Reporting obligations and investment assessment: BTI Annual Report 2024

In May 2025, the Bureau for Investment Screening (BTI) published its annual report for 2024. The BTI, part of the Ministry of Economic Affairs, assesses foreign investments and monitors compliance with economic sanctions to protect national security. Against the backdrop of increasing geopolitical tensions – including the war in Ukraine and international conflicts over technology and critical raw materials – the BTI emphasises that protecting Dutch economic security is more important than ever. 

The annual report provides insight into the impact of the Investments, Mergers and Acquisitions Security Screening Act (Vifo Act) and other relevant regulations on investment practice in the Netherlands. The annual report provides an overview of the application in 2024 of the Wet Vifo, the Telecommunications Act, the Electricity Act, the Gas Act and the new Offshore Wind Energy Act. 

Below are the key findings from the annual report with regard to investment assessments.

Increase in notifications and outcomes 
In 2024, the BTI screening team conducted 83 investigations, 69 of which were new notifications. This is a significant increase compared to 2023, when there were 55 notifications. Of the 83 investigations, 70 were completed in 2024, 61 of which were based on the Vifo Act. In addition, 14 informal opinions were issued on whether a transaction fell within the scope of the investment assessment system, double the number in 2023.

Of the completed investigations, 48 were approved unconditionally. In four cases, a screening decision was required, of which three transactions were approved subject to conditions. In one case, the Minister of Economic Affairs, in agreement with the Minister of Justice and Security, had to make use of the option to prohibit a transaction. Fourteen notifications were found not to fall within the scope of the Vifo Act or were withdrawn by the notifying party.

A large proportion of the investigations concerned investors from the Netherlands (28), followed by the United States (10), the United Kingdom (5) and Luxembourg (4). Most of the target companies were active in the industrial (35) and information and communication (14) sectors.

Processing times
All investigations were completed within the statutory time limits. In ten cases, the time limit was extended by a maximum of six months. A quarter of the investigations were completed within 35 days and 50% between 35 and 72 days. The transaction values varied widely, from less than €500,000 to more than €500 million.

Conclusion
The BTI's annual report for 2024 shows a clear increase in the number of investment assessments and a further expansion of the BTI's role as a supervisory authority. The extension of the scope of the Vifo Act to include new sensitive technologies, as announced in our previous alert, is expected to lead to even more notifications to the BTI in the coming years.

If you have any questions about the statutory investment assessments or need help completing the BTI notification form, please contact Friederike Henke, Susanna Tang, Anniek Edzes Koerts or one of the other BUREN specialists in our Corporate department. For more information about the Vifo Act, please visit our website, where you will find articles by Susanna and Friederike that discuss the application of the Vifo Act in more detail.