The Environment and Planning Act

The main instrument for regulating land use is the Environment and Planning Act and the four accompanying general administrative decrees:

• the Environment Decree (Omgevingsbesluit);
• the Environmental Quality Decree (Besluit kwaliteit leefomgeving);
• the Physical Environment Decree (Besluit activiteiten leefomgeving); and
• the Environment Buildings Decree (Besluit bouwwerken leefomgeving).

Regulated topics

The Environment and Planning Act regulates everything concerning the physical living environment. The physical living environment is a broad concept and includes at least the following:

• constructions;
• infrastructure;
• water systems;
• water;
• soil;
• air;
• landscapes;
• nature; and
• cultural heritage.

The Environment and Planning Act aims to achieve and maintain a safe and healthy physical living environment and good environmental quality, taking into account the intrinsic value of nature, and the efficient management, use and development of the physical living environment in order to meet social needs.

Zoning Plan

In addition to the general rules set out in the Environment and Planning Act and the administrative decrees, most rules relating to project development and land use/zoning can be found in the municipality’s “environmental plan”. This functions as a zoning plan, but with a wider scope, covering everything related to the physical living environment (it is referred to hereafter as the “zoning plan”).

Each municipality has one zoning plan for its entire territory that designates permitted uses and sets out general rules relating to the physical living environment. The zoning plan is, in principle, adopted by the municipal council.

Old zoning plans under previous law have become part of the new zoning plan by operation of law through the transitional provisions of the Environment and Planning Act.

A number of topics that were previously regulated at national level have now been transferred into the zoning plan. As these rules have been “handed down” to local authorities by the national government, this set of rules is referred to as the “dowry”. These topics include permit requirements relating to the construction, maintenance and use of structures, with the associated assessment rules and application requirements for a permit. They also concern rules stipulating which structures and buildings are exempt from permit requirements. Municipalities may adopt, amend or repeal these rules at local level (some have already done so, while others are still in transition). As a result, rules that previously applied everywhere may now differ from one municipality to another.

Competent Authority for Projects

In the Netherlands, there are four levels of government:

• national;
• provincial;
• water boards; and
• municipalities.

In principle, the municipality is the competent authority for spatial planning and zoning, though there are exceptions. The national legislature has regulated a number of matters. The province is important in projects that affect provincial interests, and water boards are the competent authority with regard to water management. Municipalities may establish customised regulations, unless higher-level rules state otherwise, so rules may vary locally.

Project developers mostly deal with the municipality. The municipality co-ordinates with other relevant bodies and regulations. Many national and provincial requirements are incorporated into the municipal zoning plan.

In many areas, there is considerable scope for municipalities to incorporate local regulations into their zoning plans. This applies to topics such as zoning, noise and external safety.

Technical requirements

Technical requirements for structures are regulated nationally in the Environment Buildings Decree. This Decree sets rules on construction, safety, fire safety and energy efficiency, etc. In addition, the Environment Buildings Decree specifies for which structures a permit is required. All structures must comply with these rules. These technical rules may not be deviated from in the zoning plan; the zoning plan can only relate to spatial aspects of building activities.

Good governance

In all their actions, government bodies are bound by the general principles of good governance. This applies to both public and private law actions, including when an agreement is concluded with a government body.

The general principles of good governance include (among other things) that:

• a government must prepare and justify its decisions carefully;
• similar cases must be treated equally; and
• government bodies must observe legal certainty.

Furthermore, powers may not be abused and, in principle, the promises made by a government body must be able to be relied upon.

Developments Involving the Environment and Planning Act

The Environment and Planning Act has been in force since 1 January 2024. Since then, there have been a number of developments involving this relatively new Act.

Two years on, (local) governments are still transitioning to this “new” legal system. Zoning is now centred around an environmental plan for the entire municipal area (omgevingsplan); see 1.1 Main Sources of Law. Before 2024, a municipality established (various) zoning plans which covered parts of a municipality (bestemmingsplan); some municipalities had over 100 zoning plans in place. The entry into force of the Environment and Planning Act (automatically) replaced  all of the zoning plans in the municipalities. Two years later, the environmental plan is essentially still a hodgepodge of all former zoning plans that were in place up until 1 January 2024.

In practice, regional governments are still trying to fit their “old” habits in. Under the former law, projects that did not fit within the zoning plan were often made possible by means of a change to the zoning plan. Up until 1 January 2026, municipalities may use a temporary arrangement (TAM-IMRO) under the Environment and Planning Act to amend the environmental plan using the former technical standard, as a transitional measure towards the new standard (STOP/TPOD). This arrangement served as a safeguard for area development projects; however, as of 1 January 2026 this workaround is no longer permitted. Municipalities are required to switch to the new standard for any new amendments. This transition period seems to have still been too short; expectations are that the transition will continue to be a practical hurdle for new land developments.

Owing to these changes regarding the modification of an environmental plan, in practice projects are mostly made possible by a permit for “an activity outside the environmental plan”, commonly known as the BOPA permit, and this has become a widely used instrument.

Priority Housing Construction Cases

Owing to the significant social importance of housing construction, the Administrative Jurisdiction Division (the highest general administrative court) has decided to prioritise housing construction cases over other environmental law cases until at least the summer of 2026. This project was originally due to end in July 2025, but has been extended due to the significant social relevance.

Legal Developments

A relevant development is the bill to strengthen control over housing (Wet versterking regie volkshuisvesting). The bill will amend a number of laws, including the Environment and Planning Act and the Housing Act. This bill will enable authorities to control how much, where and for whom housing construction takes place. The national government, provinces and municipalities will thus be able to regain control over public housing and the housing task. The bill has been passed by the House of Representatives and is now before the House of Lords. The expected date of entry into force is 1 January 2026.

The Strengthening Control on Housing Act will affect developers, investors, housing associations and other stakeholders in the real estate sector; see 4.2 Underwriting Standards. The imposed affordability and social housing obligations (respectively two thirds and 30% of all homes to be realised) are a limitation on the revenue potential of project developments.

Nitrogen/Nature Permits

Part of the permit process is figuring out whether a nature permit is needed. Under the Habitats Directive, the Netherlands has designated 162 Natura 2000 sites, spread across the country, including in near proximity of urban areas. According to legislation based on the Habitats Directive, a permit is required for any plan or project likely to have a significant effect on the relevant Natura 2000 site. In practice, this permit procedure often presents challenges due to the poor condition of the Dutch Natura 2000 sites.

In short, this has led to an increasing dependency on the competent authority’s nature/nitrogen policy. As a project developer, it is advisable to maintain close contact with the competent authority and to carefully consider the location in relation to nature and nitrogen. Some provinces or municipalities have already implemented more (potentially additional) measures than others.

Grid Congestion

Another element that complicates project development is that the limits of the Dutch electricity grid are coming into view increasingly quickly. When developing a project, it is important to address the project’s power supply in a timely manner. For large commercial connections, waiting times can extend to months or even years (up to ten years in cases of extreme congestion), with regional differences and complexity being important factors. Since the waiting times vary per region, it may be a relevant parameter when selecting locations to develop a new (housing or other) project. The advice is to submit applications well in advance.

Grid congestion is becoming an increasingly large obstacle for project development. However, the market is coming up with all sorts of initiatives for building “grid-consciously”, in an effort to cope with the limited transport capacity available.

Relevant Permits

In short, there are permit requirements under the Environment and Planning Act and under the zoning plan.

The permit requirements relevant to projects under the Environment and Planning Act relate to:

• activities under the zoning plan;
• Natura 2000 (nature);
• construction (see under Technical requirements in 1.1 Main Sources of Law);
• flora and fauna; and
• activities near motorways, railways, waterways, etc.

In the zoning plan, the municipality includes permit requirements with the associated assessment framework on the basis of which the permit can be granted. The municipality has discretion in determining the assessment framework.

If a project does not fit within the zoning plan, it can be enabled by:

• amending the zoning plan; or
• a permit to allow for a deviation from the zoning plan.

This kind of permit is called a BOPA permit (see 1.2 Main Market Trends and Deals). The municipality may grant the BOPA permit if the activity complies with a “balanced allocation of functions to locations”. It is up to the competent authority to determine what that criterion entails. To a large extent, this is a political decision. 

In the Netherlands, municipalities usually do not reserve space for construction projects in their zoning plans beforehand. This means that it is very unlikely for a project of any size to already fit within the zoning plan. New projects are made possible by either:

• amending the zoning plan; or
• applying for a BOPA permit.

Both options require the co-operation of the municipality. At the outset, projects are therefore discussed in detail with the municipality and further developed in consultation. This includes discussion on the public law instruments needed to make the projects possible.

Construction Activities

For construction activities, two permits are distinguished:

• the spatial permit requirement, which, if included, follows from the zoning plan; and
• the permit requirement for the technical construction activity.

These are two separate permit procedures with separate assessments.

The permit requirements in the zoning plan relate exclusively to the spatial impact of construction activities. Permit requirements for technical construction activities are regulated at national level, in the Environment Buildings Decree.

The Environment Buildings Decree specifies which constructions are subject to a permit requirement or a notification requirement. For instance, the construction of ground-level dwellings is only subject to a notification requirement; there is no permit in respect of the technical construction activity. The notification requirement means that a notification must be made to the competent authority prior to construction and upon completion of construction. The notification of completion must be accompanied by information demonstrating that the structure complies with the technical requirements of the Decree. Also, the notification must include a statement from an independent “quality assurance” body confirming that the structure complies with all technical requirements.

While there is no permit requirement for the technical construction activity, the spatial construction activity may still be subject to a permit on the basis of the zoning plan. Municipalities may also waive the permit requirement for spatial construction activities and simply impose general rules that the initiator must comply with; however, the authors have not yet encountered this in practice.

Change of Plans

A permit relates to a specific plan/specific activity. If any part of the building plan or the intended use changes and this change requires a permit, a new permit or a change to the permit may be required. Changes in ownership have no effect on the permit.

Tools for Land Acquisition

Preferential rights

The municipality may establish preferential right on a property. The preferential right gives the municipality a right of first refusal. This is a passive instrument; the preferential right does not compel the owner to sell, but limits the transferability of the plot. If an owner wishes to sell, they must first offer the plot to the municipality. If the government accepts the offer, negotiations follow. If the parties cannot reach agreement on the sale, the price for the property is determined by the court. 

The preferential right is established by means of a preferential right decision. This occurs without prior notice; the owner is informed only after the right of first refusal has been established. This is followed by spatial decision-making. There must be a basis for the right of first refusal, which is often the zoning plan. A right of first refusal based on the zoning plan is valid for five years, and the term can be extended. In practical terms, there are no possibilities of opposing the right of first refusal. Any agreements that appear to be intended to circumvent the right of first refusal are void.

Expropriation

The Environment and Planning Act includes stipulations on expropriation. Expropriation is possible if there is a necessary and urgent interest in expropriation.

The authority must first have attempted to acquire the land amicably. The decision to expropriate must be confirmed by the court. Also, the title for expropriation must be laid down in the zoning plan or in a project decision. If expropriation takes place, the authority must fully compensate the expropriated party.

If the expropriated party is willing and able to carry out the development itself, there is no need for expropriation. The expropriated party must demonstrate that it has a concrete and implementation-oriented intention to carry out the development itself in the manner intended by the competent authority.

Environmental Impact Assessment

For all projects of certain size, there is an obligation for the initiator to draw up an environmental impact assessment report (a so-called “project environmental report”) and submit it with the application for a permit. The kinds of projects this applies to follows from Annex V to the Environmental Decree (Omgevingsbesluit). The initiator may request the competent authority to provide advice on the scope and level of detail of the report. The environmental impact report identifies the environmental effects of the plan, as well as possible alternatives and measures to reduce the negative effects. When adopting an environmental plan, the municipality shall draw up a plan environmental impact assessment.

In cases where this report is not required, the environmental consequences of the project must also be substantiated when applying for a permit. Research must cover climate, water, soil, nature, flora and fauna. Research must also be conducted into the effects of sunlight, wind nuisance, parking, traffic, noise and external safety. The only real difference with the reporting obligation is that the content of this research and the procedure is not prescribed. However, the scope of the research is essentially the same.

Project Development Tools

There is no single prescribed procedure for making a project possible. The most common method is to enter into agreements with municipalities in which arrangements are made regarding the use of the instruments under public law in favour of the project. Subsequently, to make the project possible, either an amendment of the zoning plan or a BOPA permit will be chosen.

Project Decisions

A “project decision” is an instrument that can be used by water boards, provinces and central government to enable large projects of public interest. This may concern government projects as well as public-private partnership (PPP) projects. The Environment and Planning Act specifies cases in which a project decision must be used. However, a government body may also opt for this in other cases.

All activities that require a permit can be embedded in a project decision, so the project decision and the permits can be adopted together. Alternatively, the necessary permits can be issued by the regular competent authority, such as a municipality. A project decision can also be used to amend parts of a zoning plan.

As explained in 2.1 Types of Approvals, a project can be enabled either by amending the zoning plan or by a BOPA permit being granted.

In amending the zoning plan, the municipality may incorporate all kinds of requirements into the project. The substantive assessment, also based on the criterion of a balanced allocation of functions to locations, is up to the municipality.

As indicated previously, a BOPA permit can be granted by the municipality if there is a balanced allocation of functions to locations; the municipality can impose all requirements it deems necessary on a project based on its assessment of what it considers to be such a balanced allocation of functions to locations. This discretion allows the local council to indirectly impose requirements on a project.

Sustainability

Sustainability also applies to a municipality’s ambitions with regard to sustainability, climate-neutral solutions, energy efficiency, etc. These topics are usually reflected in either the assessment framework of the zoning plan, or in the assessment of what the municipality considers to be a balanced allocation of functions to locations.

Permit Instructions

The competent authority may include certain instructions in the environmental permit that must be observed when carrying out the permitted activity. For example, the permit holder may be required to take certain technical or organisational measures.

In the Netherlands, it is not the case that a project must be compensated with certain benefits. However, an authority may include certain measures in a permit to offset the adverse effects of a plan as conditional obligations. For example, a noise barrier must be constructed, or certain green spaces must be created.

Cost Recovery

Cost recovery (kostenverhaal) is part of land development. Construction activities are not permitted without payments having been made regarding cost recovery.

Right to Appeal

Regarding formal decisions by the municipality such as the refusal of permits, a procedure for objection to the decision may be initiated within six weeks after the decision is published. Subsequently, the decision on the objection may be appealed to the administrative court within six weeks. After that, an appeal may be lodged with the Administrative Jurisdiction Division, for which a period of six weeks after the appeal decision also applies.

Permit Procedures

In principle, a regular preparatory procedure applies to the granting of an environmental permit. The regular procedure means that the competent authority will, in principle, decide on the permit within eight weeks of the application. The competent authority has the option to extend this period by six weeks.

An extended procedure applies in cases designated by the competent authority. For example, this is the case when establishing or amending a zoning plan. The municipality may determine that this procedure applies to BOPA permits that may have significant consequences for the physical living environment.

In the extended preparatory procedure, the competent authority decides within six months of the application, with a possible extension of six weeks. First, the draft decision is published, and third parties may submit their concerns or opinions. The competent authority shall state in the decision why the opinions have or have not been taken into account in the final decision.

Proceedings against the adoption of a zoning plan are brought directly before the Administrative Jurisdiction Division (skipping the administrative court).

Citizen Participation

Municipalities involve local residents and other parties concerned in developing a plan. By raising objections at an early stage and, where necessary, incorporating them into the plans, they ensure that decisions are widely supported.

An initiator of a project can involve local residents and give them a say prior to applying for a permit.

Third-Party Appeal

Once a permit has been granted, the decision will be published. Concerned parties may initiate an objection procedure; after this, appeal and further appeal to the court are possible.

To be considered a “concerned party”, there must be a direct and personal interest. Furthermore, under Dutch law, the administrative court cannot overturn a decision if the legal norm that has been violated clearly does not serve to protect the interests of the person invoking it. In addition to the fact that the appealing party must be a concerned party, the infringed standard must serve to protect their interests.

Organisations such as NGOs, whose objective is to protect certain interests, are considered to be a concerned party if the decision affects their goal/special interest.

Obtaining the Permit

It is important to stress that it is at the discretion of the municipality whether or not to grant the permit.

If the project fits within the zoning plan and meets the assessment frameworks for the permit, the permit can, with some degree of certainty, said to be obtainable. If all conditions are met, the municipality may not refuse to grant the permit.

If a zoning plan sets many open standards or contains little regulation, it may be that more considerations need to be made when assessing the permit. This makes the permit more “sensitive” to objections from third parties. After all, the municipality’s assessment does not take place at the time when the zoning plan is adopted, but at the time when the permit is granted. When the substantive assessment is made, objections may be raised. If the frameworks are already in place and there is little room for discretion, there can be fewer objections. Objections can then only concern the application of the rules, not the substantive assessment. Therefore, the degree of certainty beforehand that a permit can be obtained depends much on the content and wording of the zoning plan.

If a BOPA permit is required, a substantive assessment will in any case be carried out by the municipality. The competent authority may grant the environmental permit for a BOPA if the activity complies with a “balanced allocation of functions to locations”. The municipality has a wide discretion in interpreting this standard.

Influence

The extent to which the opinions of third parties are influential is entirely up to the municipality. Sometimes, the project is modified in response to objections raised by third parties.

In general, complaints or objections regarding traffic, views, privacy and sunlight are not very likely to succeed.

For all projects of any scale, an agreement with the municipality is common. The content of the project is discussed with the municipality in order to secure its co-operation. Agreements are then made about cost recovery and the use of public space.

It is customary to first conclude a preliminary agreement setting out certain preconditions, followed by a more detailed agreement on the further elaboration of the plans for the project and cost recovery.

Typical situations include:

• projects on land owned by the municipality, sometimes preceded by municipal land acquisition;
• projects on mixed public/private land ownership (there are several options available; parties can establish a PPP, or the municipality can sell the land to the developer); and
• projects on privately owned land.

Co-Operation Agreements

In order to realise a project that does not fit within the zoning framework, developers often enter into agreements with municipalities about how the municipality will use its public law powers to make the project possible. In addition to obligations for the developer, the parties include best-efforts obligations for the municipality in the co-operation agreement.

Anterior Agreements

Under the Environment and Planning Act, public authorities are obliged to recover costs from the initiator for certain activities. This is the case, for example, for the construction of dwellings, commercial premises and shops.

Cost recovery can be regulated under both private and public law. In practice, this is almost always regulated in a so-called “anterior agreement”. This also sets out agreements about the project.

Leasehold

Some Dutch municipalities own large amounts of land that they lease out on a long-term basis. In some municipalities, this applies to virtually the entire territory. The leasehold may be temporary or perpetual.

It is usually stipulated in the leasehold conditions that the leasehold gives a right of a certain type of usage of the property. In the event of a change in permitted use, compensation must generally be paid for the amount of the economic added value of the changed use.

Purchase Agreements

Many Dutch municipalities play an active role in land policy and acquire land for area development. Land transactions with municipalities are therefore common.

The zoning plan is sometimes amended before the purchase, though this is not always the case. Again, the municipality has a great deal of freedom in its way of approaching things.

Didam case law

According to the so-called Didam case law, a government body must allow competition between candidates when selling land, unless it can be assumed on the basis of objective, verifiable and reasonable criteria that there are no other potential candidates. In that case, the intention to sell must be published in advance, with the government body having to substantiate why there is only one serious candidate for the land.

If there are several candidates, the buyer must be selected on the basis of objective, verifiable and reasonable criteria.

An agreement concluded in contravention of this Didam case law is not void or voidable, but the government may be liable for damages to the candidate who was not given an equal opportunity to compete for the land.

Validity

A permit relates to a specific plan/specific activity. Changes in ownership have no effect on the permit. Permits are valid indefinitely, unless a specific term is included in the permit. The competent authority may, however, revoke a permit if no activities have been carried out under the permit for a period of one year or a longer period specified in the permit.

If a permit application has been rejected, the applicant may reapply, but must provide new facts or changed circumstances. In short, it is not possible to submit the same application twice – it will be rejected.

An irrevocably adopted zoning plan remains in force until a new or amended plan is adopted.

Irrevocability

A permit or zoning plan can only be challenged within six weeks. If the period of six weeks within which an objection or appeal can be lodged against a decision has expired without being used, the decision becomes irrevocable. This applies to all decisions, including permits and zoning plans. It is then no longer possible to take action against them.

Only when the decisions that enable the project are irrevocable can the initiator be certain that they may carry out their plan.

Marginal Review by the Courts

As indicated under 2.1 Types of Approvals, the clearer it is that the activity is permitted under the applicable rules, the less likely it is that third parties will successfully oppose it. It is up to the municipality to make a substantive assessment, at its discretion. The municipality can do this in advance in generally binding regulations, but, if the general rules leave room for consideration at the time of granting the permit, the substantive assessment will be based on the application.

The court does not intervene in the substantive assessment of the government body, but conducts a marginal review. The court does not have its own opinion on what a “balanced allocation of functions to locations” is. The court’s assessment is limited to the question of whether the decision was made in the correct manner – for example, whether the government body weighed all relevant interests in its decision-making. Decisions are also assessed against the general principles of good governance.

Consequences of Lengthy Proceedings

Financing a project is very often dependent on an irrevocable permit. If objections and appeals are lodged against the permit, it can take a long time before the permit becomes irrevocable, causing the project to stagnate. There is a possibility that (financing) agreements are linked to a specific term and that the project runs out of time. It is also possible for economic conditions to change over time.

For this reason, the Administrative Jurisdiction Division (the highest general administrative court) has decided to prioritise housing construction cases over other environmental law cases until at least the summer of 2026, as set out under 1.2 Main Market Trends and Deals.

Citizen Participation

In the case of government decisions, a form of citizen participation is often applied in advance to support the decision-making process. Municipalities engage in citizen participation when drawing up or amending a zoning plan.

As stated under 2.7 Rights of Third Parties, an initiator of a project can involve local residents and give them a say prior to applying for a permit. This allows any objections to be taken into account as much as possible in advance.

Housing Projects

In addition to the legal requirements for a project, there are a number of other relevant topics in relation to housing.

The Dutch government is committed to the realisation of affordable housing for low- and middle-income households. At a national level, a standard applies that 30% of all housing construction consist of social (rental) housing and that two thirds consist of mid-market rental housing and affordable owner-occupied housing. This applies to new construction projects as well as to transformation projects. These standards must be met in developing housing projects.

Government subsidies for housing construction are always aimed at ensuring that affordable housing is built in the short term. One common requirement is therefore that construction commence in the short term.

In addition, parking is a relevant topic in housing projects. The parking needs of new homes are often met by a built parking facility, sometimes in combination with other transport and mobility solutions, such as facilitating car-sharing systems.

As mentioned under 2.8 Land Use Agreements, it follows from the Didam case law that generally the municipality must allow competition between candidates when selling land, unless it can be assumed on the basis of objective, verifiable and reasonable criteria that there are no other potential candidates. In that case, the intention to sell must be published in advance, with the government body having to substantiate why there is only one serious candidate for the land.

If there are several candidates, the buyer must be selected on the basis of objective, verifiable and reasonable criteria.

State Aid

In land transactions with the government or in PPP projects, it is important to check whether any advantage might amount to unlawful state aid.

If land is sold below market value or if incentives are granted without proper justifications, this may constitute a breach of EU state-aid rules. Pricing and incentives have to be market-compliant or properly justified and documented.

Enforcement

If environmental legislation is not complied with, the municipality can use enforcement instruments. The municipality can do this on its own initiative if an inspection reveals that a violation has occurred.

Besides this, third parties can submit an enforcement request; the municipality has to decide on such request. If there is a violation, the municipality is obliged to enforce the law.

If construction does not comply with the permit or if the actual use of the land is not in accordance with the environmental plan, the municipality may take enforcement action.

Enforcement of agreements

If private law agreements are violated, the municipality may also initiate proceedings. Since these are private law agreements, the civil court has jurisdiction and not the administrative court. Penalty clauses are also often included. This allows the municipality to enforce the ceasing of any use that violates the leasehold conditions.

There are a number of enforcement instruments that the municipality can apply:

• an order subject to an incremental penalty may be imposed, whereby a reasonable grace period is granted within which the infringement must be terminated – after which, payment of the penalty will be due;
• an order subject to coercive administrative action may also be imposed, whereby the municipality itself will terminate the infringement after the grace period has expired;
• there is also the possibility of imposing an administrative fine; and
• if a violation occurs during construction, the municipality may immediately halt the construction.

Screening

When assessing a permit application, the government body checks, on the basis of the Public Administration Probity Screening Act (Bibob), whether there is a risk that a permit will be misused or that the government will facilitate criminal activities.

In the Netherlands, there are no additional requirements on planning and zoning in terms of registrations or otherwise. There are also no other political considerations to take into account.

Government Information is Public

Under the Open Government Act (Woo), all government information, including information shared with the government by private parties, can be made public.

Zoning plans, and any amendments thereto, are published and accessible to everyone. Government bodies must also publish their intention to sell land; see 5.1 Enforcement Authority.

This also applies to all information that is shared with government bodies by private parties, such as emails, letters, draft-agreements, information on negotiations and so on. Anyone can request disclosure.

There are a few exceptions; for example, commercially sensitive data is redacted. These exceptions are limited.