meer II Committee (2025), Changing times, A fair income in a future-proof system (Original
title in Dutch), https://www.raadvoorrechtsbijstand.org/actueel/nieuws/2025/2025-rapport-
comm-vandermeer/.
P. Veerman, L. Bryk, M. B. Hendrickx (2024), The obstacles of the WAMCA for idealistic actions
(Original title in Dutch), https://clara-wichmann.nl/wp-content/uploads/2024/10/De-Obstakels-van-de-
WAMCA-voor-Ideele-Acties-_BCW_PILP_Rapport_2024.pdf.
Winter (2024), Report exploring the workload of the judiciary and public prosecution service, working
towards real solutions (Original title in Dutch), Finale-versie-rapport-verkenner-Werkdruk-
publicatieversie-april-2024.pdfVolkskrant (2024), NSC State Secretary Idsinga resigns following
questions over private investments (Original title in Dutch), https://www.volkskrant.nl/politiek/nsc-
staatssecretaris-idsinga-treedt-af-na-vragen-over-privebeleggingen~b523fd87/.
Whistleblower’s Authority (2025), Written contribution received following the country visit.
25
Annex II: Country visit to The Netherlands
The Commission services held virtual meetings in February 2025 with:
• Amnesty International Netherlands
• Commissariaat voor de Media
• Dutch Foundation for Public Broadcasting
• Huis voor Klokkenluiders
• Fiscale Inlichtingen en Opsporingsdienst
• Commissie Meijers
• Free Press Unlimited
• Nederlands Juristencomité voor de Mensenrechten
• Nederlandse Orde van Advocaten
• Nederlandse Vereniging voor de Rechtsspraak
• Netherlands Helsinki Committee
• National Ombudsman
• National Police
• National Internal Investigations Department
• Prosecution service
• Raad voor de rechtsspraak
• State Commission on the functioning of the rule of law
• Supreme Court
• Transparency International
* 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