Voluntary Algorithm Registration in Dutch Municipalities — What a 2025 Audit of the Ten Largest Found

Registration in the Netherlands' national Algorithm Register (launched December 2022) is voluntary, and municipalities decide for themselves whether an algorithm is high-risk. By February 2024 the register held 291 entries, led by Amsterdam (40), Utrecht (38), Den Haag (29) and Rotterdam (11), with about forty other municipalities listing 1 to 5 each (Gemeente.nu, 15 Feb 2024).
In November 2025 the civil-society group Bits of Freedom sent freedom-of-information (Woo) requests to the ten largest municipalities for the data protection impact assessments of their algorithms. All but two exceeded the legal decision period (four weeks, extendable by two); some took more than six months. Only four municipalities (Amsterdam, Groningen, Nijmegen, Utrecht) supplied documents usable for analysis, covering eleven algorithms: seven aimed at detecting rule violations such as benefit fraud and four at assistance such as early warning for debt problems (Binnenlands Bestuur, 22 Jan 2026).
Findings: municipalities without registered algorithms were found to use them; legal justification was sometimes sought after development; impact assessments were inconsistent and data protection officers' advice was not always documented; privacy statements rarely say which processes use algorithms. The researchers call for mandatory registration of high-impact algorithms and active publication of impact assessments. The case is a documented limit of voluntary transparency registers, not evidence of harm from any specific algorithm.

Read the full analysis: https://www.binnenlandsbestuur.nl/digitaal/grote-gemeenten-voldoen-niet-aan-regels-voor-algoritmes