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
Date: 2025-07-08
Institutions: European Commission, Secretariat-General
Subjects: Netherlands, administrative transparency, corruption, democracy, freedom of the press, human rights, independence of the judiciary, pluralism in the media, rule of law, whistleblowing

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}  
 
 
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. 

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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’. 

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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). 

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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. 

4 

 
 
 
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. 

5 

 
 
 
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. 

6 

 
 
 
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. 

7 

 
 
 
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. 

8 

 
 
 
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).  

9 

 
 
 
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’. 

10 

 
 
 
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). 

11 

 
 
 
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).  

12 

 
 
 
 
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. 

13 

 
 
 
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.  

14 

 
 
 
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. 

15 

 
 
 
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. 

16 

 
 
 
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. 

17 

 
 
 
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. 

18 

 
 
 
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. 

19 

 
 
 
Annex I: List of sources in alphabetical order* 

* The list of contributions received in the context of the consultation for the 2025 Rule of Law report 
can  be 
  https://commission.europa.eu/publications/2025-rule-law-report-targeted-
stakeholder-consultation_en.  

found  at 

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' 
in  Italics),  https://www.ad.nl/binnenland/rechter-en-partner-online-
geintimideerd-om-uitspraak-tegen-inreisverbod-haatpredikers~a4122c1f/. 

(Dutch  original 

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 
in  Dutch),  https://www.rechtspraak.nl/Organisatie-en-
contact/Organisatie/Raad-voor-de-rechtspraak/Nieuws/Paginas/Nieuwjaarstoespraak-Henk-
Naves.aspx. 

title 

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/. 

20 

 
 
Council 
https://www.raadvanstate.nl/jaarverslag2024/.  

(2025),  Annual  Report 

State 

of 

2024 

(Original 

title 

in  Dutch), 

Court 
Integrity 
https://www.rekenkamer.nl/publicaties/rapporten/2024/09/10/integriteit-als-basis. 

of  Audit 

(Original 

(2024), 

core 

the 

at 

title 

in  Dutch), 

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 
https://www.nederlandtegengeorganiseerdemisdaad.nl/actueel/verhalen-uit-de-
praktijk/weblog/2024/serious-crime-taskforce-helpt-criminele-activiteiten-zichtbaar-maken. 

Dutch), 

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 
Finec), 
https://www.rijksoverheid.nl/documenten/rapporten/2025/05/30/tk-beleidsreactie-wodc-onderzoek-
evaluatie-wet-verruiming-mogelijkheden-bestrijding-financieel-economische-criminaliteit-wet-finec 

economische 

criminaliteit 

financieel 

Wet 

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 
"strictest 
https://www.dutchnews.nl/2025/03/ministers-back-strictest-ever-asylum-plan-despite-criticism/. 

despite 

asylum 

ever" 

back 

plan 

criticism, 

Dutch  School  for  Public  Administration  (2024),  Threats  and  Protection:  Mid-term  evaluation  of 
network  approach  and 
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,  

the  Network  Resilient  Government 

(Original 

title 

European  Centre  for  Press  and  Media  Freedom (2025),  Mapping Media  Freedom,  The  Netherlands 
country profile, https://www.mappingmediafreedom.org/.  

European 
https://www.eppo.europa.eu/assets/annual-report-2024/index.html. 

Prosecutor’s  Office 

(EPPO) 

Public 

(2025), 

Annual 

Report 

2024, 

21 

 
 
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), 
2, 
https://www.tweedekamer.nl/kamerstukken/wetsvoorstellen/detail?cfg=wetsvoorsteldetails&qry=wets
voorstel%3A36125#wetgevingsproces. 

2021-2022 

session, 

125, 

no 

36 

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 
wordt), 
https://www.tweedekamer.nl/kamerstukken/moties/detail?id=2024Z03627&did=2024D0850.
1. 

rechtspraak 

mogelijk 

klein 

voor 

de 

zo 

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  
bewindspersonen), 
(Wet 
https://www.tweedekamer.nl/kamerstukken/wetsvoorstellen/detail?qry=wetsvoorstel%3A36549&cfg
=wetsvoorsteldetails.  

vervolgfuncties 

regels 

Leiden University (2024), A Mosaic of Interests: Towards better insight in the involvement of externals 
in 
Italics),  
https://open.overheid.nl/documenten/70a1f74e-b1a3-4ea2-a487-65f1decfc065/file.. 

decision-making 

(Original 

public 

title 

in 

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 
Dutch), 
https://www.tweedekamer.nl/kamerstukken/brieven_regering/detail?id=2025Z04230&did=2025D097
26. 

Interests” 

(Original 

title 

in 

Ministry of Internal Affairs and Kingdom Relations (2025b), Reaction to the report of the Court of 
Italics), 
Audit 
https://open.overheid.nl/documenten/56277b76-72ff-4178-8fe3-e0bac9c14189/file.  

“Integrity 

(Original 

Dutch 

core” 

title 

the 

in 

at 

Ministry of Internal Affairs and Kingdom Relations (2025c), The exploration of a legal ban on face-
Dutch), 
covering 
https://www.tweedekamer.nl/kamerstukken/brieven_regering/detail?id=2025Z07474&did=2025D169
96. 

demonstrations 

(Original 

clothing 

title 

in 

at 

Ministry of Justice (2025a), Written contribution received following the country visit. 

22 

 
 
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 
Italics), 
Asylum  and  Migration  of 
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. 

the  Dutch  Parliament 

(Original  Dutch 

title 

in 

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 
Italics), 
https://www.nationaleombudsman.nl/system/files/bijlage/Herstel%20bieden%2C%20een%20vak%20
apart.pdf. 

pathways 

(Original 

recovery 

Dutch 

title 

in 

Ombudsman (2025), Ombudsmen warn minister Faber: effect of asylum measures disastrous for entire 
society 
Italics), 
https://www.nationaleombudsman.nl/nieuws/artikel/2025/ombudsmannen-waarschuwen-minister-
faber-effect-asielmaatregelen-rampzalig-voor. 

(Original 

Dutch 

title 

in 

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 
burger), 
https://www.staatscommissierechtsstaat.nl/onderwerpen/rapport/documenten/rapporten/2024/07/02/in
dex. 

voor 

oog 

met 

de 

State  Secretary  for  Legal  Protection  (2025),  Reply  by  State  Secretary  Struyken  to  Member  Lalah’s 
questions 
Italics), 
https://www.rijksoverheid.nl/documenten/kamerstukken/2025/02/20/antwoorden-kamervragen-over-
de-onafhankelijkheid-van-de-rechtspraak. 

independence 

(Original 

judicial 

Dutch 

title 

on 

in 

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/. 

23 

 
 
Supreme Court (2025), Follow-up investigation by AG at the Supreme Court into the Public Prosecution 
Service 
Italics), 
(Original 
https://www.hogeraad.nl/actueel/nieuwsoverzicht/2025/maart/vervolgonderzoek-pg-hoge-raad-
strafbeschikking/. 

penalty 

Dutch 

order 

title 

in 

Transparency  International  (2024a),  Resignation  Idsinga  cause  for  concern  and  disappointing, 
November 
Italics),  
https://www.transparency.nl/nieuws/2024/11/opstappen-idsinga-zorgelijk-en-teleurstellend/. 

(Original 

Dutch 

2024 

title 

in 

Transparency  International  (2024b),  Commission  debate Whistleblowing  –  promises  of the  minister 
and 
Italics), 
https://www.transparency.nl/nieuws/2024/12/commissiedebat-klokkenluiders-toezeggingen-door-
minister-bzk-en-verwachtingen-voor-2025.  

expectations 

(Original 

Dutch 

2025 

title 

for 

in 

Transparency International (2024c), Prime Minister Schoof should take the lead in country-wide fight 
against 
Italics), 
https://www.transparency.nl/nieuws/2024/08/transparency-premier-schoof-moet-leiding-
nemen-in-rijksbrede-bestrijding-van-corruptie/. 

corruption 

(Original 

Dutch 

title 

in 

Transparency International (2025a), Study University of Leiden – Cabinet has to go for a transparency 
in  Italics),  https://www.transparency.nl/nieuws/2025/01/rapport-
register  (Original  Dutch 
universiteit-leiden-kabinet-kan-niet-meer-om-lobbyregister-heen/. 

title 

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 
in  Dutch),  https://www.raadvoorrechtsbijstand.org/actueel/nieuws/2025/2025-rapport-
title 
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. 

24 

 
 
 
 
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, 
• 
• 
•  JEF Europe 
•  Philea – Philanthropy Europe Association. 
•  Transparency International  

International Commission of Jurists  
International Federation for Human Rights (FIDH) 

25