The Netherlands to centralise sanctions reporting obligations if International Sanctions Act comes into force

3 November 2026

In February 2026, the Dutch government submitted draft legislation to Parliament to replace the 1977 Sanctions Act with a new International Sanctions Act (see our coverage). The Bill is before the House of Representatives and is scheduled to be debated in November 2026.

The Bill provides for an administrative body to be designated to receive reports made under reporting obligations in Dutch sanctions legislation, check reports for accuracy, collect and analyse data to advise on sanctions legislation, and provide guidance on sanctions reporting obligations.

The explanatory memorandum says that the designated body will initially be the Foreign Minister, who will set up a central sanction reporting point (“centraal meldpunt sancties”, CMS) to carry out these functions. In a  letter to the House of Representatives of 27 January 2025, the Foreign Minister said the government would develop the CMS within the Foreign Ministry, but that it could only become fully operational once the International Sanctions Act enters into force.

In its June 2026 reply to questions from the House’s Foreign Affairs Committee, the government said it intends the Act to come into force “as soon as possible” after it is approved by the House of Representatives and Senate, but that it will aim for it to come into force on 10 July 2027 if it cannot come into force before this date.