For organizations that prioritize transparency and accountability in their AI strategy
Key insight: The Netherlands has built a unique position as a pioneer in transparent algorithm administration with its Algorithm Registry. The Dutch Data Protection Authority (AP) published eight concrete guidelines in July 2025 to help organizations set up their registration. This practical approach creates not only internal control but also builds trust with citizens, customers, and courts.
Introduction
Since the introduction of the Dutch Government's Algorithm Registry in 2022, the Netherlands has been internationally recognized as a pioneer in transparent algorithm administration. Currently, approximately one thousand algorithms are registered and the registry grows daily. This marks the end of an era where "invisible" software decisions could escape attention. Organizations feel the societal pressure to document the entire lifecycle management of their algorithms. The Dutch Data Protection Authority (AP) provides eight concrete guidelines in the brochure Getting Started with Algorithm Registration (July 2025) that form the basis of this article. The AP has recently indicated that algorithm registration in the Netherlands needs improvement and calls for mandatory registration for government organizations. Those who set up the registration structure properly create not only clarity for internal supervisors but also build trust with citizens, customers, and courts.
Two goals – one registry
The AP summarizes the purpose of an algorithm registry concisely:
"In broad terms, algorithm registration has two overarching goals. The first goal is to promote internal control... The second goal is to promote external control by providing transparency."
Internal control is about governance – who is responsible, which datasets are used, what risk measures have been taken. External control focuses on public accountability: journalists, scientists, and citizens must be able to see what an algorithm does and why. By incorporating both goals in one logical structure, no duplicate forms arise and auditors can ask targeted questions.
Legal and societal milestones
The timeline below shows the most important steps:
| Date | Event | Relevance for organizations |
|---|---|---|
| 2022-10 | Launch Dutch Algorithm Registry | First publicly accessible registry; voluntary participation stimulates cultural change. |
| February 1, 2025 | Publication Report AI & Algorithm Risks Netherlands | Clarifies which sectors fall under "high risk." |
| May 20, 2025 | The Hague Court (ECLI:NL:RBDHA:2025:9525) | Judge weighs transparency obligation; explicitly mentions the registry as mitigation. |
| July 2025 | AP brochure with eight guidelines | Practical standard for organizations in both public and private sectors. |
| August 2026 | EU database for high-risk AI active (Art. 49 AI Regulation) | Registration requirement before market approval; connects to national registries but doesn't replace them. |
The court ruling of May 2025 deserves extra attention. The court honored the Tax Authority's appeal on enforcement effectiveness, but set the bar high: the service had made "as much as possible" information public AND put relevant parts in the Algorithm Registry. Otherwise, the outcome would probably have been different. This case illustrates that a carefully maintained registry can serve as a legal safety net.
Important legal lesson
The court in the Tax Authority case emphasized that transparency through the algorithm registry plays a crucial role in balancing interests. A well-maintained registry can serve as a legal safety net and proof of compliance.
Eight guidelines translated into practice
The AP names eight steps to successfully set up a registry. The table below links each step to concrete questions you can ask today:
| Guideline | Practical question | Example from the brochure |
|---|---|---|
| 1. Formulate the goal | Do we mainly want to improve internal governance or also inform customers? | Financial institution that makes credit algorithms transparent for customers. |
| 2. Define the scope | Which algorithms affect external stakeholders? | Student tracking system at school versus spell checker in the office. |
| 3. Start with what exists | What minimal description can we record now? | Include short operational description, add details later. |
| 4. Document context | What policy consideration underlies this algorithm? | Koornwoude subsidy scheme where old income threshold continued to apply. |
| 5. Describe risks and mitigation | What risk classification (low/medium/high) belongs here? | DPIA, fairness audit, objective justification for possible bias. |
| 6. Maximize transparency | Which information can be public, what remains confidential and why? | FOIA request Tax Authority; public part + confidential layer for supervisor. |
| 7. Design user-friendly form | Can citizens find the registry with two clicks? | B1 web text as first layer, click through to technical details for experts. |
| 8. Ensure management and role division | Who monitors completeness and currency? | Manager with mandate to force software suppliers to deliver. |
By asking such questions per guideline, you prevent the registry from becoming a paper tiger. It's about gradual improvement; expanding Excel tables can later migrate to an API-driven dashboard.
Practical warning: An algorithm registry that is only used as a compliance checkbox misses the point. The real value lies in the conversations and reflection that the registry initiates.
Numbers that speak
- ± 1000 algorithms have been registered in the public sector since 2022.
- Municipalities such as Amsterdam, Eindhoven and Rotterdam promote the Algorithmic Transparency Standard, including template and explanation, causing the number of registrations in those cities to grow three times faster than nationally.
This pace will likely increase when the AI Regulation opens the European database in 2026 and suppliers must report "at the gate" which models they make available. However, national registries remain necessary for low- and medium-risk models AND for controls during the usage phase. The brochure says about this:
"This database may overlap with an algorithm registry, but is not a replacement for setting up your own algorithm registry."
Koornwoude case – policy changes, algorithm remains
The fictional municipality of Koornwoude learned in 2025 how decisive old policy choices can be. In a subsidy scheme against heat stress, a hard income threshold of €32,000 automatically rejected applications. When the political priority shifted to customization, the algorithm registry immediately pointed to the guilty decision criterion. Without such a logbook, the error would probably only have come to light years later.
Lessons from Koornwoude
- Always document the policy considerations behind algorithmic decisions
- Keep track of when and why parameters were set
- Ensure traceability of decision criteria
- Plan regular reviews of algorithm parameters
Judicial review and transparency
In the Tax Authority case from May 2025, the court weighed three principles: inspection effectiveness, operational safety, and discrimination controls. That balance is precarious. However, the judge emphasized that the algorithm registry had already made a large part of the information public. This made it "verifiable enough" to prevent inspection fraud while still offering substantial openness.
Looking ahead
Registration is the beginning, not the endpoint. The real value lies in the conversations that a living registry initiates: data scientists who add a new risk score with every model update, lawyers who explain why certain fields cannot be public, policymakers who clean up old parameters when policy changes. From August 2026, the European database will put extra pressure, but those who already apply the eight guidelines now won't be running behind the facts later.
Practical tip: Start documenting your algorithms today, even if the registry isn't perfect yet. Experience shows that organizations that start early benefit most from their registration efforts later.
Practical checklist for the first step
Step-by-step implementation
- Identify scope: which algorithms affect external stakeholders?
- Start small: begin with a simple description of existing algorithms
- Plan governance: who is responsible for maintenance and updates?
- Determine transparency level: what can be public, what remains internal?
- Integrate into processes: make registration part of the development cycle
Concrete action points
- Study the AP brochure and identify which algorithms within your organization may fall under the scope.
- Map out what information is already available and what gaps exist.
- Determine who will be responsible for maintaining the registry.
- Plan a first registration of your most important algorithms.
- Consider how you can maximize transparency without giving away trade secrets.
Final thoughts
The Netherlands has shown in three years that transparent algorithm administration is not a future plan but an executable practice. It's now up to organizations to further refine that practice and ensure that AI applications are not only smart, but above all responsible and explainable.
The eight guidelines from the AP provide a solid foundation for organizations that want to seriously work on algorithm registration. Those who follow this approach build not only compliance but sustainable trust in their data-driven decision-making.
The path to transparent algorithm administration requires investment in time, resources, and culture, but delivers decision-making that truly does justice to the complexity of our digital age.
This article is an initiative of geletterdheid.ai. We help organizations navigate the complexity of the EU AI Act and build responsible AI practices. Do you have questions about algorithm registration in your organization? Contact us.