COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report Country Chapter on the rule of law situation in Belgium Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Rule of Law Report The rule of law situation in the European Union
Date: 2025-07-08
Institutions: European Commission, Secretariat-General
Subjects: Belgium, 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) 901 final  COMMISSION STAFF WORKING DOCUMENT 2025 Rule of Law Report        Country Chapter on the rule of law situation in Belgium Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Rule of Law Report          The rule of law situation in the European Union {COM(2025) 900 final} - {SWD(2025) 902 final} - {SWD(2025) 903 final} - {SWD(2025) 904 final} - {SWD(2025) 905 final} - {SWD(2025) 906 final} - {SWD(2025) 907 final} - {SWD(2025) 908 final} - {SWD(2025) 909 final} - {SWD(2025) 910 final} - {SWD(2025) 911 final} - {SWD(2025) 912 final} - {SWD(2025) 913 final} - {SWD(2025) 914 final} - {SWD(2025) 915 final} - {SWD(2025) 916 final} - {SWD(2025) 917 final} - {SWD(2025) 918 final} - {SWD(2025) 919 final} - {SWD(2025) 920 final} - {SWD(2025) 921 final} - {SWD(2025) 922 final} - {SWD(2025) 923 final} - {SWD(2025) 924 final} - {SWD(2025) 925 final} - {SWD(2025) 926 final} - {SWD(2025) 927 final} - {SWD(2025) 928 final} - {SWD(2025) 929 final} - {SWD(2025) 930 final} - {SWD(2025) 931 final}  
 
 
ABSTRACT 

The  level  of  perceived  judicial  independence  in  Belgium  continues  to  be  high.  The 
Government  maintains  the  intention  to  transfer  budgetary  management  powers  for  the 
administration  of  the  justice  system  from  the  executive  to  the  judiciary.  Following  the 
adoption  of  directives  prohibiting  the  recording  of  meetings  between  lawyer  and  clients, 
lawyers  called  for  additional  procedural  safeguards  to  protect  legal  professional  privilege. 
Some  further  steps  have  been  taken  to  address  the  structural  resource  deficiencies  in  the 
justice system,  such  as the  publication of all open positions for magistrates and  court staff, 
although a long-term structural approach is required. The Government is addressing criticism 
by the Court of Audit on the management of the digitalisation of justice. Some further steps 
have  been  taken  to  improve  the  efficiency  of  justice,  particularly  to  reduce  the  length  of 
proceedings based on comprehensive statistical data.  

New investigative and prosecutorial structures also targeting corruption will be set up. Good 
cooperation between the Central Office for the Repression of Corruption and the prosecution 
service continues, although concerns exist on the handling of prominent high-level corruption 
cases.  Some  steps  are  under  consideration  to  strengthen  integrity  procedures  in  the  police. 
Shortcomings continue in the monitoring and enforcement of existing integrity policies, and 
in the verification and transparency of asset and interest declarations. The new Government 
has not yet taken a decision on whether to proceed with draft lobbying  rules. The House of 
Representatives  slightly  updated  its  rules  on  gifts  and  benefits,  while  gaps  in  rules  on 
“revolving doors”  remain. Increased  attention is  paid  to  addressing high  risks of corruption 
both at local level and linked to organised crime. 

Despite challenges, media regulatory authorities across Belgium have taken steps in adapting 
their  strategies  while  maintaining  a  strong  legal  foundation  for  their  independence.  Public 
service  media  in  Belgium  face  various  challenges  across  the  three  communities  including 
governance structures and budgetary pressures. Recent legislative developments led to some 
improvements regarding access to public documents, while further procedural improvements 
are needed. The Government took steps to strengthen legal protections for journalists, such as 
decriminalising  defamation  and  introducing  harsher  penalties  for  crimes  committed  against 
journalists.  

The Federal Human Rights Institute raised concerns regarding the budget of the interfederal 
equality  body. Limited  steps have been taken on ensuring  compliance by public authorities 
with final rulings of national courts while supervision by the Council of Europe on structural 
issues identified by the European Court of Human Rights continues. Despite a high level of 
protection under the law, civic space remains narrowed, and stakeholders are raising concerns 
regarding new obstacles to the right to demonstrate. 

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RECOMMENDATIONS 

Overall,  concerning  the  recommendations  in  the  2024  Rule  of  Law  Report,  Belgium  has 
made: 

•  Some  further  progress  on  efforts  to  address  the  structural  resource  deficiencies  in  the 
justice  system,  taking  into  account  European  standards  on  resources  for  the  justice 
system. 

•  Some  further  progress  on  efforts  to  improve  the  efficiency  of  justice,  particularly  to 

reduce the length of proceedings based on comprehensive statistical data. 

•  Some  progress  on  strengthening  the  integrity  framework  by  adopting  rules  on  gifts  and 
benefits for members of Parliament and limited progress on rules on revolving doors for 
government and their private offices. 

•  No  further  progress  on  completing  the  legislative  reform  on  lobbying,  establishing  a 
framework  including  a  transparency  register  and  a  legislative  footprint,  covering  both 
members of Parliament and Government. 

•  Some  further  progress  on  efforts  to  strengthen  the  framework  for  access  to  official 
documents, in particular by improving request and appeal processes, taking into account 
European standards on access to official documents. 

•  Limited  progress  on  measures  to  ensure  compliance  by  public  authorities  with  final 

rulings of national courts and the European Court of Human Rights.   

On this basis, and considering other developments that took place in the period of reference 
and in addition to recalling the relevant commitments made under the national Recovery and 
Resilience Plan, it is recommended to Belgium to: 

•  Continue  ongoing  efforts  to  address  the  structural  resource  deficiencies  in  the  justice 

system, taking into account European standards on resources for the justice system. 

•  Continue  ongoing  efforts  to  improve  the  efficiency  of  justice,  particularly  to  reduce  the 

length of proceedings based on comprehensive statistical data. 

•  Strengthen the integrity framework, including by adopting rules on gifts and benefits for 
members  of  Parliament  and  rules  on  revolving  doors  for  government  and  their  private 
offices.  

•  Complete  the  legislative  reform  on  lobbying,  establishing  a  framework  including  a 
transparency  register  and  a  legislative  footprint,  covering  both  members  of  Parliament 
and Government. 

•  Further continue efforts to strengthen the framework for access to official documents, in 
particular  by  improving  request  and  appeal  processes,  taking  into  account  European 
standards on access to official documents. 

•  Take measures to  ensure compliance by public  authorities with  final  rulings of national 

courts and the European Court of Human Rights.  

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I. 

JUSTICE SYSTEM 1 

Independence  

The level of perceived judicial independence in Belgium continues to be high among the 
general public and among companies. Overall, 64% of the general population and 72% of 
companies perceive the level of independence of courts and judges to be ‘fairly or very good’ 
in  20252.  The  perceived  judicial  independence  among  the  general  public  has  increased  in 
comparison with 2024 (61%) and has slightly decreased in comparison with 2021 (66%). The 
perceived judicial independence among companies has significantly increased in comparison 
with 2024 (64%), as well as in comparison with 2021 (58%). 

The Government maintains its intention to transfer budgetary management powers for 
the  administration  of  the  justice  system  from  the  executive  to  the  judiciary3.  Once  the 
transfer is completed, the governing bodies of the three ‘pillars’ of the judiciary (the Entity 
Cassation for the Court of Cassation, the College of Courts and Tribunals and the College of 
Public  Prosecutors)  will  be  directly  responsible  for  managing  staff  budgets  and  policy4. 
Discussions continue on the exact details of the  transfer. Prior to the transfer, consideration 
will be given to how the framework for the allocation of court staff and magistrates can be 
improved5,  for  instance  based  on  regular  workload  measurements6.  According  to  the 
Government,  this  increase  in  managerial  autonomy  of  the  judiciary  cannot  be  established 
without a reform of the evaluation and disciplinary system7. The High Council for Justice and 
Court  of  Cassation  have  however  criticised  the  Government  for  making  the  link  between 
efficiency and disciplinary issues8.  

Following  the  adoption  of  directives  prohibiting  the  recording  of  meetings  between 
lawyer  and  client,  lawyers  called  for  additional  procedural  safeguards  to  protect  legal 
professional  privilege. As reported in  the 2024  Rule of Law Report, directives prohibiting 
the  recording  between  lawyers  and  clients  have  strengthened  lawyer-client  confidentiality9. 
The Government highlighted the need for certain limitations to legal professional privilege to 
uphold  the  public  interest  (for  example  whistleblower  protection)10.  Bar  Associations, 
however,  called  for  additional  procedural  safeguards.  In  particular,  they  consider  that  the 
investigating judges who decide on whether lawyer-client communication is confidential (and 
should  therefore  be  excluded  from  the  case  file)  should  not  handle  the  same  case  on 

1   An overview of the institutional framework for all four pillars can be found here.  
2   Figures 50 and 52, 2025 EU Justice Scoreboard and Figures 49 and 51, 2023 EU Justice Scoreboard. The 
level  of  perceived  judicial  independence  is  categorised  as  follows:  very  low  (below  30%  of  respondents 
perceive judicial independence as fairly good and very good); low (between 30-39%), average (between 40-
59%), high (between 60-75%), very high (above 75%). 

3   Coalition agreement, p. 158. 
4   2024 Rule of Law Report Belgium, p. 4. The autonomous management of human resources would include 

decisions on the transfer of magistrates and court staff. 

5   Country visit Belgium, Government. 
6   Country visit Belgium, Court of Cassation. 
7    Coalition agreement, p. 159; The Government indicates that the Guidelines on the evaluation of the quality 
of  work  of  judges,  adopted  by  the  European  Commission  for  the  Efficiency  of  Justice  (CEPEJ)  in 
December 2024, could serve as a valuable source of inspiration; Country visit, Government. 

8   Country visit Belgium, High Council for Justice, Court of Cassation. The Court of Cassation points to the 
risk  of  seeking  to  remedy  the  efficiency  of  the  judiciary  in  general  through  the  evaluation  of  individual 
judges.  

9    2024 Rule of Law Report Belgium, p. 6. 
10     Belgian Government (2025), written input, pp. 6, 7. 

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substance11.  Bar  Associations  and  the  Court  of  Cassation  furthermore  criticised  the  use  of 
videoconferencing  in  civil  and  criminal  cases,  for  its  possible  negative  impact  on  lawyer-
client  confidentiality12.  Bar  Associations  also  raise  concerns  about  public  criticism  of  the 
judiciary and lawyers by some politicians, which they see as undermining their fundamental 
role in upholding the rule of law13. 

Quality  

Some further progress has been made to address the structural resource deficiencies in 
the justice system, such as the publication of all open positions for magistrates and court 
staff,  although  a  long-term  structural  approach  is  required14.  The  budget  spent  on  the 
justice system and the number of professional judges per 100 000 inhabitants remain below 
the  EU  average15,  and  as  Belgium  had  a  caretaker  Government  between  June  2024  and 
February 2025, no additional budgetary resources could be provided in this period. The new 
Government exempted the judiciary from budget cuts16. Moreover, there was a 5% increase 
in the number of judges and public prosecutors between 2020 and 202417, and publication of 
all  open  positions  for  magistrates  and  court  staff,  although  a  significant  number  of  those 
vacancies could not be filled18. In this regard, the Court of Cassation  and High Council for 
Justice  point  to  the  salaries  not  being  sufficiently  attractive  and  to  challenging  working 
conditions  in  the  judiciary19.  Bar  Associations  furthermore  regret  the  abolition  of  the 
privilege  of  jurisdiction  for  lawyers  performing  as  substitute  judges20,  considering  the 
willingness of many lawyers to remedy the shortage of judges by performing as a substitute21. 
While acknowledging the efforts made, the Committee of Ministers of the Council of Europe 
has  repeatedly  called  for  a  long-term  structural  perspective  on  the  budget  for  the  justice 

11   CCBE (2025), written input, p. 21. 
12   Law of 25 April 2024 organising hearings by videoconference in judicial proceedings; A survey conducted 
amongst lawyers and judges in juvenile delinquency cases (where videoconferencing was already applied) 
shows that 86% of participants did not consider the  communication to be confidential. Country visit, Bar 
Associations, Court of Cassation. 

13   CCBE (2025), written input, p. 21. 
14   The 2024 Rule of Law Report recommended Belgium to ‘continue efforts to address the structural resource 
deficiencies  in  the  justice  system,  taking  into  account  European  standard  on  resources  for  the  justice 
system’. 

15   Figures 34 and 37, 2025 EU Justice Scoreboard. 
16    The  Council  of  State,  however,  was  not  exempted.  The  Council  expressed  concern  that  the  Government 
continues to link additional resources for the judiciary to the prioritisation of certain cases which, according 
to some stakeholders, may lead to an additional backlog in other areas and affect citizens’ (equal) access to 
justice. Country visit, Council of State. 

17   Country visit Belgium, Government. 
18   Country visit Belgium, Court of Cassation. 
19   Reference is made to the physical working conditions and the intended lowering of pensions of magistrates; 
Country visit, Court of Cassation; High Council for Justice  (2025), written input, p. 10; On 27 June 2024 
the first president of the Court of Cassation and the first presidents of the courts of appeal and labour courts, 
the Prosecutor General at the Court of Cassation, the  Prosecutors General at the courts of appeal, and the 
federal prosecutor adopted a declaration calling on the  Government and  Parliament to fully recognize  the 
judiciary  as  a  power  of  the  State  and  providing  it  with  the  necessary  funding  to  ensure  quality  justice; 
Declaration by representatives of the judiciary (2025). 

20   This privilege entails that a complaint with civil action against judges is not possible, that they cannot be 
prosecuted directly by an aggrieved party and that prosecution must take place before a higher court. The 
Government’s justification for abolition was that the current system of jurisdictional privileges for judges is 
no longer adapted to reality. Some positions have been excluded, such as legal referendaries at the Court of 
Cassation or the Constitutional Court, and retired judges. 

21   CCBE (2025), written input, p. 20. 

4 

 
 
 
system  and  judicial  staff22.  Overall,  some  further  progress  has  been  made  on  the  2024 
recommendation. 

The  Government  is  addressing  criticism  by  the  Court  of  Audit  regarding  the 
management of the digitalisation of justice. In December 2024, the Belgian Court of Audit 
reported some serious shortcomings in the digitalisation strategy of the department of justice. 
These  include  a  lack  of  an  overarching  approach,  inefficient  use  of  resources  and  an 
excessive  reliance  on  external  consultants,  as  well  as  a  lack  of  oversight  creating  fraud 
risks23. The Government sent an initial action plan to the Court of Audit on 2 September 2024 
in  response  to  its  draft  recommendations.  It  indicates  that  many  actions  have  already  been 
initiated or finalised to improve the governance, coordination, (financial) accountability and 
exclusion  of  fraud  risks24.  The  Bar  Associations  call  for  one  centralised  point  of  contact 
within the Justice Ministry that monitors the vision and progress of the digitalisation projects 
together with the justice actors25.  

Efficiency 

Some further progress has been made to improve the efficiency of justice, particularly 
to reduce the length of proceedings based on comprehensive statistical data26. Length of 
proceedings  and  the  judicial  backlog  in  Belgium  are  long-standing  problems27.  On  28 
November 2024, the High Council for Justice published an additional report on the Court of 
Appeal  of  Brussels,  where  backlogs  and  processing  time  remain  very  problematic28.  A 
comprehensive overview of the efficiency of justice remains unavailable due to a persistent 
lack of data on court proceedings. The College of Courts and Tribunals is carrying out further 
efforts  on  the  issue  of  statistics  and  the  mapping  of  the  backlog  of  court  cases.  At  the 
beginning of 2025 it published data on the duration of criminal cases dealt with by the appeal 
courts29. A file management project funded under the Recovery and Resilience Facility will 
facilitate  the  further  collection  of  statistics30.  The  disposition  time  in  civil  and  commercial 
cases at first instance courts was 246 days in 2023. No data were available for previous years. 
The estimated time to resolve administrative cases at first instance courts increased (360 days 
in 2023 compared to 288 in 2022)31. The Government indicates that the creation of chambers 

22   Council  of  Europe,  Committee  of  Ministers  (2024a);  Belgian  Government  (2025),  written  input,  p.  6; 

Country visit Belgium, Court of Cassation. 

23   Court of Audit (2024). 
24   Country visit Belgium, Government. In general, judges and prosecutors can work remotely and make use of 
an  electronic  case  management  system.  Areas  identified  for  improvement  include  the  use  of  electronic 
communication tools, digital solutions to initiate and follow court proceedings, online access to published 
judgments and machine-readable judicial decisions. 

25   Country visit Belgium, Bar Associations. 
26   The  2024  Rule  of  Law  Report  recommended  Belgium  to  ‘strengthen  efforts  to  improve  the  efficiency  of 

justice, particularly to reduce the length of proceedings’. 

27   Group  of  cases  Bell  (No.  44826/05)  (ENHA):  Excessive  length  of  civil  and  criminal  proceedings,  in 
particular  in  the  judicial  area  of  Brussels  (see  judgment  Van  Den  Kerkhof,  No.  13630/19)  (violations  of 
Article 6 § 1).   

28    The Report contains recommendations to improve productivity and ways to reduce the inflow of new cases; 
High Council for Justice, Supplementary report audit of Brussels Court of Appeal, 28 November 2024. 

29     Prior efforts were reported on in the 2024 Rule of Law Report, Belgium, p. 10. 
30   Belgian Government (2025), written input, p. 3; Country visit Belgium, Government. 
31     Figures 5 and 7, 2025 EU Justice Scoreboard. 

5 

 
 
 
for the amicable settlements of cases should also help to further reduce backlogs32. Overall, 
some further progress has been made on the 2024 recommendation. 

II. 

ANTI-CORRUPTION FRAMEWORK  

The  perception  among  experts,  citizens  and  business  executives  is  that  the  level  of 
corruption in the public sector remains relatively low. In the 2024 Corruption Perceptions 
Index  by  Transparency  International,  Belgium  scores  69/100  and  ranks  9th  in  the  European 
Union  and  22nd  globally33.  This  perception  of  the  level  of  corruption  has  significantly 
increased34 over the past  five years.  The 2025 Special Eurobarometer on Corruption shows 
that 59% of respondents consider corruption widespread in their country (EU average 69%) 
and  18%  of  respondents  feel  personally  affected  by  corruption  in  their  daily  lives  (EU 
average  30%).  As  regards  businesses,  54%  of  companies  consider  that  corruption  is 
widespread  (EU  average  63%)  and  30%  consider  that  corruption  is  a  problem  when  doing 
business  (EU  average  35%).  Furthermore,  49%  of  respondents  find  that  there  are  enough 
successful prosecutions to deter people from corrupt practices (EU average 36%), while 40% 
of  companies  believe  that  people  and  businesses  caught  for  bribing  a  senior  official  are 
appropriately punished (EU average 33%)35.  

New investigative and prosecutorial structures will be set up, with corruption being an 
important  target.  The  new  Government  intends  to  create  a  new  financial  investigation 
service  (to  be  named  FIOD-SRFF36)  and  a  new  specialised  prosecution  service  focused  on 
financial  crime  and  corruption,  which  would  be  established  within  current  prosecutorial 
structures37. This frames within an overall “follow-the-money” approach targeting organised 
crime38.  Detailed  proposals  are  still  forthcoming,  also  as  regards  the  exact  division  of 
competencies,  as  discussions  remain  ongoing  between  government  and  prosecution 
services39. 

Good cooperation between the Central Office for the Repression of Corruption and the 
prosecution  service  continues,  although  some  concerns  exist  on  the  handling  of 
prominent  high-level  corruption  cases.  Good  cooperation  between  the  Central  Office  for 
the Repression of Corruption (CDBC-OCRC) and the prosecution service continues, as does 
work on several complex and high-level corruption cases. The prosecution is still developing 
specific  guidance  for  prosecutors  in  the  area  of  economic  and  fiscal  crime40.  Civil  society 

32   Belgian Government (2025), written input, p. 3; Act of 19 December 2023 containing various provisions on 

civil and judicial matters. 

33   The level of perceived corruption is categorized as follows: low (above 79); relatively low (between 79-60), 

relatively high (between 59-50), high (below 50). 

34   In 2020 the score was 76, while, in 2025, the score is 69. The score significantly increases/decreases when 
it  changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5  points);  is  relatively  stable 
(changes from 1-3 points) in the last five years. 

35   Data from Special Eurobarometer 561 (2025) and Flash Eurobarometer 557 (2025). 
36   Fiscale en Financiële Opsporingsdienst / Service de Recherche Fiscal et Financier.  See Ministry of Justice 

(2025a) and Ministry of Justice (2025b), p. 32.  

37   Belgian  Government  (2025a),  pp.  128-129  and  p.  154  and  Country  visit  Belgium,  public  prosecution 

service. 

38   Ministry of Justice (2025a). 
39   Ministry of Justice (2025a). 
40   Public prosecution service (2025a) and 2024 Rule of Law Report, Belgium, pp. 13-14.  

6 

 
 
 
raises  concerns  over  the  resources  of  law  enforcement  and  prosecution41.  Allegations  of 
information leaks in sensitive corruption investigations and undue political influence related 
to  the  work  of  the  CDBC-OCRC  are  a  cause  of  concern42  and,  according  to  civil  society, 
could impact the trust of the public in the CDBC-OCRC43. In response to these allegations, 
law enforcement reaffirms  the independence of  the CDBC-OCRC as enshrined in  law44. In 
2024,  the  prosecution  signalled  367  incoming  corruption  cases45,  of  which  90  were 
dismissed, while 7 cases led to an indictment (by January 2025)46. The EPPO has signalled 
seven corruption cases among its open cases (which consists of 5.1% of its total open cases) 
in 2024 in Belgium47. The investigation and prosecution of foreign bribery cases continue to 
be  limited.  A  new  report  of  the  OECD  criticises  in  particular  the  low  number  of 
investigations and prosecution of foreign bribery cases, the low awareness within companies 
on  the  risks  of  foreign  bribery  as  well  as  a  lack  of  investigations  and  low  sanctions 
specifically  targeting  legal  persons.48.  The  prosecution  reported  only  four  cases  of  foreign 
bribery registered between 2022 and 202449. 

Some improvements on police integrity are under consideration to address challenges in 
preventing  corruption  within  the  police.  The  181  local  police  zones  maintain  disparate 
integrity policies and smaller police zones are not maintaining an effective integrity policy50. 
The authorities did not move forward on a Code of Conduct for the entire integrated police, 
as  recommended  by  GRECO51,  and  overall,  the  police  integrity  policy  is  assessed  as 
insufficient by stakeholders52. Nevertheless, several actions are envisaged to address the risk 
of  corruption  within  the  police.  The  new  Government  announced  it  will  allow  voluntary 
mergers  of  local  police  zones  so  they  can  operate  at  a  larger  scale,  which  may  also  create 
possible opportunities to improve integrity policy. There are plans to introduce screening and 
integrity checks during the entire career of a police officer, a proposal that had previously not 
moved forward.53 Committee P has overall signalled a lack of attention to integrity during the 
recruitment, selection and training of new police officers54.  

41   In  particular  considering  the  increasing  number  of  complex  cases.  Country  visit  Belgium,  Transparency 

International and 2024 Rule of Law Report, Belgium, pp. 13-14.  

42   The  acting  chief  of  the  CDBC/OCRC  was  questioned  and  his  offices  searched  by  the General  Inspection 
following  allegations  of  information  leaks.  Following  that,  complaints  were  filed  with  Committee  P 
concerning  political  interference  into  the  investigations  led  by  CDBC/OCRC  by  superiors  of  overarching 
departments. Investigations remain ongoing.  
43   Country visit Belgium, Transparency International. 
44   Ministry of Justice (2025a). 
45   Out of which 6 concerned corruption in the private sector, with 361 related to the public sector (including 
102 cases related to bribery in the public sector and 82 related to abuse of function in the public sector).  

46   Others remain at various stages of the criminal procedure. Public prosecution service (2025a). 
47   EPPO (2025a), p. 16. 
48   A  clear  strategy  on  combating  foreign  bribery  and  sufficient  resources  for  the  investigative  and 
prosecutorial  bodies  are  recommended.  There  are  no  measures  that  promote  self-investigation  and  self-
reporting of companies. OECD (2025), pp. 7-8.   

49   One in 2022; one in 2023 and two in 2024. Public prosecution service (2025a). 
50   As reconfirmed by Federal Police (2025a). See also 2023 Rule of Law Report, Belgium, pp. 10-12. 
51   Federal Police (2025a) and GRECO (2022), recommendation xvi, paras 75-81. See also 2022 Rule of Law 

Report, Belgium, p. 10. 

52   Country visit Belgium, Committee P and 2024 Rule of Law Report, Belgium, pp. 14-15. 
53   Belgian Government (2025a), p. 139 and pp. 141-142 and Country visit Belgium, Committee P.  
54   Committee  P  (2024);  Country  visit  Belgium,  Committee  P  and  Federal  Police  (2025a).  Committee  P 

expects to publish recommendations on this topic in the future. 

7 

 
 
 
There  is  still  a  lack  of  monitoring  and  enforcement  of  existing  integrity  policies 
concerning Ministers, their private offices and  members of Parliament. Gaps remain in 
existing  integrity  policies55,  particularly  due  to  the  absence  of  any  monitoring  and 
enforcement  mechanism56.  Increased  checks  on  the  application  of  the  Code  of  Conduct  for 
federal  public  office  holders  are  a  priority  of  the  new  Minister  of  Public  Administration. 
However, in the absence of a monitoring mechanism, it is unclear how these checks will be 
carried out in practice57. Training and awareness raising in relation to integrity remain to be 
enhanced.58.  The  Federal  Deontological  Commission  has  voiced  concerns  that  powers 
concerning  integrity  policy  are  dispersed  across  various  bodies  and  recommended  that  its 
own  role  as  an  advisory  body  be  strengthened.59  As  regards  the  federal  civil  service,  the 
Integrity Bureau continues the work with the Federal Network of Integrity Coordinators with 
all Ministries now having established an Integrity Coordinator60. 

The system of asset and interest declarations has shortcomings in terms of verification 
and  transparency.  As  outlined  in  previous  Rule  of  Law  Reports,  the  system  of  asset 
declarations  does  not  ensure  adequate  verification  and  transparency,  as  the  Court  of  Audit 
receives  the  declarations  in  sealed  envelopes  and  declarations  are  only  accessible  by 
investigating  judges  in  the  context  of  criminal  investigations61.  Parliament  declared  its 
intention  to  work  towards  more  comprehensive  rules  on  declarations  of  parliamentarians’ 
assets over the long term62, but no immediate plans by either Government or Parliament were 
tabled63. Compliance with the requirement to submit declarations is very good with 99% of 
those required to do so64 submitting their assets and mandates declarations on time. Due to a 
lack  of  adequate  verification,  the  correctness  of  these  declarations  remains  solely  the 
individual responsibility of the person declaring them65.  Civil society organisations continue 
to  criticise the lack of transparency of asset  declarations  as well as the set-up of the  whole 
system66.  

55   The updated Code of Conduct for federal public office holders remains in place and since 2023 covers all 
staff members of the Federal Government (i.e. including the ministerial private offices). A specific Code of 
Conduct remains in force for Ministers, as these are not covered in the Code of Conduct for federal public 
office holders. 2024 Rule of Law Report, Belgium, pp. 15-16. 

56   As  recommended  multiple  times  by  GRECO  –  a  number  of  GRECO  recommendations  remain 
unimplemented. GRECO (2022a), recommendation iii and paras. 115-120 and GRECO (2022b), paras. 60-
62.  

57   Ministry of Public Administration (2025), p. 19.  
58   Country visit Belgium, Federal Deontological Commission.  
59   Federal Deontological Commission (2025) and Country visit Belgium, Federal Deontological Commission. 
60   The  first  round  of  Integrity  Action  Plans  from  all  Ministries  was  received  in  2024.  Belgian  Government 

(2025a), p. 9 and Country visit Belgium, Integrity Bureau. 

61   2024 Rule of Law Report, Belgium, pp. 16-17. 
62   Ministry of Justice (2025a).  
63   This  remains  subject  to  an  open  GRECO  recommendation.  Asset  Declarations  are  submitted  in  closed 
envelopes only accessible in the course of criminal investigations. GRECO repeated the previous remarks 
(as mentioned in the 2022 Rule of Law report) from the Fifth Round Evaluation Report in its most recent 
compliance report. 2024 Rule of Law Report, Belgium, pp. 16-17 and GRECO (2024a), recommendations 
xii and xiii.   

64   538 persons out of 543 required to submit asset declaration, 9 543 out of 9 568 persons required to submit 

mandate declarations. Court of Audit (2025). 

65   Court of Audit (2025). 
66   Country Visit Belgium, Transparency International and Cumuleo (2025). 

8 

 
 
 
 
There has been no further progress on completing the reform of lobbying legislation as 
the  new  Government  has  not  yet  taken  a  decision  on  draft  lobbying  rules  for 
Government members67. The previous Government had presented a draft law and decree68 
envisaging rules for contacts between lobbyists and members of the federal executive69 and it 
had also gathered advice from the Council of State and the Data Protection Authority70. The 
new  Government  is  now  examining  these  drafts  and  has  yet  to  decide  whether  it  would 
continue with this reform71. Civil society does not expect a decision soon and has criticised 
the Government  lacking  ambition in this area72. The  outgoing Parliament had committed to 
its  own  reform  using  similar  definitions  as  the  Government  to  avoid  duplication  of 
registrations73,  but  it  is  unclear  whether  the  new  Parliament  intends  to  take  the  same 
approach. As no further steps have been taken by either Government or Parliament, there has 
been no further progress on the recommendation made in the previous years.  

There has been some progress in relation to the rules on gifts and benefits for members 
of Parliament through a minor update of the House’s Deontological Code74. Members of 
both  the  Senate  and  House  of  Representatives  are  covered  by  a  general  prohibition  on 
receiving gifts in return for actions taken in the course of their mandate75. In line with advice 
from  the  Federal  Deontological  Commission,  the  House  of  Representatives  clarified  an 
inconsistency between its Deontological Code and the applicable legislation on political party 
financing  in  March  2024,  ensuring  that  donations  of  citizens  to  a  political  party  are  not 
classified as gifts76. Shortcomings identified in previous Rule of Law Reports77 have not been 
fully addressed as  there is  no concrete guidance to  members of Parliament on what  type of 
gifts  would  be  acceptable  (i.e.  a  monetary  threshold).  Information  about  gifts  accepted  and 
their origin is not registered, and, as a consequence, also not visible to the public. While there 
is a stated intention of both Houses of Parliament to further address these issues, no further 
concrete actions or texts were tabled, and the House of Representatives explicitly decided not 
to  introduce  a  gifts  register78.  Ministers  and  members  of  ministerial  private  offices  remain 
covered  by  separate  policies  on  gifts79,  while  the  Federal  Deontological  Commission 
continues to offer individual advice – upon request – to Members of Parliament, Government 
and high public office holders on potential conflicts of interest. Given some efforts to clarify 
the rules for members of Parliament regarding gifts and benefits for members of Parliament, 

67   The 2024 Rule of Law Report recommended to Belgium to ‘complete the legislative reform on lobbying, 
establishing  a  framework  including  a  transparency  register  and  a  legislative  footprint,  covering  both 
members of Parliament and Government’. 

68   The draft law regulates the substance of the reform, while the draft decree foresees the necessary rules on 

data protection for data included in the transparency register. 

69   Draft legislation foresees a transparency register, managed by the Prime Minister’s Office, with registration 
obligations for lobbyists and all ministerial private offices. 2024 Rule of Law Report, Belgium, p. 17.  

70   2024 Rule of Law Report, Belgium, p. 17. 
71   Ministry of Justice (2025a).  
72   Country visit Belgium, Transparency International. 
73   2024 Rule of Law Report, Belgium, p. 17. 
74   The 2024 Rule of Law Report recommended to Belgium to “Strengthen the integrity framework, including 
by  adopting  rules  on  gifts  and  benefits  for  members  of  Parliament  and  rules  on  revolving  doors  for 
government and their private offices.” 

75   2022 Rule of Law Report, Belgium, pp. 12-13. 
76   Belgian Government (2025), written input, p. 10. 
77   2022 Rule of Law Report, Belgium, pp. 12-13. 
78   GRECO (2024b), recommendation i, paras 10-14.  
79   The Ministerial Code of Conduct, as adopted on 16 June 2023; and the extension of the Code of Conduct 

for public mandate holders. See 2023 Rule of Law Report, Belgium, p. 16. 

9 

 
 
 
some progress has been made on this part of the recommendation of the 2024 Rule of Law 
Report.  

There  has  been  limited  progress  on  rules  on  ‘revolving  doors’80.  In  a  June  2024 
‘circular’, the outgoing Minister of Public Administration raised attention to the risk of post-
employment  conflicts  of  interest  and  ‘revolving  doors’  in  the  federal  public  sector  and 
provided  an  overview  of  the  existing  measures81.  The  ‘circular’  also  outlined  the  possible 
elements for implementing a preventive policy around post-employment conflicts of interest 
and  revolving  door  situations  –  including  the  existing  legal  prohibition  of  former  civil 
servants  to  be  involved  in  public  tenders  in  the  two  years  following  their  employment82. 
While important to raise awareness on the issue, this non-binding ‘circular’ did not introduce 
any  new  rules  nor  address  the  existing  gaps  for  either  members  of  Government  or  their 
private  offices  or  civil  servants  more  broadly.  The  Federal  Internal  Audit  Service  is 
conducting  a  thematic  audit  on  how  the  various  ministries  and  agencies  within  the  Federal 
Public Service address the issue of revolving doors in public procurement procedures83. The 
recommendations  contained  in  the  own  initiative  opinion  of  the  Federal  Deontological 
Commission  on  the  topic  have  not  been  taken  forward  by  any  institution84.  Therefore,  as 
preliminary steps were taken to  address  these gaps,  limited progress  has been made on this 
part of the recommendation made in the 2024 Rule of Law Report.  

There  are  no  further  plans  to  reform  the  political  party  financing  architecture.  The 
outgoing Government and Parliament did not secure agreement on a reform of political party 
financing,  despite  lengthy  preparations85  and  stakeholder  concerns86.  Lacking  such  an 
agreement, the new Government is not intending to further discuss the matter87.  

Whistleblower protection is largely in place whilst specific rules for certain categories of 
public employees remain to be adopted.  Whilst  whistleblower protection rules  have been 
largely put in place88, specific rules applying to employees working in the judiciary and the 
state  security  services  are  still  pending89.  In  2025,  a  law  has  been  adopted  regulating 
whistleblowing  protection  within  the  House  of  Representatives  and  the  Senate90.  The 

80   The 2024 Rule of Law Report recommended to Belgium to ‘strengthen the integrity framework, including 

by adopting […] rules on revolving doors for Government and their private offices’. 

81    There are some rules on ‘revolving doors’ for members of Parliament and public officials. However, these 
do  not  include  clear  or  binding  rules  regarding  cooling-off  periods  or  transitory  restrictions  for  either 
ministers, their staff, or members of Parliament. 

82   Ministry of Public Administration (2024) and Belgian Government (2024), written input, p. 10. 
83   Federal Internal Audit Service (2025). 
84   Recommendations  from  the  Commission  include,  inter  alia,  introducing  legally  binding  general  rules  on 
revolving  doors,  including  a  cooling-off  period  for  particular  high-level  functions  (ministers,  heads  of 
private offices, high-level civil servants), among other measures such as lobbying bans for former ministers 
and better preventative action on conflicts of interest. 2024 Rule of Law report, Belgium, pp. 18-19.  

85   2024 Rule of Law Report, Belgium, p. 19. 
86   2024 Rule of Law Report, Belgium, p. 19. 
87   Ministry of Justice (2025a) and Belgian Government (2025a), p. 6. 
88   Several separate laws, one for the private sector, one for the federal public sector, as well as laws for the 

regional employees in the public sector, have been adopted in 2022, 2023 and 2024. 

89   See also Country Visit Belgium, Federal Institute of Human Rights; and FIRM/IFDH (2025). 
90   On  13  March  2025,  the  House  of  Representatives  adopted  the  Private  Member's  bill  DOC  56-0656/001 
which seeks to transpose EU Directive 2019/1937 on whistleblower protection with regard to the House of 
Representatives and the Senate: DOC 56-0656/005. The text adopted by the House has been sanctioned by 
the King on 27 March 2025 giving it the status of a federal law. That law will be published in the  Belgian 
Official Gazette in due course. On 13 March 2025, the House also adopted the proposal to amend the House 

10 

 
 
 
 
material  scope  of  that  law  has  been  limited  to  breaches  of  Union  law  in  view  of  the 
peculiarity of the parliamentary activities and to prevent abuses.91  The Federal Human Rights 
Institute  and  stakeholders  have  criticised  the  limited  scope  of  this  law  since  it  foresees  a 
narrower  material  scope  for  civil  servants  working  in  Parliament  than  the  general  regime 
applicable  to  the  civil  servants  working  at  the  federal  government  level92.  The  Federal 
Ombudsperson  and  the    Federal  Human  Rights  Institute  have  issued  a  practical  guide  for 
whistleblowers  to  help  them  navigate  through  the  legislation  and  various  systems93.  The 
Federal  Ombudsperson  (as  the  external  whistleblowing  reporting  channel)  indicates  that 
complaints  from  the  private  sector  are  generally  declared  non-admissible  (currently  87%) 
because  they  concern  issues  outside  the  scope  of  the  law.  Moreover,  whistleblowing 
mechanisms for the public sector appear to function well94.   

Increased attention is paid to addressing high risks of corruption both at local level and 
linked  to  organised  crime.  Businesses’  attitudes  towards  corruption  in  the  EU  show  that 
27% of companies in  Belgium  (EU average  25%) think that corruption has prevented them 
from  winning  a  public  tender  or  a  public  procurement  contract  in  practice  in  the  last  three 
years95.  67%  perceive  the  level  of  independence  of  the  public  procurement  review  body 
(Council  of  State)  as  very  or  fairly  good96.  The  Single  Market  and  Competitiveness 
Scoreboard  on  access  to  public  procurement  in  Belgium  reports  26%  of  single  bids  for 
2023(EU average 29%).  Public procurement remains  an  area at  high risk of corruption and 
stakeholders  continue  to  signal  low  transparency  of  government  contracts97.  The  limited 
awareness  of  the  concept  of  conflict  of  interest  at  local  level  continues  to  represent  an 
increased  risk  of  corruption,  following  a  number  of  allegations  of  conflicts  of  interest 
involving mayors and aldermen, often linked to real estate transactions, detected in the period 
2022-202598.  The  incoming  Flemish  government  has  made  it  a  priority  to  address  such 
cases99.  Civil  society  highlights  differences  of  auditing  capacities  at  regional  level100.  The 
authorities recognise that  cases  of corruption concerning public officials  are often linked to 
organised  crime  groups  and  drug-related  crimes.  A  type  of  case  often  cited  is  the 
unauthorised  access  to  databases  by  public  officials  to  obtain  specific  data  for  criminal 

Rules  DOC  56-0657/001  which  aims  to  harmonize  the  House  Rules  with  the  provisions  of  the 
abovementioned federal law of 27 March 2025. That amendment to the House Rules has been published in 
the Belgian Official Gazette on 30 April 2025. 

91   See the parliamentary preparation of the law: DOC 56-0656/002, p. 4-5. 
92   FIRM/IFDH  (2025)  and  country  visit  Belgium,  Ombudsperson,  Transparency  International  and  Federal 

Institute of Human Rights. 

93   Ombudsperson (2024). 
94   Country visit Belgium, Ombudsperson. 
95   Flash  Eurobarometer  557  on  Businesses’  attitudes  towards  corruption  in  the  EU  (2025).  This  is  1 

percentage points above the EU average.  

96   Figure 59, 2025 EU Justice Scoreboard. 
97   Stichting Overheidsopdrachten (2024).  
98   Separate  allegations  of  conflicts  of  interest  were  detected  in  around  10  municipalities  in  Belgium,  in 
particular  in  Flanders,  mostly  involving  possible  conflicts  of  interest  of  mayors  in  relation  to  real  estate 
transactions.  In  at  least  two  of  these  cases,  the  (former)  mayors  were  convicted  in  a  subsequent  criminal 
case. Audit Vlaanderen (2024), see also 2024 Rule of Law Report, Belgium, pp. 20-21. 

99   Flemish Minister of Domestic Administration (2025). No corresponding information was made available by 

the Walloon Region and the Brussels Region. 
100   Country visit Belgium, Transparency International. 

11 

 
 
 
groups,  in  return  for  substantial  payments101.  The  police  highlights  the  need  for  increased 
screening of employees102.  

III.  MEDIA PLURALISM AND MEDIA FREEDOM 

Media  regulatory  authorities  across  Belgium  have  made  progress  in  adapting  their 
strategies,  while  maintaining  a  strong  legal  foundation  for  their  independence.  In 
Flanders, the Flemish Regulator for the Media (VRM) continues to operate as an independent 
external agency with strengthened legal, financial, and operational guarantees103. It has been 
designated as a competent authority under the Digital Services Act (DSA) and will play a key 
role in  overseeing  the European Media  Freedom  Act  (EMFA) implementation, including  in 
areas  such  as  media  ownership  transparency  and  platform  regulation104.  While  no  new 
funding has yet been allocated for EMFA implementation, VRM’s staffing was increased in 
late 2023 to manage new tasks related to the DSA and other responsibilities105. A recent legal 
change also introduced a six-month extension mechanism to ensure the continuity of VRM’s 
chambers, reinforcing its decision-making autonomy106. In the French-speaking Community, 
the  Conseil  Supérieur  de  l’Audiovisuel  (CSA)  remains  an  independent  and  adequately 
resourced  body107,  benefiting  from  increased  powers  under  the  DSA  and  playing  a  pivotal 
role  in  the  preparation  for  EMFA  enforcement108.  The  Medienrat  of  the  German-speaking 
Community  has  undergone  significant  structural  reinforcement109.  In  2024,  the  French-
speaking  Conseil  de  Déontologie  Journalistique  (CDJ)  launched  its  first  public  awareness 
campaign to improve recognition among the general public and highlight the importance of 
ethical journalism110. A growing point of concern is the relationship between the CDJ and the 
regulator  CSA111.  Although  their  respective  competences  are  formally  defined  in  the  2009 
decree112,  overlapping  mandates  in  practice  have  led  to  legal  and  procedural  tensions 
prompting  a  case  before  the  Council  of  State113.  Ongoing  discussions  are  being  held  at 
ministerial  level  to  address  the  articulation  between  journalistic  self-regulation  and 

101   The police indicated that the main targets of bribery by drugs-related organised crime groups are the police, 

customs, port and local officials. See also 2024 Rule of Law report, Belgium, p. 14. 

102   Federal Police (2025a). 
103   Act of 27 March 2009 on Radio and Television Broadcasting Link to the Media Decree. 
104   Country visit Belgium, Belgian Government. 
105   VRM (2025), written input, p. 1. 
106   VRM (2025), written input, p. 4-5. 
107   Belgian  Government  (2025),  written  input,  second  batch,  p.  11:  “To  quote  some  figures,  the  financial 
resource of the CSA is about 3,7 million euros for 2024. Their budget has increased by more than 30% in 5 
years”. 

108   Country visit Belgium, Government. 
109   Since 2024, it directly manages its own staff, marking a notable improvement in operational autonomy. The 
Medienrat has seen a substantial increase in funding and staffing Belgian authorities (2025), written input, 
second batch, p. 11. 

110   The  Belgian press council (CDJ) launches its first campaign aimed at the general public to (re)affirm the 

link between journalistic ethics and trustworthy information, CDJ website. 

111   Country visit, Conseil de déontologie journalistique (CDJ) and CDJ (2025), written input, p. 5. 
112   Décret du 4 fevrier 2021 relatif aux services de medias audiovisuels et aux services de partage de videos. 
113   In  July  2024,  the  CDJ  joined  a  proceeding  against  the  CSA  before  the  Council  of  State,  initiated  by  the 
French-speaking public media RTBF. The CDJ argues that the CSA is impeding on the competences of the 
CDJ - Federal Institute for the Protection and Promotion of Human Rights (2025), written input, pp. 21-22 
and CDJ press statement. 

12 

 
 
 
audiovisual regulation114. In Flanders the relationship between the Dutch-speaking Raad voor 
de Journalistiek (RvJ) and the VRM is more clearly delineated and has not raised the same 
issues. Greater recognition is considered crucial by the RvJ and the VRM to safeguard press 
freedom  and  support  trustworthy  information  in  an  increasingly  challenging  information 
environment115. 

Public  service  media  in  Belgium  face  various  challenges  across  the  three  communities 
including  governance  structures  and  budgetary  pressures.  In  Flanders,  the  Vlaamse 
Radio-  en  Televisieomroeporganisatie  (VRT)  has  received  additional  resources  under  the 
2024–2029 Media Policy Plan116.  The Flemish government  has reaffirmed  VRT’s  mandate, 
with  an  emphasis  on  journalistic  independence,  impartiality,  and  editorial  autonomy. 
However,  concerns  have  emerged  over  the  composition  of  the  new  Board117  and  growing 
political scrutiny, including parliamentary interpellations on internal matters. VRT also cites 
an  increasing  regulatory  burden  that  affects  its  ability  to  remain  competitive118.  In  the 
Wallonia-Brussels Federation, the new Government adopted a policy declaration in July 2024 
that  foresees  an  early  revision  of  the  Radio-Télévision  Belge  de  la  communauté  Française 
(RTBF)’s  legal  framework119  to  refocus  on  public  service  missions  such  as  information, 
culture, and lifelong education120. Budgetary constraints will freeze RTBF’s funding at 2024 
levels  until  2029,  resulting  in  a  projected  EUR 78  million  shortfall  and  a  corresponding 
savings plan. In the German-speaking Community, the Belgischer Rundfunk (BRF) continues 
to  operate  under  a  stable  framework,  with  its  management  contract  extended  pending  new 
negotiations121.  While  its  Board  remains  politically  composed,  BRF  is  open  to  governance 
reform,  including  the  possible  introduction  of  independent  directors,  inspired  by  the  VRT 
model122.  Across all three communities, public broadcasters underline the need for regulatory 
clarity,  financial  sustainability,  and  autonomy  to  maintain  their  public  service  remit123.  The 
Media  Pluralism  Monitor  2025  (MPM)  reports  a  low  risk  (17%)  for  the  political 
independence of public service media124, up from an even lower level (3%) in 2024. 

Recent  legislative  developments  led  to  some  progress  regarding  access  to  public 
documents125,  while  procedural  improvements  are  still  needed.  In  2024,  a  federal  law 
amending  the  1994  framework  on  administrative  transparency126  was  adopted  and  partially 
entered  into  force  in  July  2024.  Additionally,  Belgium  has  signed  but  had  not  ratified  the 
Council of Europe Convention on Access to Official Documents. However, the publication of 
the  federal  law  remains  pending,  and  the  Walloon  Region  has  yet  to  adopt  enabling 

114   In March 2025, a meeting between the CDJ/AADJ and the Media Minister’s cabinet appeared to confirm 
the  Minister’s  intention  to  invite  Parliament  to  consider  revising  the  2009  decree,  depending  on  the 
forthcoming decision of the Council of State and as reported by the CDJ. 

115   Country visit Belgium, Conseil de déontologie journalistique (CDJ) and Raad voor de Journalistiek (RvJ).  
116   Flemish Government's 2024-2029 Policy Plan for media. 
117   VVJ [The Flemish Association of Journalists] advocates essential pluralism for VRT board of directors. 
118   VRT (2025), written input, p. 2. 
119   Décret portant statut de la Radio-Télévision belge de la Communauté française (RTBF), 14 Juillet 1997. 
120   RTBF (2025), written input, p. 1. 
121   BRF (2025), written input, p. 3. 
122   BRF (2025), country visit Belgium and written input, p. 1. 
123   VRT, RTBF and BRF (2025), country visits Belgium and written inputs. 
124   2025 Media Pluralism Monitor, country report for Belgium, p. 25. 
125   2024 Rule of Law Report, Belgium, p. 2. 
126   Belgian Government (2025), written input, p. 9. 

13 

 
 
 
legislation127.  While  these  steps  mark  a  positive  trend,  stakeholders128  highlight  some 
persistent  shortcomings.  At  the  federal  level,  three  parallel  publicity  regimes  and  two  non-
binding  appeal  bodies  (including  a  federal  Commission  for  Access  to  Administrative 
Documents,  CADA)  create  uncertainty  and  limit  effectiveness.  Given  their  non-binding 
nature,  decisions  issued  by  these  bodies  are  often  not  followed  by  public  authorities.  Civil 
society continues to call for simplified procedures, the merger or reform of appeal bodies, and 
the  empowerment  of  the  federal  CADA  with  binding  authority,  adequate  resources,  and 
systematic publication of decisions129. Human rights and journalists’ organisations have also 
expressed  concerns  about  what  they  see  as  unclear  definitions  of  the  offence  of  disclosing 
state  secrets  in  which  is  part  of  a  broader  revision  of  the  Criminal  Code in  March  2024130. 
Government representatives, however, have defended the new provision, stating that it aims 
to  modernise outdated definitions and that safeguards are in  place to ensure proportionality 
and  protect  legitimate  journalistic  activity131.  In  October  2024,  journalist  unions  and  the 
Ligue des droits humains challenged this provision before the Constitutional Court, arguing 
that it could criminalise public interest reporting132. Overall, some progress has been made on 
the recommendation made in the 2024 Rule of Law Report. 

The  Government  took  steps  to  strengthen  legal  protections  for  journalists.  It  notably 
decriminalised defamation133 and introduced harsher penalties for crimes committed against 
journalists,  recognising  their  public  interest  role134.  Progress  was  also  made  on  strategic 
lawsuits  against  public  participation  (SLAPPs),  with  Belgium  actively  working  on 
transposing  the  EU  anti-SLAPP  Directive.  The  Minister  of  Justice  is  planning  to  submit  a 
legislative  proposal  transposing  the  EU  SLAPP  Directive  for  discussion  within  the 
Government  and,  subsequently,  for  adoption  in  Parliament.  The  draft  law proposes  broad 
protections,  covering  civil  and  criminal  procedures,  and  includes  support  mechanisms135.  It 
has  been  developed  with  input  from  journalist  associations,  using  the  national  SLAPP 
working  group  as  a  source  of  inspiration136.  Meanwhile,  journalist  associations  and  public 
broadcasters  report  growing  legal  intimidation  and  political  interference137.  Lawsuits 
targeting  major  media  outlets  have  raised  concerns  about  press  freedom  and  misuse  of 

127   The Council of Europe Convention on Access to Official Documents (CETS No. 205), also known as the 
Tromsø Convention, entered into force on 1 December 2020. The bill assenting to the Council of Europe 
Convention  on  Access  to  Public  Documents,  was  unanimously  adopted  on  14/03/2024  in  the  plenary 
session of the Chamber and submitted for Royal Assent. However, the law has still not been published in 
the Belgian Official Gazette and the file will be handled by the new cabinet of the Minister of Security and 
the Interior. Belgian Government (2025), second batch, written input, pp. 9-10 

128   FIRM-IFDH,  journalists  associations,  and  Cumuleo  –  as  expressed  during  the  Country  visit  andin  their 

written contributions. 

129   FIRM-IFDH (2025), written input, pp. 25-26. 
130   FIRM-IFDH (2025), written input, pp. 27-28. 
131   Belgian authorities, written input, second batch, pp. 16-17.  
132   A ruling is expected early 2026. 
133   Belgian Government (2025a), written contribution, p. 17. 
134   The  Law  of  18  January  2024  officially  recognizes  journalists  as  holding  a  "societal  role",  meaning  that 
crimes  like  violence  or  threats  committed  against  them  can  now  trigger  aggravated  penalties,  similar  to 
those  protecting  police  officers  or  healthcare  workers.  This  legal  recognition  strengthens  protection  for 
journalists facing intimidation or attacks, Belgian authorities, written contribution, second batch, p. 17. 

135  The anti-SLAPP working group has a website where notes and the draft law can be consulted.  
136   The  Government  indicated  that  the  working  group  will  be  once  again  consulted  during  the  upcoming 

processes. 

137   Conseil  de  déontologie  journalistique  (CDJ)(2025),  written  input,  p.  5;  BRF  (2025),  written  input,  p.3; 

FIRM-IFDH (2025), written input, pp. 23-24. 

14 

 
 
 
 
judicial  procedures138.  The  climate  for  journalists  is  reportedly  becoming  increasingly 
difficult,  particularly  online  and  during  demonstrations139,  with  media  outlets  citing 
increasing  harassment,  including  threats  and  pressure  targeting  journalists  and,  in  some 
instances, their families140. While initiatives like PersVeilig.be141 offer support, stakeholders 
stress  the  need  for  greater  institutional  backing,  stronger  safeguards,  and  better  law 
enforcement cooperation to ensure journalists can work safely and independently. Since the 
2024  Rule  of  Law  Report,  six  new  alerts  concerning  Belgium  have  been  registered  on  the 
Council  of  Europe’s  Platform  to  promote  the  protection  of  journalism  and  safety  of 
journalists142.  The  Media  Freedom  Rapid  Response  mechanism  has  identified  17  alerts 
including threats such as SLAPPs, political interference, smear campaigns, arbitrary arrests, 
cyberattacks, and restrictions on journalists’ access to events143. 

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Stakeholders  are  mostly  satisfied  with  the  opportunities  to  engage  with  policymaking. 
Representatives  of  business  associations  indicate  that  they  are  generally  satisfied  with  the 
way  in  which  they  are  consulted,  though  they  are  concerned  about  the  fragmentation  and 
inconsistencies  between  the  legal  framework  at  federal  and  regional  level144.  The  Federal 
Human  Rights  Institute  also  points  to  a  complex  institutional  environment.  It  is  frequently 
asked  by  the  Government  or  the  federal  Parliament  to  provide  advice  on  legislative 
initiatives.  However,  in  absence  of  a  clear  obligation  to  consult  the  Institute,  the  frequency 
and nature of this contact can vary depending on the individual office holder145.  

Over half of the companies surveyed in Belgium express confidence in the effectiveness 
of investment protection. 60% of companies are very or fairly confident that investments are 
protected  by  law  and  courts146.  Stakeholders  confirmed  that  they  do  not  see  an  issue  with 
investment  protection  in  Belgium.  As  regards  authorities  relevant  for  economic  operators, 
53% of companies perceive the level of independence of the national  competition authority 
(Belgian Competition Authority) as very or fairly good147. A number of judicial mechanisms 
are in place at the level of the Council of State to ensure the implementation of administrative 
court  judgments,  including  disciplinary  actions  against  the  responsible  officials,  the 
possibility  to  substitute annulled  administrative  acts,  and  to  award  direct  and  consequential 
damages and compensation148. 

138   European Federation of Journalists (2024) 
139   FIRM-IFDH (2025), written input, pp. 23-24 
140   BRF (2025), written input, p. 2; RTBF (2025), written input, p. 2. 
141   Vlaamse Vereniging van Journalisten (2024). 
142   Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists,  Belgium.  These  include   
allegations  of  police  action  involving  the  seizure  of  journalistic  materials,  judicial  gag  orders  and  legal 
proceedings  against  media  outlets,  and  political  interference  affecting  the  editorial  independence  of  the 
public broadcaster RTBF. Out of six alerts, Belgium replied to five, with one more reply expected by July.  

143   European Centre for Press and Media Freedom, Media Freedom Rapid Response – Belgium. 
144   Country visit Belgium, Federal Business Association. 
145   FIRM-IFDH (2025), written input, p. 14. 
146   Figure 54, 2025 EU Justice Scoreboard. 
147   Figure 60, 2025 EU Justice Scoreboard. 
148   Figure 49, 2025 EU Justice Scoreboard. The data presented reflects exclusively the mechanisms in place at 
the level of the highest administrative jurisdictions; the same or other mechanisms may be in place at lower 
instance administrative courts. 

15 

 
 
 
The  Federal  Human  Rights  Institute  raised  concerns  regarding  the  budget  of  the 
interfederal equality body. The Government Agreement announced a 25% budget cut to the 
Interfederal  Centre  for  Equal  Opportunities  and  Opposition  to  Racism  and  Discrimination 
(Unia)149. FIRM-IFDH warns that this budget cut will lead to a reduced level of human rights 
protection150. The Government aims to achieve an A-status for FIRM-IFDH, which requires 
establishing a structure that is competent for human rights matters across federated entities as 
well  as  the  federal  level.  Furthermore,  the  Human  Rights  League  reiterated  its  call  on  the 
Belgian  authorities  to  make  sure  that  all  human  rights  monitoring  bodies  comply  with  the 
Paris Principles on independence and effectiveness, especially the Data Protection Authority, 
Standing Police Monitoring Committee and Policy Information Monitoring Body151.  

There  has  been  limited  progress  to  ensure  compliance  by public  authorities  with  final 
rulings  of  national  courts,  while  supervision  by  the  Council  of  Europe  on  structural 
issues  identified  by  the  European  Court  of  Human  Rights  continues152.  Compliance  by 
the  Government  with  final  rulings  of  national  courts  and  orders  imposing  periodic  penalty 
payments153  remains  an  issue,  despite  a  joint  memorandum  of  the  three  highest  courts 
(Constitutional Court, Court of Cassation and Council of State) issued in July 2024 requiring 
it to  respect  court judgments154. In November 2024, FIRM-IFDH launched an investigation 
into  the  non-implementation  of  court  rulings  issued  against  Belgian  authorities155.  The 
Government  remains  under  supervision  by  the  Committee  of  Ministers  of  the  Council  of 
Europe  on  structural  issues  identified  by  the  European  Court  of  Human  Rights156.  It  has 
engaged in this process and underlined its commitment to remedy the violation found both at 
individual  and  general  level  in  judgments  of  the  European  Court  of  Human  Rights  without 
delay,  as  specified  in  the  action  plans  which  are  periodically  updated  and  sent  to  the 
Committee of Ministers157. However, in September 2024, the Committee of Ministers found 
that the Belgian Government had taken insufficient action to address the systematic problems 

149   Unia  functions  as  the  equality  body  at  the  federal  regional  and  community  levels,  except  on  the  Flemish 

level, where the Flemish Human Rights Institute functions as the equality body. 

150   Country visit Belgium, FIRM-IFDH. 
151   League of Human Rights (2025), written input, p. 23. UN General Assembly (1993). 
152   In  its  2024  Rule  of  Law  Report  the  Commission  recommended  Belgium  to  ‘Take  measures  to  ensure 
compliance  by  public  authorities  with  final  rulings  of  national  courts  and  the  European  Court  of  Human 
Rights’. 

153   Council of State Judgment No 257.300 of 13 September 2023; Flemish Refugee Council (2025); Judgment 
by  the  Brussels  Court  of  Appeal  of  30  January  2025  ordering  the  Belgian  state  to  as  soon  as  possible 
consult with the US to allow Nizar Trabelsi to return to Belgium at least temporarily and to provide him 
with  a  laissez  passer;  The  Council  of  State  has  on  several  cases  suspended  and  cancelled  arms  export 
licenses,  ruling  that  their  issue  was  contrary  to  international  humanitarian  law;  Country  visit  Belgium, 
FIRM-IFDH, Bar Associations, Human Rights Leagues. 

154   Country visit Belgium, Court of Cassation, Constitutional Court and Council of State; Joint memorandum 

of the three highest courts of Belgium of 19 July 2024.  

155   The investigation focuses on decisions handed down by Belgian courts against the authorities from 2014-

2024, which are not implemented by Belgian authorities. 

156   Judgment  of  the  European  Court  of  Human  Rights  of  18  July  2023,  Camara  v  Belgium  (application  no. 
49255/22); judgment of the European Court of Human Rights of 25 November 2014,  Vasilescu v Belgium 
(application no.  64682/12);  judgment of  the  European  Court  of  Human  Rights of  2  October 2012,  L.B.  v 
Belgium (application no.22831/08). 

157   Country  visit  Belgium,  Government.  The  action  plans  submitted  by  the  Government  and  decisions  by 
Committee  of  Ministers  are  presented  in  the  regularly  updated  Factsheet  ‘Belgium  -  Overview  of  main 
issues  before  the  Committee  of  Ministers  -  Ongoing  Supervision’,  prepared  by  the  department  for  the 
execution of judgments. 

16 

 
 
 
identified in the Camara v. Belgium judgment158. Overall, limited progress has been made on 
the 2024 recommendation. 

On  1  January  2025,  Belgium  had  17  leading  judgments  of  the  European  Court  of 
Human  Rights  pending  implementation,  a  decrease  of  4  compared  to  the  previous 
year159.  At  that  time,  Belgium’s  rate  of  leading  judgments  from  the  past  10  years  that  had 
been  implemented  was  70%  (compared  to  61%  in  2024;  30%  remained  pending),  and  the 
average time that the judgments had been pending implementation was 4 years and 9 months 
(compared  to  3  years  and  11  months  in  2024)160.  The  oldest  leading  judgment,  pending 
implementation  for  16  years,  concerns  the  excessive  length  of  civil  proceedings  at  first 
instance  level161.  As  regards  the  respect  of  payment  deadlines,  on  31  December  2024  there 
were 4 cases in total awaiting confirmation of payments (compared to 5 in 2023)162. On 16 
June 2025, the number of leading judgments pending implementation had increased to 18163.  

Despite a high level  of protection under the law, civic space remains narrowed164, and 
stakeholders are raising concerns regarding new obstacles to the right to demonstrate. 
Stakeholders continue to raise concerns regarding disproportionate preventive and repressive 
actions undertaken by public authorities undermining the right to demonstrate165. To prevent 
disruptions of public order and ensure public safety, the Government intends to introduce the 
possibility in the criminal code to impose an additional sanction of a prohibition to take part 
in  demonstrations  on  individuals  convicted  of  illegal  acts  committed  during  previous 
manifestations166. The Federal Human Rights Institute referred to a negative opinion it issued 
on  an  earlier  draft  for  a  judicial  demonstration  ban  under  the  previous  Government  which, 
according  to  FIRM-IFDH,  already  raised  questions  as  to  its  proportionality  and  practical 
enforceability167. On 7 October 2024, trade unions and several CSOs lodged a constitutional 
complaint  related  to  the  criminal  offence  of  ‘malicious  attack  on  government  authority’168. 
The Constitutional Court issued two judgments of particular relevance to civic space. On 19 
September  2024,  the  Constitutional  Court  annulled  a  provision  of  a  Flemish  Community 
decree on the subsidising of social-cultural work, which excluded certain organisations from 
eligibility  for  subsidies169. On  14  November  2024,  the  Court  pointed  to  the  need  to  restrict 
recourse  to  the  civil  law  procedure  based  on  which  Presidents  of  first  instance  courts  may 

158   Council of Europe, Committee of Ministers (2024b). 
159   For an explanation of the supervision process, see the website of the Council of Europe.   
160   All figures calculated by the European Implementation Network (EIN) and based on the number of cases 
that are considered pending at the annual cut-off date of 1 January 2025. EIN (2025), written input, p. 1. 

161   Judgment of the ECtHR, 44826/05, Bell v. Belgium, pending implementation since 2009.  
162   Council of Europe (2025), p. 156.   
163   Data according to the online database of the Council of Europe (HUDOC). 
164   Rating  given  by  CIVICUS;  ratings  are  on  a  five-category  scale  defined  as:  open,  narrowed,  obstructed, 

repressed and closed. 

165   League of Human Rights (2025), written input, p. 26. 
166   Coalition agreement, pp. 133-134. 
167   FIRM-IFDH (2023). 
168   Article  547  Criminal  Code;  Constitutional  Court,  case  number  8339,  Greenpeace  Belgium  and  others,  7 

October 2024 (pending). 

169   The Court concluded that the contested subsidy condition does not meet the requirements of the principle of 
legal certainty due to its ambiguous character; judgment of the Constitutional Court of 19 September 2024 
in case number 93/2024; 2024 Rule of Law Report Belgium, pp. 29, 30. 

17 

 
 
 
issue an urgent court order without hearing the opposing party, to a limited number of cases, 
excluding its use to challenge a strike170. 

170   Judgment of the Constitutional Court of 13 November 2024, case 123/2024. NGOs welcomed this decision; 

League of Human Rights (2025), written input, p. 5; 2024 Rule of Law Report Belgium, pp. 30-31. 

18 

 
 
 
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 

2025-2029/ 

Belgian  Government  (2025a),  Federal  government  agreement  2025-2029  (Accord  de  coalition 
fédérale 
2025-2029), 
https://www.belgium.be/sites/default/files/resources/publication/files/Regeerakkoord-
Bart_De_Wever_nl.pdf, 
https://www.belgium.be/sites/default/files/resources/publication/files/Accord_gouvernemental-
Bart_De_Wever_fr.pdf. 

regeerakkoord 

federal 

Audit  Vlaanderen  (2024),  Thematic  Audit  –  Analysis  of  the  Integrity  System  of  local  government 
(Thema-audit 
besturen), 
https://www.auditvlaanderen.be/lokale-besturen/auditplanning/thema-audit-analyse-van-het-
integriteitssysteem-van-lokale-besturen. 

integriteitssysteem 

Analyse 

lokale 

van 

van 

het 

Committee P (2024), Investigative Report on the recruitment, selection and training within the police 
(Rekrutering, 
politieorganisatie), 
https://comitep.be/document/onderzoeksrapporten/onderzoeksrapport%20over%20de%20rekrutering,
%20selectie%20en%20opleiding%20binnen%20de%20politieorganisatie.pdf. 

opleiding 

selectie 

binnen 

en 

de 

Constitutional  Court  (2024),  Judgment  of  the  Constitutional  Court  of  13  November  2024  in  case 
number 123/2024, https://www.const-court.be/public/n/2024/2024-123n.pdf. 

Council of Europe, Committee of Ministers (2024a), H46-6 Bell group v. Belgium (Application No. 
44826/05),  Supervision  of  the  execution  of  the  European  Court’s  judgments,  11-13  June  2024, 
https://hudoc.exec.coe.int/eng#{%22execidentifier%22:[%22004-1201%22]}. 

Council  of  Europe,  Committee  of  Ministers  (2024b),  H46-6  Camara  v.  Belgium  (Application  No. 
49255/22,  Supervision of the  execution  of  the  European  Court’s  judgments,  17-19  September  2024, 
CM/Del/Dec(2024)1507/H46-6. 

Council  of  Europe  (2025),  Factsheet  ‘Belgium  -  Overview  of  main  issues  before  the  Committee  of 
Ministers - Ongoing Supervision’, https://rm.coe.int/mi-belgium-eng/1680a23c80. 

Council  of  Europe:  Committee  of  Ministers  (2025),  Supervision  of  the  execution  of  judgments  and 
decisions of the European Court of Human Rights, 18th Annual Report of the Committee of Ministers, 
https://rm.coe.int/gbr-2001-18e-rapport-annuel-2024/1680b4d77d. 

Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  – 
Belgium. 

Court of Audit, Federal steering policy for the digital transformation of the justice system, December 
2024, https://www.ccrek.be/en/publication/federal-steering-policy-for-the-digital-transformation-of  

Court  of  Audit  (2025),  large  majority  of  public  officials  submitted  their  assets  and  mandates 
declarations  with  the  Court  of  Audit  (Overgrote  meerderheid  mandatarissen  diende  in  2024 
mandatenlijsten 
Rekenhof), 
https://www.ccrek.be/sites/default/files/PDF/20250214_Persbericht.pdf. 

vermogensaangiften 

het 

bij 

en 

in 

Cumuleo (2025), Written contribution received following the country visit. 

19 

 
 
Declaration by representatives of the judiciary (2025), Declaration by representatives of the judiciary 
and  call  on 
June  2025,  available  here: 
https://courdecassation.be .  

legislative  powers,  27 

the  executive  and 

(2025a), 
EPPO 
2024/index.html. 

Annual 

Report 

2024, 

https://www.eppo.europa.eu/assets/annual-report-

EPPO (2025b), Written contribution for the 2025 Rule of Law Report. 

European Centre for Press and Media Freedom, Media Freedom Rapid Response – Belgium. 

European  Federation  of  Journalists  (2024),  Belgium:  Serious  concerns  over  cases  of  preventive 
censorship  involving  four  media  outlets,  Belgium:  Serious  concerns  over  cases  of  preventive 
censorship involving four media outlets – European Federation of Journalists.  

European Implementation Network (EIN) (2025), written input for the 2025 Rule of Law Report. 

Federal Deontological Commission (2025), Written contribution received following the country visit 

Federal Police (2025a), Written contribution received following the country visit. 

Federal Internal Audit Service (2025), Written contribution received following the country visit. 

FIRM/IFDH(2023),  Advice  of  20  February  2023  on  the  judicial  ban  on  demonstrations,    FIRM  - 
05-2023 
IFDH  Advies 
Betogingsverbod_fr.pdf. 

05-2023  Betogingsverbod_0.pdf; 

IFDH  Advies 

FIRM 

- 

FIRM/IFDH  (2025),  Letter  to  the  Chamber  of  Representatives  on  legislative  proposal  656/1  on 
whistleblower protection for the Chamber of Representatives and the Senate (Brief FIRM/IFDH aan 
de Kamer over het Wetsvoorstel nr. 656/1 tot omzetting van Richtlijn (EU) 2019/1937 (…) inzake de 
bescherming  van  personen  die  inbreuken  op  het  Unierecht  melden,  wat  de  Kamer  van 
volksvertegenwoordigers  en  de  Senaat  betreft  /  Lettre  FIRM/IDFH  au  Chambre  concernant  la 
Proposition de loi n° 656/1 visant à transposer la directive (UE) 2019/1937 (…) sur la protection des 
personnes  qui  signalent  des  violations  du  droit  de  l’Union,  en  ce  qui  concerne  la  Chambre  des 
représentants et le Sénat), 25 February 2025. 

Flemish Minister of Domestic Administration (2025), Additional measures to improve integrity and 
deontology  for  local  governments  (Extra  maatregelen  om  integriteit  en  deontologie  bij  lokale 
besturen 
verbeteren), 
te 
https://www.hildecrevits.be/extra_maatregelen_om_integriteit_en_deontologie_bij_lokale_besturen_t
e_verbeteren. 

Flemish  Refugee  Council  (2025),  Dashboard  Non-reception  policy  (Dashboard  niet-opvangbeleid), 
https://www.caritasinternational.be/wp-content/uploads/2025/03/NL-Dashboard-Beleid-van-niet-
opvang-maart-2025.pdf?x24972. 

GRECO  (2022a),    Fifth  Evaluation  Round  –  Compliance  Report,  Belgium,  https://rm.coe.int/fifth-
evaluation-round-preventing-corruption-and-promoting-integrity-i/1680a53b99. 

GRECO  (2022b),  Fourth  Evaluation  Round  –  3rd  Interim  Compliance  Report,  Belgium, 
https://rm.coe.int/fourth-evaluation-round-corruption-prevention-in-respect-of-members-
of/1680a7eada. 

20 

 
 
 
(2024a),  Fifth  Evaluation  Round  –  Second  Compliance  Report,  Belgium, 

GRECO 
https://rm.coe.int/grecorc5-2024-3-final-eng-2nd-compliance-report-belgium-conf-2775-
2677/1680af94d7. 

GRECO (2024b), Fourth Evaluation Round – Addendum to the Second Compliance Report, Belgium, 
https://rm.coe.int/grecorc4-2024-1-final-eng-add-to-the-2nd-compliance-report-belgium-
con/1680af9498. 

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

Ministry of Justice (2025b), Policy Statement – Justice, 13 March 2025, doc. 56 0767/017. 

Ministry  of  Public  Administration  (2024),  Circular  of  16  June  2024  –  Conflicts  of  Interest 
(Omzendbrief Belangenconflicten), https://bosa.belgium.be/nl/news/omzendbrief-belangenconflicten. 

Ministry  of  Public  Administration  (2025),  Policy  Statement  –  Budget,  11  March  2025,  doc.  56 
0767/011. 

OECD  (2025),  Anti-Bribery  Convention  Phase  4  Report  on  Belgium,  25  March  2025, 
https://www.oecd.org/en/publications/2025/03/oecd-anti-bribery-convention-phase-4-report-on-
belgium_39a2856e.html. 

Ombudsperson (2024), Guide for Whistleblowers, December 2024 (Guide du lanceur d'alerte/ Gids 
voor 
https://www.federaalombudsman.be/fr/guide-du-lanceur-dalerte/ 
https://www.federaalombudsman.be/nl/gids-voor-klokkenluiders.   

klokkenluiders), 

Public prosecution service (2025a), Written contribution received following the country visit. 

Stichting  Overheidsopdrachten  (2024),  Memorandum  2024  –  8  points  of  action  for  better  public 
procurement  as  of the  next  legislature  (8  actiepunten om  performanter  aan  te  besteden tijdens  deze 
legislatuur), https://www.stichtingoverheidsopdrachten.org/initiatieven/memorandum/. 

UN  General  Assembly  (1993),  Principles  relating  to  the  Status  of  National  Institutions  (The  Paris 
Principles),  adopted  by  the  United  Nations  General  Assembly  resolution  48/134  of  20  December 
1993, https://ganhri.org/paris-principles/.  

Vlaamse  Vereniging  van  Journalisten  (2024),  Persveilig.be:  annual  review  2024,  Persveilig.be: 
annual review 2024 | Flemish Association of Journalists.  

Voorhoof Dirk (2025), Belgium: A model for the transposition of the EU anti-SLAPP Directive,  
Belgium: A model for the transposition of the EU anti-SLAPP Directive – Dirk Voorhoof – Inforrm's 

Blog.  

VRTNWS (2025a), House search of anti-corruption investigator (Huiszoeking bij anti-corruptiedienst 
van  federale  politie,  topman  verhoord),  https://www.vrt.be/vrtnws/nl/2025/02/06/huiszoeking-bij-
anticorruptiespeurder-federale-politie/. 

 VRTNWS (2025b), Head Anti-Corruption Investigator goes to Committee P out of fear of political 
influence  in  sensitive  files  (Hoofd  anti-corruptiespeurders  stapt  naar  Comité  P,  uit  angst  voor 
politieke inmenging bij gevoelige dossiers), https://www.vrt.be/vrtnws/nl/2025/02/12/speurders/. 

21 

 
 
 
 
Annex II: Country visit to Belgium 

The Commission services held virtual meetings in March 2025 with: 

•  Amnesty International Belgium 
•  Bureau of Integrity 
•  College of Courts and Tribunals 
•  Committee P 
•  Community Authorities for Media 
•  Constitutional Court 
•  Council of State 
•  Court of Cassation 
•  Federal Deontological Commission 
•  Federal Human Rights Institute 
•  Federal Ombudsmen 
•  Federal Police 
•  Federation of Belgian Enterprises (VBO-FEB) 
•  Flemish Association of Journalists (VVJ) 
•  Flemish Bar Association 
•  Flemish Media Regulator 
•  French- and German-speaking Order of the Belgian Bar 
•  High Council for Justice 
•  High Council for the Audiovisual 
•  Journalistic Ethics Council 
•  Liga voor Mensenrechten 
•  Ligue des Droits Humains 
•  Ministry of the Interior 
•  Ministry of Justice 
•  Prosecution Service 
•  Public Service Media 
•  Transparency International Belgium 

* The Commission also met the following organisations in a number of horizontal meetings:  

•  Amnesty International 
•  Araminta 
•  Civil Liberties Union for Europe  
•  Civil Society Europe  
•  European Civic Forum  
•  European Partnership for Democracy 
•  European Youth Forum, 
• 
• 
•  JEF Europe 
•  Philea – Philanthropy Europe Association. 
•  Transparency International  

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

22