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Bibob Investigation

The Bibob Act (Public Administration Probity Screening Act) is an important instrument for governments to prevent inadvertently facilitating criminal activities. The aim is to prevent the misuse of permits, subsidies, tenders, or transactions with the government.

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When is a Bibob investigation conducted?

A Bibob investigation takes place for applications regarding:

  • Permits (for example, hospitality, gambling, environmental permits)
  • Subsidies
  • Government contracts
  • Real estate transactions involving the government

Who conducts the Bibob investigation?

The investigation can be conducted by the municipality or the administrative body itself, or by the National Bibob Bureau (LBB). The National Bibob Bureau has extensive powers to map integrity risks and assist administrative bodies with risk assessment.

Application and Questionnaire

Questionnaire and Application

The procedure begins with completing a Bibob questionnaire. This form requests extensive information on topics such as:

  1. Company structure and control
  2. Financing of the enterprise
  3. Business relationships and business partnerships
  4. Criminal records


Failure to complete the Bibob questionnaire fully or correctly can lead to refusal or withdrawal of a permit. We assist our clients in providing this information correctly.

Documentation and substantiation

When submitting the form, supporting documents must be provided. These may include:

  1. Extracts from the Trade Register
  2. Annual accounts, profit and loss statements
  3. Proof of ownership, contracts, and financing documents
  4. Organizational chart and company structure

Integrity assessment

The administrative body assesses whether there is a serious risk that the permit, transaction, or subsidy will be misused for criminal purposes. The Bibob investigation thus remains a risk assessment. Based on this risk assessment, the administrative body decides whether to refuse or withdraw a permit, for example. This integrity assessment is based on the following types of information:

  1. Criminal & Administrative data such as convictions or administrative fines or, for example, orders subject to penalty payments
  2. The analysis of the structure where, for example, capital provision or control is decisive.

After the advice on the risk, a decision by the administrative body follows

This forms the ‘final piece’ of the Bibob investigation. The decision explains why the administrative body has made a decision based on the advice to, for example, refuse or withdraw the permit. This decision is subject to objection and appeal.

Advice from the National Bibob Bureau

If the Administrative Body has requested advice from the National Bibob Bureau, the LBB will provide advice to the Administrative Body. In practice, the advice is often followed by the Administrative Body. The LBB thus advises on the risk that the requested permit may be misused. The LBB then determines the degree of risk of misuse. The following degrees of risk are possible:

  • No risk
  • Lesser degree of risk
  • Serious risk

This forms the ‘final piece’ of the Bibob investigation. The decision explains why the administrative body has made a decision based on the advice to, for example, refuse or withdraw the permit. This decision is subject to objection and appeal.