BTI Annual Report 2025

The Bureau for Investment Screening (Bureau Toetsing Investeringen, “BTI”) has published its annual report for 2025. The BTI, part of the
Ministry of Economic Affairs and Climate Policy, assesses investments for national security risks and monitors compliance with economic sanctions. Against the backdrop of ongoing geopolitical tensions — including wars and conflicts, and the global competition for knowledge, technology, data, and critical raw materials — the BTI states that protecting Dutch economic security remains a top priority. The annual report provides insight into the impact of the Investments, Mergers and Acquisitions Security Screening Act (Wet veiligheidstoets investeringen, fusies en overnames, also referred to as “Vifo Act”), the Telecommunications Act, the Electricity Act 1998, and the Gas Act. The key findings are outlined below.

Investment Screening Statistics: Rise in Notifications
The number of notifications continued to rise in 2025 compared to previous years. This increase is linked to a rise in investments in sensitive technologies. In 2025, the BTI conducted 91 investigations, 78 of which were new notifications. A total of 76 investigations were completed, 66 of which were approved unconditionally. Eight notifications were withdrawn or not processed because they fell outside the scope of the Vifo Act. In 2025, no notifications led to an assessment decision. Consequently, no prohibitions or measures were imposed.

In addition, 16 informal opinions were issued last year, allowing parties to receive non-binding advice in advance on whether a transaction falls within the scope of the investment assessment system.

A large proportion of the investigations involved investors from the Netherlands (41), followed by the United States (8), Luxembourg (5), and Germany (5). As in 2024, most of the target companies were active in the industrial (55) and information and communication (14) sectors.

All investigations were completed within the statutory time limits. The average processing time was 37 days, a slight decrease compared to 2024. A quarter of the investigations were completed within twenty days, and in half of the cases, it was communicated within 27 days that no assessment decision was required. In nine cases, the time limit was extended by up to six months.

Key Developments
Prohibition converted to conditional approval. In 2025, an appeal proceeding took place following a prohibition imposed earlier in 2024. In this proceeding, the Minister decided to convert the prohibition into a conditional approval.

First administrative fine for non-compliance with reporting obligation. The BTI determined that a transaction had taken place that was not reported, even though it should have been reported under the Vifo Act before it was completed. As a result, the Minister imposed an administrative fine on the parties.

New sectoral assessment. On July 1, 2024, the Dutch government launched a public consultation on the legislative proposal for the Defence and Security-Related Industry Resilience Act (Wet weerbaarheid defensie en veiligheid gerelateerde industrie). The BTI will implement and oversee compliance with the new sectoral investment screening for the defence industry. The proposal is expected to be presented to the House of Representatives in the fourth quarter of 2026.

Conclusion
The BTI's 2025 annual report shows a further increase in the number of investment screenings and a further expansion of the BTI's scope of responsibilities. With the announced extension of the scope of the Vifo Act to include new sensitive technologies, the number of notifications is expected to increase further.