Ecorys evaluates the Dutch Implementation Act of the EU Regulation on Terrorist Content Online

Ecorys continues to contribute to combating terrorist content online.

In the EU, online platforms are increasingly being misused by various types of extremist groups to spread their ideologies, recruit members, prepare terrorist attacks, and raise funds, with negative consequences for the security in Europe. To address this threat, Regulation (EU) 2021/784 on combating the spread of terrorist content online entered into force in 2022. In the Netherlands, this has been translated into the Terrorist Online Content Implementation Act (TOI) to enable faster identification and removal of terrorist material online.

On behalf of the Research and Data Centre (WODC), Ecorys has carried out an evaluation of the effectiveness and efficiency of the TOI Implementation Act. The study examined how the legislation operates in practice, the governance structure, and whether an appropriate balance has been struck between tackling terrorist content and safeguarding the rights of hosting providers, online platforms, and their users. 

The study’s key findings include: 

• The TOI Implementation Act is largely working as intended, and the competent authority has successfully established an operational process for identifying, assessing, and removing terrorist content online.
• Approximately 330 removal orders were issued in 2024 and 2025. Hosting service providers complied with virtually all of these orders within the legally required one-hour timeframe. 
• Identifying terrorist content online remains challenging, as detection still relies heavily on manual processes. Moreover, a substantial share of harmful online content falls outside the legal definition of terrorist content, limiting the scope of intervention within the remit of this legal framework.
• Practical experience with parts of the legal framework remains limited. To date, no objections or appeals have been filed, no exposure decisions have been issued, and the dispute resolution procedure has not yet been used. 
• No evidence was found of systematic infringements of fundamental rights or the excessive removal of lawful content. 
• While the legislation is effective in removing identified terrorist content online, its wider impact on the overall availability of terrorist content online is difficult to measure. 

The full report (in Dutch as well as the English summary are available here: link

Would you like to learn more about the study and its findings? Join our webinar on 5 November from 15:30-17:00 CET.  More information and registration details can be found via the following link: 

https://eu.mar.medallia.com/s/100022778?d=l&h=C0BE19E45264E04&l=en

For further information about the study, please contact Gabriëlle Op ‘t Hoog or Sabine Hellemons