BIO2 and AI procurement in the Netherlands

Start with the current baseline

BIO2 is the Dutch government's information security baseline. It is centred on risk management and organisational measures as well as technical controls. The official BIO website identifies BIO2 v1.3 as the current baseline.

Older material may refer to BIO1 protection levels such as BBN1, BBN2 and BBN3. Do not treat those labels as a current, universal product certification or as a shortcut for approving an AI supplier. Confirm the framework and transition arrangements that apply to the organisation.

Check the organisation's obligations

The official BIO2 and Cybersecurity Act update explains that the Cyberbeveiligingswet entered into force on 15 August 2026. For organisations within its scope, parts of BIO2 are anchored in the relevant implementing rules. Scope and exceptions matter; not every control has the same legal basis.

Ask the organisation's security owner to record the applicable requirements and residual risks for the intended workflow. BIO2 does not remove separate privacy, AI Act or sector-specific obligations.

Five questions for an AI procurement review

Information: which records are necessary, how sensitive are they and who owns them?
Access: which users, tools, support teams and subprocessors can reach those records?
Operation: where are processing, logs and backups handled, and how are incidents managed?
Control: which actions require approval, and how can access be revoked or work stopped?
Evidence: which tests, contracts, operating procedures and records demonstrate that the measures work?

European hosting can help meet a chosen boundary. It does not by itself prove BIO2 conformity or rule out every foreign access risk. Assess the contract, service configuration and operating model together.

Put the scope in writing

For a NeuroCluster engagement, agree the workflow, approved sources, access boundaries and responsibilities before connecting live records. Start with a limited evaluation and review the evidence with the public organisation's security and privacy teams.

Sources and review date

Checked on 15 October 2026. See BIO2 v1.3 in the Staatscourant and the official guidance linked above. No BIO certification of NeuroCluster is asserted on this page.