Published on: 2025-11-13

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Intelligence Report: Nationale veiligheidsrisico’s in greenfieldinvesteringen – Rand.org

1. BLUF (Bottom Line Up Front)

The strategic judgment is that greenfield investments in the Netherlands pose significant national security risks, particularly concerning the continuity of vital processes and strategic dependency. The most supported hypothesis is that enhancing the current investment screening framework to include greenfield investments will mitigate these risks. Confidence level: Moderate. Recommended action includes expanding the VIFO Act to comprehensively cover greenfield investments and aligning with EU standards to ensure consistency and prevent regulatory gaps.

2. Competing Hypotheses

Hypothesis 1: Greenfield investments pose a similar level of national security risk as brownfield investments, necessitating the extension of current regulatory frameworks to include them comprehensively.

Hypothesis 2: Greenfield investments pose a unique set of risks that are distinct from brownfield investments, requiring sector-specific legislation to address vulnerabilities in critical infrastructure areas.

Hypothesis 1 is more likely because the analysis indicates that greenfield investments affect vital processes and increase strategic dependency, similar to brownfield investments. The comparative analysis with other European countries supports the need for a unified approach rather than sector-specific legislation.

3. Key Assumptions and Red Flags

Assumptions include the belief that the current regulatory framework is insufficient to address the specific risks posed by greenfield investments. A red flag is the potential for regulatory gaps if the EU standards are not aligned, leading to inconsistent application across member states. There is a risk of bias in assuming that the Dutch context can directly adopt strategies from other European countries without adaptation.

4. Implications and Strategic Risks

The primary strategic risks include the potential for foreign entities to exploit regulatory discrepancies, leading to increased strategic dependency and vulnerability in critical sectors such as energy and telecommunications. There is a risk of cascading threats in the form of economic leverage by foreign powers, cyber vulnerabilities through technology transfer, and political influence through strategic dependencies.

5. Recommendations and Outlook

• Expand the VIFO Act to include greenfield investments comprehensively, ensuring consistent application across all sectors.
• Align Dutch investment screening mechanisms with EU standards to prevent regulatory gaps and ensure fair competition.
• Enhance international cooperation and data sharing among EU member states to map vulnerable sectors and harmonize national approaches.
• Best-case scenario: Effective regulation mitigates national security risks while maintaining a favorable investment climate.
• Worst-case scenario: Inadequate regulation leads to increased foreign influence and strategic vulnerabilities.
• Most-likely scenario: Gradual improvement in regulatory frameworks with ongoing challenges in balancing security and investment attractiveness.

6. Key Individuals and Entities

No specific individuals are mentioned. Key entities include the Dutch government, EU regulatory bodies, and foreign investors.

7. Thematic Tags

National Security Threats

Structured Analytic Techniques Applied

• Cognitive Bias Stress Test: Expose and correct potential biases in assessments through red-teaming and structured challenge.
• Bayesian Scenario Modeling: Use probabilistic forecasting for conflict trajectories or escalation likelihood.
• Network Influence Mapping: Map relationships between state and non-state actors for impact estimation.

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