Netherlands Sunshine Reporting: How the Dutch Approach Shapes Europe’s Transparency Landscape
Table of content
- Who must report, and the material threshold
- What gets reported: categories and recurring issues
- What information is included in the Healthcare Transparency Register?
- Enforcement, accountability and legal backing — a shifting picture
- Comparisons and interoperability with EU frameworks
- Practical implications for companies and compliance leaders
- Bottom line
Author
Sabrina Morgan is the Head of Global Compliance & Customer Delivery at Vector Health. She oversees global transparency reporting and international disclosure requirements along with the Italian Sunshine Act strategy. She also leads the global client delivery team dedicated to data integrity, compliance solutions, and regulatory alignment for pharmaceutical and MedTech organizations.
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The Foundation for the Code of Conduct for Medicine Advertising (CGR) translated this policy push into practice, drafting a transparency code in 2011 in close consultation with stakeholders. Soon after, the medical devices (GMH) and veterinary products (CAVP) codes joined, creating the foundation for today’s centralized Healthcare Transparency Register (Transparantieregister Zorg). Since 2013, the register has published disclosures of payments and transfers of value, managed by the independent TRZ Foundation.
This history places the Netherlands in an interesting middle ground in Europe’s transparency landscape: a long-standing, centralized register born from self-regulation, but with momentum building toward firmer statutory rules. Understanding how the Dutch system works, what must be reported, and what may change is essential for compliance teams operating both locally and across EU markets.
Who must report, and the material threshold
Reporting obligations in the Netherlands stem from industry self-regulatory codes — the Code of Conduct for Pharmaceutical Advertising (CGR) and the Code of Conduct for Medical Devices (GMH). These require member companies to disclose certain financial relationships.
In practice, disclosures are made annually to the central Transparency Register, with submissions due between January and June for the prior calendar year and publication in July. The GMH Code applies a reporting threshold of €500 per calendar year per recipient, while the CGR requires reporting of specified categories of transfers. This hybrid model — centralized publication under the Stichting Transparantieregister Zorg, but industry-led reporting rules — is a defining feature of the Dutch approach.
What gets reported: categories and recurring issues
Typical reportable categories in the Dutch Transparency Register include:
- Consultancy fees paid to healthcare professionals
- Speaker fees and event-related honoraria
- Grants and donations provided to healthcare organisations
- Sponsorship of conferences and educational activities
- Financial support to patient organisations
The register publishes, per recipient (HCP or institution), the type of cooperation, the company involved, and the amount for that year. Searches are made by HCP/HCO, not by company.”
What information is included in the Healthcare Transparency Register?
The following information will be included in the Healthcare Transparency Register:
- The name of the healthcare provider involved (doctor, pharmacist or nurse), the partnership (e.g. scientific association or partnership) or the institution (hospital, patient organisation);
- The name of the company involved;
- The nature of the financial relationship (e.g. service provision or sponsorship);
- The total amount or fee paid by the company that year per individual financial relationship. The register does not specify who receives this amount. In many cases, companies do not pay the
- healthcare providers themselves, but rather the partnership or institution where they work;
The year in which the financial relationship took place.
Enforcement, accountability and legal backing — a shifting picture
industry monitoring, reputational consequences), rather than on statutory penalties for failures to disclose transfers of value. Disclosure of financial relationships over €500 must be reported annually in the TRZ, a requirement grounded in self-regulatory codes rather than legislation. By contrast, breaches of advertising rules can lead to administrative fines under the Dutch Medicines Act. The practical reality for compliance teams is that transparency enforcement remains reputational, not statutory — and any future move toward legislation would represent a significant change beyond what is reflected in the current framework.
Comparisons and interoperability with EU frameworks
At the EU level, industry-wide transparency practices are shaped by EFPIA’s Disclosure Code and by national registers across member states. The Dutch centralized register is relatively mature compared with countries that still rely solely on company-level disclosures, and it offers the advantage of a single searchable source for stakeholders. That said, differences in definitions, thresholds and reporting windows across countries mean companies operating regionally must reconcile multiple reporting workflows and taxonomies (and consider the European Gateway and other aggregation tools for cross-country visibility).
Practical implications for companies and compliance leaders
- Data governance matters. The Dutch register expects recipient-level detail — to avoid errors, companies must align CRM, finance, and medical affairs data feeds and agree standard classifications for event types, consulting, and educational support. Robust master data reduces rework at disclosure time.
- Affiliate coordination is essential under the Dutch system. Cross-border sponsorships or parent-company funding for local activities can trigger Dutch reporting obligations, and without a documented decision logic companies risk duplication or omissions. Establishing clear attribution rules across affiliates ensures consistent reporting into the Transparency Register.
- Prepare for change. With Dutch policymakers signalling intention to legislate, companies should map current disclosure processes to potential statutory requirements and consider small process improvements now (audit trails, opt-outs/consents where relevant, clearer service agreements) rather than waiting for final law text.
Bottom line
The Netherlands demonstrates a pragmatic, centralized model for transparency: well-established public reporting via the Healthcare Transparency Register, built on industry codes, and trending toward firmer legal clarity. For compliance teams in the country, this means three priorities — clean data, consistent affiliate rules, and readiness for statutory change. Getting those right will not only meet Dutch expectations but also position firms to navigate increasingly harmonized, but still varied, European transparency norms.