On March 24, 2026, the Dutch Senate (Eerste Kamer) rejected the Act on transparency and countering subversion by civil society organizations (Wet transparantie en tegengaan ondermijning door maatschappelijke organisaties) (“Act”). The Act was designed to counter undesirable foreign influence on civil society organizations in the Netherlands through donations.

Under the proposed Act, civil society organizations, such as foundations (stichtingen), associations (verenigingen), and religious communities (kerkgenootschappen), as well as comparable foreign-law entities that habitually carry out activities in the Netherlands, would be subject to a disclosure obligation. This obligation requires civil society organizations to make information available to specifically designated government authorities. The information concerned relates to the origin, purpose, and amount of donations with a value of EUR15,000 or more, regardless of whether those donations originate from within or outside the Netherlands. By means of a general order in council (algemene maatregel van bestuur), this threshold may be lowered for certain countries that are considered to pose a heightened risk of undesirable foreign influence. Under the proposed Act, the board of a civil society organization would be required to retain the donation records for five years. Where donations prove to be substantial, further enquiries into the donor’s identity may follow. In addition, foundations that are not currently required to publicly file annual accounts (or equivalent financial statements) would be required to deposit their balance sheet and income and expenditure statement with the Dutch trade register (handelsregister) within ten months of the end of the financial year.

Concerns have been raised about the effectiveness of the Act, the use of open-ended standards susceptible to broad interpretation, and the reluctance on the part of the authorities tasked with enforcement. The financial reporting obligation for foundations was not addressed during the vote.

It remains to be seen whether the Act will be amended and resubmitted. Q.G.M will continue to monitor the progress of this Act. Please feel free to reach out to one of our corporate lawyers if you have any questions or need advice.