Amended Security Screening Act: new obligations for employers
The Security Screening Act ('the Act') is currently being amended. The two main changes are the introduction of a location-related certificate of no objection (verklaring van geen bezwaar – vgb) and the introduction of a register of confidential position holders in active service. The amended Act is expected to come into force in early 2026.
In order to comply with the new Security Screening Act ('the Act'), the Security Screening Unit (UVO) is gathering relevant information for the register of confidential position holders in active service. Once the revised Act comes into force, employers of individuals holding a confidential position will be obliged to provide information for the register
Location-related certificate of no objection
The most important change to the Act is the addition and introduction of the location-related certificate of no objection. A location-related certificate of no objection remains valid even if the employee moves to a new post at the same designated location and the same level of security clearance. This creates more flexibility for sectors where employees in a confidential position regularly change employers. A designated location need not necessarily be a single physical location; it can also mean a certain sector or a group of physical locations.
Register of confidential position holders in active service
The amended Security Screening Act introduces a register of all individuals currently working in confidential positions: the register of confidential position holders in active service.
Companies working at designated locations, such as in civil aviation security, will be obliged to submit filings to UVO when a person is appointed to a location-related confidential position (reporting obligation). The obligation to submit filings to UVO when a person ceases working in a confidential position (reporting obligation) applies to all employers.
This will create an active register showing all confidential position holders in active service. UVO is responsible for keeping the register up to date, but employers are obliged to submit the relevant information.
What is expected from employers
When the new Act comes into force, the register must contain the details of all confidential position holders in active service. For this reason, once the Act comes into force, employers who request security screenings will be required to provide the details of all their confidential position holders in active service within four weeks. Extra information will be sent to employers to help them prepare for this. Details which will be required include:
First name(s)
Prefix(es)
Surname
Reference of certificate of no objection (file number)
Citizen service number (BSN)
Date of birth
Other amendments to the Act
The revised Act also makes it possible to request security screening for individuals who are not appointed to a confidential position (Article 13(2)). In practice, this provision will only be used by the Ministry of Economic Affairs.
Finally, the amended Act offers a good opportunity to make some other changes to improve the workability and enforceability of the Security Screening Act. One such change is the requirement that employers provide an annual prognosis of their staff turnover in order to anticipate the number of requests for security screenings.
FAQs
The legislative proposal affects those in charge of access to the designated locations, employers, confidential position holders at designated locations and applicants for such positions, and the ministers responsible for designating locations.
The amended Act gives a number of additional obligations to employers who employ or will be employing confidential position holders. These include the obligation to submit filings on their confidential position holders and to submit an annual prognosis of staff turnover in order to anticipate the number of requests for security screenings.
Under the Investments, Mergers and Acquisitions (Security Screening) Act ('Vifo Act'), this option may only be used within the context of economic security and at the request of the Minister of Economic Affairs.
If you request security screenings as an employer, you are obliged under the new Act to submit certain information. This information must be provided within four weeks of the Act coming into force. You will receive extra information about the exact details that must be submitted.
No, the register is not a replacement, nor it is possible to link it to your own HR system. This means you will still need to keep your own records/HR system. Due to security requirements, the register is held on a secure internal network which cannot be linked to external networks (including HR systems).
The purpose of the register is to check whether confidential position holders who are moving to another confidential position within the same location have a location-based certificate of no objection. This will ensure that the individuals in question will not require a new security screening when moving to a new employer at the same location, but their existing certificate of no objection can be reused.
The register must contain all the details specified in Article 10a(2) of the amended Act.
The details needed for the register may be submitted in a CSV file via eAV. The eAV module is already in use for requesting security screenings online. It is important that you have eHerkenning, the online login key that enables you to log into the eAV module. If you do not yet have eHerkenning, or you wish to authorise other members of staff, please go to [Linken naar eherkenning.nl].
The CSV format will be shared with requesters of security screenings (submitters) in late 2025. Details required include: - first name(s), prefix, surname, citizen service number (BSN), date of birth, reference of certificate of no objection (file number), security clearance level and position code.
No, this is not possible. To submit the necessary information, employers must use the CSV format. This will be made available to employers. This is the only way to ensure the information is correctly entered in the register.
Once the amended Security Screening Act comes into force, the new Article 10(4) provides a legal basis allowing you to submit the BSN.
Yes, it will be possible to consult the register in real time. However, you will need the relevant authorisations and it is only possible in specific cases. Instructions for this will follow when the revised Act comes into force.
No, this is not possible. The register can only be consulted to see which confidential position holders have a location-related certificate of no objection. Furthermore, the register can only be searched by name. With a view to privacy and security considerations, no overviews of employees will be shown.
No, this is not possible.It is only possible to look up individual confidential position holders in active service to check whether they already have a location-related certificate of no objection. It is not possible to look up confidential position holders with a position-related certificate of no objection.
It goes without saying that the security of personal data is paramount and we take thorough and effective measures to ensure this.
The Security Screening Unit (UVO) will ensure that new confidential position holdersare added to the register. Employers are obliged to submit the required filings for existing confidential position holders.
The same instructions apply to ABRO as to all other employers of confidential position holders.
