For entrepreneurs and directors facing a Bibob investigation in connection with a permit, subsidy, real estate transaction, or tender.
The Bibob Act empowers the government to investigate your integrity before granting a permit, subsidy, or contract — and to refuse or revoke it in the event of a serious risk of abuse. A Bibob investigation often feels like an accusation, even though you have done nothing wrong. Our lawyers and in-house counsel assist both international corporations and the local entrepreneur: from completing the questionnaire to submitting a statement of views and filing an appeal.
Lawyers and in-house counsel Bibob specialists in one team.Practical specialist legal assistance for entrepreneurs.
Active for SMEs and corporates — from large corporations to the baker on the corner.Practical specialist legal assistance for entrepreneurs.
Key themes: questionnaire, Bibob assessment, statement of views, and revocation.Practical specialist legal assistance for entrepreneurs.
Specialist Bibob advice from €155 per hour excl. VAT.Clarity regarding the process, approach, and next steps.
We worked for, among others:
We worked for, among others:
What is the Bibob Act?
Bibob stands for the Act on the Promotion of Integrity Assessments by Public Administration. This Act, in force since 2003 and expanded several times since, provides administrative bodies with the instrument to investigate whether their decisions unintentionally facilitate criminal activities. The government aims to prevent a permit, subsidy, real estate transaction, or public contract from being used to exploit benefits derived from criminal offenses or to commit criminal offenses. A Bibob investigation is therefore not a criminal prosecution, but an administrative integrity test.
Our lawyers and in-house counsel assist both international corporations and the local entrepreneur — from the hospitality business applying for an operating license to the group bidding on a tender.
When does the Bibob Act apply?
An administrative body can apply the Bibob assessment to decisions such as hospitality and alcohol licenses, operating licenses, building and environmental permits, Opium Act exemptions, and gambling licenses. Since 2013, the law also applies to real estate transactions in which the government is a party, and the assessment can be used for subsidies and public contracts (tenders) in sectors including construction, environment, and ICT. If you have doubts about a permit or contract, it is advisable to consult with our administrative and environmental law .
The Bibob questionnaire and the own investigation
The Bibob procedure often begins with an extensive questionnaire regarding the financing, control, and corporate structure of your company. The administrative body first conducts its own investigation (its own investigation) based on your answers and public sources. You are obliged to provide the requested information; if you fail to do so or provide incomplete information, the permit may be refused or revoked on that ground alone (Article 4 of the Bibob Act). We help you complete the form correctly and fully and submit the correct documents as early as possible — prevention is better than cure in this case.
The advice of the National Bibob Office
If the administrative body is unable to reach a decision itself, it may request advice from the National Bibob Office (LBB). The LBB has access to confidential sources, such as police and judicial records, and assesses whether a risk exists. In principle, the office issues advice within eight weeks, with a possible extension of four weeks. The advice is not binding: the administrative body makes the decision itself and must justify it independently. We verify whether the advice has been carefully prepared and whether it genuinely supports the conclusion.
The degree of risk and the business partnership
The core of the assessment is the degree of risk: a serious degree of risk can lead to refusal or revocation, while a lesser degree of risk can lead to conditions being attached to the permit (Article 3 of the Bibob Act). In this regard, not only your own conduct counts, but also that of persons in a business partnership — a financier, a supplier, or a co-shareholder. We map out which relationships the administrative body holds against you and whether that connection holds up legally.
The viewpoint: your chance to respond
Before the administrative body refuses or revokes a permit, it must give you the opportunity to present your views (Article 4:8 of the General Administrative Law Act). This is a crucial moment: here you refute incorrect assumptions, place facts in the correct context, and, if necessary, prevent a negative decision. Our lawyers and in-house counsel draft a substantiated statement of views together with you and, where possible, request access to the Bibob advice.
Objection, appeal and preliminary relief
If the procedure nevertheless leads to refusal or revocation, an objection to the administrative body is available, followed by an appeal to the administrative court (pursuant to the General Administrative Law Act). Because a revocation can immediately halt your business, we request a preliminary injunction where necessary to suspend the decision. While a lawyer is not always mandatory for legal proceedings, the complexity of a Bibob file almost always makes specialized assistance advisable.
Bibob for SMEs and corporations
The top end of the market often focuses solely on large cases. We do not: our mixed team of lawyers and in-house counsel assists both international corporations with tenders and hospitality entrepreneurs or the baker on the corner with operating licenses. Accessible and practical, yet legally sharp — because with Bibob, the survival of your business is often at stake.
Does it concern a real estate transaction or a tender?
If the Bibob investigation is involved in a real estate deal or a public contract, we collaborate with our specialists in real estate law and procurement law. If it affects control or financing within your company, our corporate law the case. This ensures you remain aligned on all fronts.
What we help with
From the first letter from the administrative body to the appeal to the court — our lawyers and legal experts guide you through every phase of the Bibob procedure.
Filling out the Bibob questionnaire correctly and completely
Guidance with the administrative body's own investigation
Assessment of the advice from the National Bibob Office
Drafting a substantiated opinion (Article 4:8 of the General Administrative Law Act)
Defense against refusal or revocation of your permit
Objection and appeal to the administrative court
Interim measure to suspend a revocation
Advice on your business partnership and financing structure
Preventive Bibob advice before an application or transaction
When do you engage this team?
In a Bibob procedure, deadlines are short and every response carries significant weight. The sooner you involve us, the more options you retain. If you recognize any of these situations, seeking advice is advisable.
You will receive a Bibob questionnaire with your application
In a Bibob file, your starting position determines the outcome. Before we respond, we map out the questionnaire, our own investigation, and — where possible — the Bibob advice, and determine which facts are being held against you. In this way, we choose the route that best serves your interests: a full explanation, a substantiated view, or legal proceedings, rather than a hasty initial response that harms you later.
Our approach
From questionnaire to solution in four steps.
1
Intake
We discuss your company, the application, and the received form or decision, and review the deadlines.
2
Analysis
We assess our own investigation and the Bibob advice, and map out opportunities and risks.
3
Strategy
We choose the route — explanation, statement of views, or procedure — and the involvement of a lawyer or legal expert.
4
Execution
We handle everything: from filling out the form to the statement of views and the appeal to the administrative court.
Mr. Jaime BoogaersCorporate Law · Lawyer
In a legal dispute, it is not just about being right. It is also about evidence, timing, negotiating position, and the business consequences of every step.
Specialists within Bibob
Our specialists combine legal analysis with experience in cases for entrepreneurs, directors, and organizations.
All our legal experts and lawyers possess broad knowledge of the Bibob Act. In addition, they have specialized in one or more areas of focus within administrative law. We have organized several areas of focus into various practice groups. Each lawyer is part of one or more practice groups based on his or her specialism(s). Clients can go directly to the appropriate practice group for each case. Here, they are assisted by the lawyer or legal expert most suitable for the case. Where necessary, we draw upon the expertise and experience of our specialist colleagues from other practice groups.
Frequently asked questions about Bibob
The questions entrepreneurs ask us most often about a Bibob investigation.
What does it mean if I receive a Bibob questionnaire?
This means that the administrative body investigates your integrity before deciding on your permit, subsidy, or contract. This is not an accusation and not a criminal case, but an administrative review. You are, however, obliged to provide the requested information; in the event of incomplete answers, the application may be refused on that ground (Article 4 of the Bibob Act).
Can my permit be revoked by Bibob?
Yes. In the event of a serious risk that the permit will be abused, the administrative body may refuse or revoke it; in the event of a lesser risk, it may attach conditions to the permit (Article 3 of the Bibob Act). Before this happens, you must be given the opportunity to present your views (Article 4:8 of the General Administrative Law Act).
What is the National Bibob Office?
The National Bibob Office (LBB) is an independent agency that advises the administrative body upon request. It has access to confidential sources, such as police and judicial data. The advice is not binding: the administrative body makes the decision itself and must independently justify that decision.
Will I be held accountable by my business partners?
That is possible. The assessment also considers individuals within your business partnership, such as a financier, supplier, or co-shareholder. We assess whether that relationship holds up legally and whether the administrative body is justified in taking it into account.
Do I need a lawyer or a legal expert?
That depends on your situation. For completing the form, advice, and drafting a statement of opinion, an in-house counsel is often sufficient. For proceedings before the administrative court, assistance from a lawyer is advisable and sometimes mandatory. We have both in-house and will determine together with you what is most suitable.
Can I prevent a Bibob investigation?
The governing body decides for itself whether to apply the assessment, so you cannot completely avoid it. However, you can prepare thoroughly: a clear financing structure, transparent governance, and a fully completed form reduce the likelihood of questions and delays. We proactively identify these risks.
Discuss your situation with a Bibob specialist.Our Bibob lawyers and legal experts help both large companies and small business owners move forward. Schedule a meeting and know where you stand and what the best course of action is within a single session.
