This study analyses national security risks linked to greenfield and brownfield investments in the Netherlands, drawing lessons from across Europe. It reviews regulatory frameworks, key risks, and policy options such as extending the Vifo Act or sector-specific laws, aiming to balance security with a favourable investment climate and alignment with EU standards to prevent exploitation of regulatory discrepancies.

Nationale veiligheidsrisico's in greenfieldinvesteringen: Lessen voor investeringstoetsing in Nederland

[National Security risks for greenfield investments: Lessons for investment review in the Netherlands]

Sean Flanagan, Judith Huismans, Francesca Ghiretti

ResearchPublished Nov 13, 2025

Cover: Nationale veiligheidsrisico's in greenfieldinvesteringen: Lessen voor investeringstoetsing in Nederland
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Note: This report is in Dutch. An English-language summary is available.

This report examines national security risks associated with greenfield investments — a form of foreign direct investment (FDI) whereby a company establishes new operations from the ground up — compared with brownfield investments. The study explores how these risks manifest in the Dutch context and draws lessons from several European countries, including the United Kingdom, Germany, France, Sweden, the Czech Republic, Spain and Greece. The analysis follows the Dutch investment review framework, focusing on three main risk categories: the continuity of vital processes, the leakage of critical knowledge or technology, and the creation of strategic dependencies. The findings indicate that greenfield investments can pose similar threats to those of brownfield investments, particularly with respect to vital process continuity and strategic dependencies. Policy options considered include extending the current Vifo Act or introducing sector‑specific legislation to enhance investment screening in the Netherlands. Finally, the report explores how the need for national security protection can be balanced with maintaining a favourable investment climate. Alignment with European Union standards is seen as essential to avoid regulatory gaps and to ensure fair competition within the Single Market. The policy recommendations emphasise international cooperation, harmonisation of national approaches and consideration of sectoral conditions when expanding screening mechanisms.

Key Findings

Risk characteristics

  • Greenfield investments can present substantial national security risks, particularly affecting the continuity of vital processes and increasing strategic dependencies. The transfer of sensitive knowledge and technology appears less pronounced in greenfield investment cases, although it cannot be ruled out entirely.

International comparison

  • Comparative analysis across several European states indicates differing approaches to addressing security threats arising from greenfield investments. Most countries apply similar screening processes for greenfield and brownfield investments, typically focusing on critical sectors such as energy, telecommunications and defence. Alignment with European Union level standards assists in managing cross border investment flows and prevents inconsistencies in regulatory application.

Policy considerations

  • In the Dutch context, there are opportunities to strengthen investment review mechanisms. Extending the Vifo Act to encompass greenfield investments comprehensively would offer greater transparency and consistency. Alternatively, sector specific legislation could help capture high risk investments in sensitive infrastructure areas. The analysis highlights the importance of maintaining a careful balance between safeguarding national security interests and preserving an attractive environment for legitimate foreign investment.

Recommendations

  • Strengthen cooperation among EU Member States to share data and map sectors most vulnerable to national security risks arising from greenfield investments.
  • Align Dutch policy on greenfield investments closely with EU standards to prevent exploitation of regulatory discrepancies within the Single Market.
  • Extend the Vifo Act to include clear greenfield investment review provisions, ensuring transparency, sector delineation and reduced administrative burden. Such an expansion would bolster national resilience while maintaining competitiveness in attracting foreign investment by balancing security requirements with economic interests.

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Flanagan, Sean, Judith Huismans, and Francesca Ghiretti, Nationale veiligheidsrisico's in greenfieldinvesteringen: Lessen voor investeringstoetsing in Nederland: [National Security risks for greenfield investments: Lessons for investment review in the Netherlands]. Santa Monica, CA: RAND Corporation, 2025. https://www.rand.org/pubs/research_reports/RRA4191-1.html.
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The research described in this report was prepared for the Dutch Ministry of Economic Affairs and conducted by RAND Europe.

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