Martijn Ridderbos and Kari Spijker of the ACM, the Netherlands Authority for Consumers and Markets (ACM), use a wide range of algorithms. Thanks in part to the national Algorithm Register, the organisation has gained a clearer picture of which algorithms it uses and for what purpose.
Currently, 15 of the ACM’s algorithms are listed in the Algorithm Register. This makes the authority a frontrunner among Dutch regulators. But this is just the beginning. Martijn Ridderbos, board member, and Kari Spijker, algorithm governance specialist at the ACM’s Taskforce for Data and Algorithms (TDA), expect this number to grow significantly in the near future.
Greater control over your own algorithms
“We have been working with the national Algorithm Register for almost 2 years now,” explains Spijker. “It has helped us gain a clearer understanding of the algorithms we use throughout the organisation. By registering our algorithms, we were compelled to ask ourselves: what do we actually define as an algorithm, and what falls under that definition?”
According to Spijker, the register acts as a tool to provide an overview. “The ACM consists of many different directorates, each overseeing markets in its own way. The Algorithm Register prompted us to update and expand our internal register. Which algorithms and AI systems do we use? And are they up to standard? The national Algorithm Register has really helped us work more responsibly and transparently as a regulator.”
Core values
Ridderbos agrees: “Our mission is to ensure markets work well for people and businesses, now and in the future. We uphold three core values: independence, openness, and ingenuity. The Algorithm Register is particularly important from the perspective of openness. We believe it is essential to be public and transparent about what we do. That’s why we share our most important algorithms in a register that is accessible to everyone.”
Balancing openness and oversight
However important transparency is, the ACM cannot disclose all its algorithms in full, as this could compromise its oversight role. “For some algorithms, you don’t want everyone to know exactly how they work,” says Ridderbos. “That could undermine our oversight. It’s a dilemma, because we want to be as open as possible.”
As a result, some algorithms are only described in broad terms. “We rephrase any overly sensitive information,” Spijker clarifies. “For example, we describe how an algorithm works technically, without revealing details about sources or specific methods.”
Ridderbos emphasises that this is not an arbitrary choice. “We do not withhold information that the public should know based on our criteria. But we do make careful decisions to avoid compromising our oversight tasks.”
Maximising transparency
The Taskforce for Data and Algorithms is increasingly developing its own algorithms to gain deeper insights into markets and market behaviour, and to detect market problems. “We expect more registrations to follow in this area,” says Ridderbos. “Developments are moving rapidly, both among the parties we oversee and within our own organisation. We are exploring how to use AI to enrich our work and to effectively oversee markets where data and AI play an ever-growing role. This requires maximum transparency where possible and careful judgment. The more we use AI and algorithms in the Netherlands, the greater the need for openness, especially for public service providers. We hope other organisations will follow our lead. This contributes to a level playing field.”
Towards data-driven oversight
As the use of data and algorithms has increased, the ACM established the Taskforce for Data and Algorithms in early 2023. “We are now transforming this into a full directorate,” says Ridderbos. “Data-driven oversight is an essential part of our role.” Spijker sees a broader societal responsibility. “Digitalisation is profoundly changing society, and our digital tools and capabilities must keep pace. Regulators have a duty to guide these developments and ensure a safe and reliable online environment.” To this end, the ACM, together with other regulators such as the Dutch Healthcare Authority (NZA) and the Authority for the Financial Markets (AFM), is training data specialists through a traineeship focused on the use of data and algorithms in regulatory practice.
Get involved
Ridderbos and Spijker also encourage other government organisations to share their algorithms via the Algorithm Register: “Don’t get stuck on definitions for too long,” advises Spijker. “Just start by taking stock and sharing. The Algorithm Register is not only an obligation, but also a source of inspiration. It shows what you are already doing—and you can be proud of that.”



