Are you a citizen of the EU, the EEA or Switzerland and wish to take up residence in the Netherlands to practise your profession as a maritime pilot on a permanent basis?
Are you a citizen of the EU, the EEA or Switzerland and wish to provide pilotage services in the Netherlands on a temporary and occasional basis?
Recognition pilot
Are you a citizen of the EU, the EEA or Switzerland and wish to take up residence in the Netherlands to practise your profession as a maritime pilot on a permanent basis?
1. General
1.1 Freedom of establishment
The EU facilitates freedom of establishment and free movement of services. If you are a resident of another country in the EU, the EEA or Switzerland and you work or have worked there as a maritime pilot, you can take up residence in the Netherlands and, subject to conditions, practise your profession as a maritime pilot on a permanent basis. If you intend to do so, you must first submit an application for recognition of your professional qualifications/diplomas to the Algemene Raad van de Nederlandse Loodsencorporatie (the competent authority). On the basis of this application, your professional qualifications/diplomas will be compared with the professional qualifications/diplomas of the Dutch Registered Pilot. On the basis of this comparison, the competent authority may state that compensation measures are necessary and you may be given the opportunity to bridge the differences by completing an adaptation period and/or taking an aptitude test. You can only start working in the profession after formal authorisation from the competent authority.
1.2. Professional qualifications
In order to practise your profession in another EU country, mutual agreements have been made within the EU on the standardisation of education and recognition of diplomas and certificates. These agreements are laid down in European directives (Directive 2005/36/EC and Directive 2013/55/EU) for the recognition of EU professional qualifications. These EU directives regulate the access to and the exercise of a regulated profession in the Netherlands for citizens from other countries in the EU, the EEA or Switzerland. In the Netherlands, these directives have been incorporated into the Algemene wet erkenning EU-beroepskwalificaties (Dutch Recognition of Professional EU Qualifications Act).
1.3. Regulated profession
In the Dutch Regulation Establishing the List of Regulated Professions, adopted by the Dutch Minister of Education, Culture and Science, the profession of Registered Pilot (registerloods) has been designated as a regulated profession and has been included in the EU Database of Regulated Professions. A profession is regulated if, according to the law, you need a special diploma, have to take certain exams and/or register with a professional organisation before you can exercise the profession.
The professional qualifications/diplomas for the profession of the Dutch Registered Pilot are laid down in the Dutch Loodsenwet (Pilots’ Act), the Dutch Besluit opleidingen en bevoegdheden nautische beroepsbeoefenaren (Decree on Training and Qualification of Nautical Professionals) and in the Dutch Regeling opleidingen en bevoegdheden nautische beroepsbeoefenaren (Regulation on Training and Qualification of Nautical Professionals).
1.4. Competent authority
Each regulated profession has a competent authority that checks whether you meet the requirements for the profession. The competent authority for the profession of Registered Pilot is the Algemene Raad of the Nederlandse Loodsencorporatie.
1.5. Application for recognition of professional qualifications
If you wish to take up residence in the Netherlands as a migrant professional to practise the profession of Registered Pilot on a permanent basis, you first have to apply for recognition of your professional qualifications/diplomas. You can do this with the Algemene Raad of the Nederlandse Loodsencorporatie, which will assess your diploma, education and experience and compare them with the professional qualifications/diplomas of the Dutch Registered Pilot.
1.6. Regionale Loodsencorporaties
It is also important for you to know that the Dutch Registered Pilots work from one of the following four regions (Regionale Loodsencorporaties): Noord, Amsterdam-IJmond, Rotterdam-Rijnmond and Scheldemonden. In your application for recognition of professional qualifications you therefore also have to state in which region you wish practise your profession as a pilot on a permanent basis.
1.7. Regulated education and training
The Dutch Registered Pilots Education and Training Programme is a regulated training course according to the definition in Directive 2005/36/EC. Regulated education and training is any training specifically geared to the pursuit of a given profession and consists of a course of study the structure and level of which are laid down by law and which may be complemented, where appropriate, by professional training, probationary or professional practice, the structure and level of which are also determined by law.
1.8. Master in Maritime Piloting
The Dutch Registered Pilots Education and Training Programme is an accredited HBO (Higher Professional Education) Master’s Programme of more than 1 year. The requirement for entry to this Master’s Programme is a 4-year (Maritime) Bachelor’s Degree with mandatory practical experience. The Registered Pilots Education and Training Programme is provided by the Nederlandse Loodsencorporatie. The Nederlandse Loodsencorporatie is an educational institution recognized by the Dutch Ministry of Education, Culture and Science. The diploma entitles pilots to use the title of Master of Science.
1.9. Information about the Training and Education Programme
For detailed information on the Dutch Registered Pilots Education and Training Programme, please contact Stichting Opleiding en Deskundigheidsbevordering Registerloodsen (STODEL) via email: OTRMMP@loodswezen.nl.
2. Recognition
2.1. Recognition of professional qualifications/diplomas
The Algemene Raad of the Nederlandse Loodsencorporatie decides on the recognition of your professional qualifications/diplomas on the basis of the Dutch Recognition of Professional EU Qualifications Act (incorporating Directives 2005/36/EC and 2013/55/EU). This Act provides for five levels of professional qualification as a benchmarking instrument for EU professional qualifications.
2.2. Rules for the recognition of professional qualifications/diplomas from an EU country
- The professional qualifications/diplomas which you have obtained in your EU country and which are compulsory for the pilotage profession in your country will be recognised in the event of equivalence with a level of qualification referred to in the abovementioned Act.
§ If the pilotage profession is not a regulated profession in your country, your professional qualifications/diplomas obtained in your EU country will be recognised if they demonstrate that you have undergone education and training for the profession of a maritime pilot and if you have practised this profession full-time or part-time for at least 1 year over the past 10 years. The requirement of 1-year professional experience is not applicable in the case of professional qualifications/diplomas obtained through regulated education and training.
- Professional qualifications/diplomas will be recognised if they have been obtained in your EU country on the basis of education and training certified in your country as equivalent to the middle level of qualification referred to in the above-mentioned Act.
- Your professional qualifications/diplomas will not be recognised if they are four levels below that of the qualification level of the Dutch Registered Pilot.
2.3. Rules on the recognition of professional qualifications/diplomas from a third country
- Your professional qualifications/diplomas obtained in a third country will be recognised if you have practised the pilotage profession in an EU country for at least 3 years, and
- The EU country in question has recognised both your professional qualifications/diplomas and your professional experience.
3. Application for recognition of professional qualifications/diplomas
3.1. Documents required for your application for recognition of professional qualifications/diplomas
Your application for recognition of your professional qualifications/diplomas should be sent to the Algemene Raad of the Nederlandse Loodsencorporatie. On the basis of the Act and the Regulation on Training and Qualification of Nautical Professionals, you have to submit the following documents together with your application:
1. Your first name, surname and contact details.
- Copy of your passport or identity card, and
- If you are not a national of an EU country, a document showing that you are a family member of an EU citizen, or that you have a long-term residence permit or refugee status in an EU country, or that you have an EU work permit (‘blue card’) or other relevant evidence that you may be entitled to EU rights. You are advised to check this with the relevant national authorities.
3. Copy or copies of your diploma or diplomas (sometimes a certified translation is also required).
- Including proof of certificates of competence, other certificates, diplomas and professional experience.
4. Where appropriate, a document proving that you have practised your profession full-time or part-time for at least 1 year over the past 10 years (a certified translation may be required).
- Proof that you have not been temporarily or permanently prohibited from practising your profession and that you have no criminal record.
- Valid Seafarer Medical Certificate.
- Proof of financial ability.
- Proof of your professional liability insurance (insurance company, policy number).
4. Decision procedure
4.1. Procedure following submission of your application for recognition of professional qualifications/diplomas
After submitting your application, the following applies:
- You will be notified of the costs of the application procedure, including the costs for the issue of the decision and the organisation of an aptitude test and/or adaptation period.
- You will receive confirmation that your application has been received within one month. However, if there is a problem with your file, it may take up to 4 months before the Algemene Raad of the Nederlandse Loodsencorporatie will respond.
- When the Algemene Raad of the Nederlandse Loodsencorporatie confirms the receipt of your application, it may also request you to send additional information.
- The Algemene Raad of the Nederlandse Loodsencorporatie will decide on your application within three months. This period may be extended by one month.
- If your application is rejected, the Algemene Raad of the Nederlandse Loodsencorporatie will give reasons for the rejection.
- Sometimes the Algemene Raad of the Nederlandse Loodsencorporatie may decide that compensation measures are necessary before your qualifications can be recognised.
If it appears that your professional qualifications/diplomas are insufficiently equivalent to those of the Dutch Registered Pilot, the Algemene Raad of the Nederlandse Loodsencorporatie may impose compensation measures on the basis of the Dutch Recognition of Professional EU Qualifications Act. The final decision on the recognition of your professional qualifications/diplomas will then be postponed until you have met these additional conditions.
5. Compensation measures
5.1 Compensation measures in case of substantial differences
On the basis of your application for recognition of your professional qualifications/diplomas, the Algemene Raad of the Nederlandse Loodsencorporatie will determine the level of your professional qualifications/diplomas. In the event of substantial differences in content and level between your education and training and that of the Dutch Registered Pilot or, in the event of a difference in professional activities, the Algemene Raad of the Nederlandse Loodsencorporatie may impose compensation measures. The Algemene Raad will motivate its decision, making clear that these measures are taken on the basis of a careful comparison and are tailored to your situation.
5.2 Adaptation period and/or aptitude test
As far as compensation measures are concerned, you are offered the choice between an adaptation period and an aptitude test. However, if the difference in the level of qualification between your training and the training for the Dutch Registered Pilot is too great, or if your professional qualifications/diplomas were issued in a third country, both an adaptation period and an aptitude test are required. The Algemene Raad will motivate its decision, making clear that these measures are taken on the basis of a careful comparison and are tailored to your situation.
5.3 Adaptation period
The adaptation period will last a maximum of 3 years. When determining the adaptation period, the Algemene Raad of the Nederlandse Loodsencorporatie will first check whether the knowledge, skills and competences you have acquired in the context of your professional experience or in the context of lifelong learning can overcome the substantial differences in content and level (see point 5.1).
With regard to the adaptation period, the Algemene Raad of the Nederlandse Loodsencorporatie will inform you about the following:
- The areas of content or partial areas of content.
- The duration of the adaptation period.
- Any additional training that is part of the adaptation period.
- The manner in which the adaptation period is assessed.
5.4 Aptitude test
With regard to the aptitude test, the Algemene Raad of the Nederlandse Loodsencorporatie will establish the following:
- The areas of content or partial areas of content.
- The manner in which and the period within which the various components of the aptitude test will be taken.
- If you are required to take an aptitude test, the Algemene Raad of the Nederlandse Loodsencorporatie will give you the opportunity to take the test within six months of taking the decision (see point 4.1).
6. Decision
6.1 Decision on the application for recognition of professional qualifications/diplomas
- You will be notified of the approval of your application. You can only start working in the profession after formal permission from the Algemene Raad of the Nederlandse Loodsencorporatie.
- You will be notified of the rejection of your application. The Algemene Raad of the Nederlandse Loodsencorporatie will give reasons for the rejection.
§ The application for recognition of your professional qualification/diploma will be approved if you have successfully completed the adaptation period or the aptitude test and if you have paid the associated costs.
§ The application for recognition of your professional qualification/diploma will be rejected if you have not successfully completed the adaptation period or the aptitude test or if you have not paid the associated costs. The Algemene Raad of the Nederlandse Loodsencorporatie will give reasons for the rejection.
7. Dutch language
7.1 Knowledge of the Dutch language
You must have the necessary knowledge of the Dutch language required for the profession of Registered Pilot in the Netherlands.
8. Costs
8.1 Costs
- The costs related to the adaptation period are € 1,347 per day
- The costs related to the aptitude test are € 1,347 per day
9. Objection and appeal
9.1 Objection to the decision
If you disagree with the decision of the Algemene Raad of the Nederlandse Loodsencorporatie on the recognition of your professional qualifications, you can lodge a written objection within 6 weeks of the date of the decision. In that case, send a notice of objection to the Algemene Raad stating why you disagree with the decision. The notice of objection must at least contain your name, address and signature. The Algemene Raad of the Nederlandse Loodsencorporatie will consider your notice of objection and make a reconsidered decision.
9.2 Appeal against the decision on the objection
If you disagree with the reconsidered decision, you have the right to appeal to the Administrative law sector of the Rotterdam District Court. In the reconsidered decision you will find information on how to lodge a notice of appeal. An appeal against a Decision of the District Court can be lodged with the Administrative Jurisdiction Division of the Dutch Council of State, the highest court of appeal on this matter.
Recognition pilot
Are you a citizen of the EU, the EEA or Switzerland and wish to provide pilotage services in the Netherlands on a temporary and occasional basis?
1. General
1.1 Free movement of services
The EU facilitates freedom of establishment and free movement of services. If you are a resident of another country in the EU, the EEA or Switzerland and you work or have worked there as a maritime pilot, you can (subject to conditions) provide the services of a maritime pilot (as a service provider) in the Netherlands on a temporary and occasional basis. If you intend to do so, you must inform the Algemene Raad of the Nederlandse Loodsencorporatie (the competent authority) of this in advance by means of a written declaration. On the basis of this declaration, the Algemene Raad may decide to compare your professional qualifications/diplomas with those of the Dutch Registered Pilot. On the basis of this comparison, the competent authority can determine to what extent your professional qualifications differ from those of the Dutch Registered Pilot. On the basis of these differences, the Algemene Raad may require you take an aptitude test. You can only start working as a pilotage service provider after formal permission from the competent authority.
1.2. Professional qualifications
In order to practise your profession in another EU country, mutual agreements have been made within the EU on the standardisation of education and recognition of diplomas and certificates. These agreements are laid down in European directives (Directive 2005/36/EC and Directive 2013/55/EU) for the recognition of EU professional qualifications. These EU directives regulate the access to and the exercise of a regulated profession in the Netherlands for citizens from other countries in the EU, the EEA or Switzerland. In the Netherlands, these directives have been incorporated into the Algemene wet erkenning EU-beroepskwalificaties (Dutch Recognition of Professional EU Qualifications Act).
1.3. Regulated profession
In the Dutch Regulation Establishing the List of Regulated Professions, adopted by the Dutch Minister of Education, Culture and Science, the profession of Registered Pilot (registerloods) has been designated as a regulated profession and has been included in the EU Database of Regulated Professions. A profession is regulated if, according to the law, you need a special diploma, have to take certain exams and/or register with a professional organisation before you can exercise the profession.
The professional qualifications/diplomas for the profession of the Dutch Registered Pilot are laid down in the Dutch Loodsenwet (Pilots’ Act), the Dutch Besluit opleidingen en bevoegdheden nautische beroepsbeoefenaren (Decree on Training and Qualification of Nautical Professionals) and in the Dutch Regeling opleidingen en bevoegdheden nautische beroepsbeoefenaren (Regulation on Training and Qualification of Nautical Professionals).
1.4. Competent authority
Each regulated profession has a competent authority that checks whether you meet the requirements for the profession. The competent authority for the profession of Registered Pilot is the Algemene Raad of the Nederlandse Loodsencorporatie.
1.5. Declaration by the service provider (temporary and occasional provision of services)
If, as a migrant professional (service provider), you intend to provide the services of a maritime pilot in the Netherlands on a temporary and occasional basis, you must submit a written declaration of this intention on paper or in electronic format to the Algemene Raad of the Nederlandse Loodsencorporatie. This declaration must be renewed every year. The Algemene Raad of the Nederlandse Loodsencorporatie can decide to check your declaration against a number of criteria, including your diploma, education and experience and compare these with those of the Dutch Registered Pilot.
1.6. Regionale Loodsencorporaties
It is also important for you to know that the Dutch Registered Pilots work from one of the following four regions (Regionale Loodsencorporaties): Noord, Amsterdam-IJmond, Rotterdam-Rijnmond and Scheldemonden. In your declaration, therefore, you also have to state in which region you wish to provide the services of a maritime pilot on a temporary and occasional basis.
1.7. Regulated education and training
The Dutch Registered Pilots Education and Training Programme is a regulated training course according to the definition in Directive 2005/36/EC. Regulated education and training is any training specifically geared to the pursuit of a given profession and consists of a course of study the structure and level of which are laid down by law and which may be complemented, where appropriate, by professional training, probationary or professional practice, the structure and level of which are also determined by law.
1.8. Master in Maritime Piloting
The Dutch Registered Pilots Education and Training Programme is an accredited HBO (Higher Professional Education) Master’s Programme of more than 1 year. The requirement for entry to this Master’s Programme is a 4-year (Maritime) Bachelor’s Degree with mandatory practical experience. The Registered Pilots Education and Training Programme is provided by the Nederlandse Loodsencorporatie. The Nederlandse Loodsencorporatie is an educational institution recognized by the Dutch Ministry of Education, Culture and Science. The diploma entitles pilots to use the title of Master of Science.
1.9. Information about the Training and Education Programme
For detailed information on the Dutch Registered Pilots Education and Training Programme, please contact Stichting Opleiding en Deskundigheidsbevordering Registerloodsen (STODEL) via email: OTRMMP@loodswezen.nl.
2. Declaration by the service provider
2.1. Declaration by the service provider
If you intend to provide the services of a maritime pilot in the Netherlands on a temporary and occasional basis, you must notify the competent authority, i.e. the Algemene Raad of the Nederlandse Loodsencorporatie, of this in advance in writing (on paper or in electronic format). You must submit this declaration before you start providing your pilotage services for the first time. This written declaration must be submitted every year and, on the basis of the Dutch Recognition of Professional EU Qualifications Act and the Dutch Regulation on Training and Qualification of Nautical Professionals, must be accompanied by the documents listed below.
2.2. Documents to be annexed to the declaration
Each time you submit a declaration, and also if there are any changes in your situation, you must send the following documents to the Algemene Raad of the Nederlandse Loodsencorporatie:
1. Your first name, surname and contact details.
- Copy of your passport or identity card, and
- If you are not a national of an EU country, a document showing that you are a family member of an EU citizen, or that you have a long-term residence permit or refugee status in an EU country, or that you have an EU work permit (‘blue card’) or other relevant evidence that you may be entitled to EU rights. You are advised to check this with the relevant national authorities.
- Document showing that you are legally established in an EU country to provide pilotage services there and that you have not been temporarily or permanently prohibited from practising your profession and that you have no criminal record.
- The name of the profession in the country where you normally work.
- Copy or copies of your diploma or diplomas (sometimes a certified translation is also required).
- Including proof of your educational qualifications, formal qualifications or professional skills.
- Where appropriate, a document proving that you have practised your profession full-time or part-time for at least 1 year during the last 10 years (a certified translation may be required).
- Proof of your professional liability insurance (insurance company, policy number).
- Reference numbers of all your previous declarations submitted in the Netherlands (if applicable).
- Proof of your registration (registration number) in a trade register or similar public register, including the name of that register.
- If a licence is required for the provision of pilotage services in your country of establishment, the name and address of the competent supervisory authority.
- The professional organisation(s) to which you are affiliated as a service provider.
- Where you provide services in your capacity as a VAT taxable person, the VAT identification number.
3. Restrictions to the provision of services
3.1. Restrictions to the provision of services due to professional qualifications/diplomas
The Algemene Raad of the Nederlandse Loodsencorporatie, under the Dutch Recognition of Professional EU Qualifications Act, may not impose restrictions on you as a pilotage service provider on account of your professional qualifications/diplomas if the following applies:
- The pilotage education and training or the pilotage profession has been regulated in your EU country.
- The pilotage education and training or the pilotage profession has not been regulated in your EU country and you have practised this profession in your EU country for at least 1 year during the past 10 years.
However, due to the fact that the pilotage profession in the Netherlands is a regulated profession with implications for public health or public safety, the Algemene Raad of the Nederlandse Loodsencorporatie, after having received your declaration of intention to provide pilotage services in the Netherlands as a service provider, may decide to check your professional qualifications/diplomas first.
This is in accordance with the Dutch Recognition of Professional EU Qualifications Act. In the case of the provision of services on a temporary and occasional basis, the Act allows the Algemene Raad of the Nederlandse Loodsencorporatie to check the professional qualifications/diplomas of professionals whose profession has implications for public health or public safety.
If the check reveals that your professional qualifications/diplomas differ from those of the Dutch Registered Pilot, the Algemene Raad of the Nederlandse Loodsencorporatie may require you to take an aptitude test to show that you can bridge these differences. In that case, the final decision on permission to provide pilotage services as a service provider is taken on the basis of the result of the aptitude test.
4. Decision procedure
4.1. Procedure following the submission of your declaration as a service provides
After receipt of your declaration by the Algemene Raad of the Nederlandse Loodsencorporatie, the following applies:
- You will be notified of the costs of the application procedure, including the costs for the issue of the decision and the organisation of an aptitude test.
- The Algemene Raad of the Nederlandse Loodsencorporatie will decide within one month:
- Whether it will check your professional qualifications/diplomas.
- Whether, after having checked your professional qualifications/diplomas, you will have to take an aptitude test.
- Whether, after having checked your professional qualifications/diplomas, you will receive permission to act as a pilotage service provider.
- The aforementioned one-month decision period may, before the end of that period, be suspended by one month, stating the reasons for the suspension. Once the period of suspension has expired, a decision will be taken on your declaration within 2 months.
- If it has been decided that you must take an aptitude test, the Algemene Raad of the Nederlandse Loodsencorporatie will give you the opportunity to take it within one month of that decision.
- You will receive a detailed reasoning for that decision explaining that it was made on the basis of a careful comparison and has been tailored to your situation.
- The final decision on the permission to provide pilotage services as a service provider is taken on the basis of the result of the aptitude test.
- Your declaration as a service provider will be rejected if you have not passed the aptitude test or have not paid the associated costs.
- If the Algemene Raad of the Nederlandse Loodsencorporatie does not respond within the time limits described, you may start the provision of pilotage services as a service provider in the Netherlands.
5. Aptitude test in case of substantial differences
5.1 Substantial differences
On the basis of a check, the Algemene Raad of the Nederlandse Loodsencorporatie determines whether there are any substantial differences between your professional qualifications/diplomas and those of the Dutch Registered Pilot. Substantial differences refer to essential areas of the profession.
In that case, under the Dutch Recognition of Professional EU Qualifications Act, the Algemene Raad of the Nederlandse Loodsencorporatie will require you to take an aptitude test to demonstrate that you have acquired the missing knowledge, skills and competences and that you can bridge the substantial differences.
The Algemene Raad will motivate its decision, explaining that it was made on the basis of a careful comparison and has been tailored to your situation.
5.2 Aptitude test
With regard to the aptitude test, the Algemene Raad of the Nederlandse Loodsencorporatie will establish the following:
- The areas of content or partial areas of content.
- The manner in which and the period within which the various components of the aptitude test will be taken.
- If you are required to take an aptitude test, the Algemene Raad of the Nederlandse Loodsencorporatie will give you the opportunity to take the test within one month of taking the decision (see point 4.1).
6. Decision
6.1 Decision on your declaration as service provider
- You will be notified of the approval of your declaration. You can only start the provision of pilotage services after formal permission from the Algemene Raad of the Nederlandse Loodsencorporatie.
- You will be notified of the rejection of your declaration. The Algemene Raad of the Nederlandse Loodsencorporatie will give reasons for the rejection.
- You will be notified of the fact whether or not the Algemene Raad of the Nederlandse Loodsencorporatie has decided to check your professional qualifications/diplomas. The Algemene Raad of the Nederlandse Loodsencorporatie will give reasons for the decision.
- You will be notified of the decision that an aptitude test is required. The Algemene Raad of the Nederlandse Loodsencorporatie will give reasons for the decision.
- Your declaration will be approved if you have passed the aptitude test and have paid the associated costs.
- Your declaration will be rejected if you have not passed the aptitude test or have not paid the associated costs. The Algemene Raad of the Nederlandse Loodsencorporatie will give reasons for the rejection.
7. Dutch language
7.1 Knowledge of the Dutch language
You must have the necessary knowledge of the Dutch language required for the profession of Registered Pilot in the Netherlands.
8. Costs
8.1 Costs
The costs related to the aptitude test are € 1,347 per day
9. Objection and appeal
9.1 Objection to the decision
If you disagree with the decision of the Algemene Raad of the Nederlandse Loodsencorporatie with regard to your declaration, you can lodge a written objection within 6 weeks of the date of the decision. In that case, send a notice of objection to the Algemene Raad stating why you disagree with the decision. The notice of objection must at least contain your name, address and signature. The Algemene Raad of the Nederlandse Loodsencorporatie will consider your notice of objection and make a reconsidered decision.
9.2 Appeal against the decision on the objection
If you disagree with the reconsidered decision, you have the right to appeal to the Administrative law sector of the Rotterdam District Court. In the reconsidered decision you will find information on how to lodge a notice of appeal. An appeal against a Decision of the District Court can be lodged with the Administrative Jurisdiction Division of the Dutch Council of State, the highest court of appeal on this matter.