Dutch Algoritmeregister

The Algoritmeregister (algoritmes.overheid.nl) is the Dutch national transparency register for algorithms used by government bodies, built on the Algoritmekader metadata standard. Publication has been Dutch cabinet policy since 2022 for "impactful" algorithms, and is moving toward a statutory footing in step with the EU AI Act's high-risk obligations and its own EU-level database for high-risk systems used by public authorities (Art. 49(3)) — the exact legal-mandate timeline is still evolving, so treat this page as describing the metadata standard and Hermiq's support for it, not a final statement of when publication becomes legally required for your organisation.

This page doesn't map to numbered articles the way the AI Act and GDPR pages do — the Algoritmekader is a metadata standard, not a statute. Instead, each section below is one of the standard's required publication fields.

How it fits together

Hermiq's AiFeature object can carry the Algoritmekader metadata as an optional field group — optional at cataloguing time (design-time governance doesn't require it), mandatory at publish time. Publication itself is delegated to OpenCatalogi's existing publication pipeline rather than Hermiq opening its own connection to algoritmes.overheid.nl — when OpenCatalogi isn't installed, publishing is simply unavailable and the feature stays fully governable internally.

The publish gate

Hermiq refuses to publish an AiFeature unless all of the following hold, and tells you exactly which one failed rather than publishing a partial entry:

• riskCategory is high — minimal/limited features are out of scope for the national register and publishing them is refused.
• lifecycle is enabled.
• The DPO acknowledgement is recorded (the same gate described under EU AI Act — Art. 9).
• Every mandatory field below is present.

Scope mismatch: "impactful" is broader than "high-risk"

Dutch cabinet policy asks for impactful algorithms to be published — a broader, policy-defined category than the AI Act's Annex III high-risk tier that Hermiq's riskCategory field mirrors. A feature you've honestly classified limited under the AI Act could still be "impactful" enough under Dutch policy to warrant publication, and Hermiq's publish gate will refuse it (riskCategory isn't high) with no way around that from the UI. If a feature seems impactful but isn't AI Act high-risk, don't rely on the publish gate — check with your DPO whether it should be published anyway, outside Hermiq's automated path.

The metadata fields

Field	Captures
doel	The purpose of the algorithm
wettelijkeGrondslag	Its legal basis
impacttoetsen	Impact assessments performed (IAMA / DPIA / FRAIA) with references
dataBronnen	Data sources / categories used
menselijkeTussenkomst	A description of the human-oversight arrangement
verantwoordelijke	The responsible organisation and contact
publicatiecategorie	The Algoritmekader publication category

How Hermiq supports it. Every field above is a real field on the AiFeature schema, and the publish gate mechanically enforces that they're all present before anything reaches the register — you cannot publish an entry with a placeholder or a missing legal basis.

Your responsibility. Hermiq checks that the fields are filled in, not that what you wrote is accurate — wettelijkeGrondslag naming the wrong statute, or menselijkeTussenkomst describing oversight that doesn't actually happen in practice, will pass the gate and still be wrong. The content of every field is yours to get right.

Publication state

An AiFeature's algoritmeregisterStatus is niet-gepubliceerd (not published) until you explicitly publish it, at which point it becomes gepubliceerd and stores the register's external reference (algoritmeregisterRef); withdrawing sets it to ingetrokken and requests unpublication.

Your responsibility. Deciding to publish — and keeping the entry current as the underlying agent changes — is a step your organisation takes. An accurate but stale register entry is still a compliance gap; nothing re-publishes automatically when you change how an agent works.

Where to manage this

The Algoritmekader fields, the publish/withdraw actions, and each feature's algoritmeregisterStatus all live on the in-app Settings page's Algorithm register tab, alongside the rest of AiFeature governance — there is no separate page for national-register publication.