Corporate gifts in the Netherlands: government max €50, healthcare max €50 (CGR), and Criminal Code art. 177 Sr for bribery. Cadeo choice gifts from €15 stay within every limit, with an automatic audit trail.
Gift Laws for Businesses in the Netherlands — Anti-Corruption, Integrity Codes & Sector Rules [2026]
You want to surprise your team, customers, or business partners with a thoughtful gesture. But then the question comes up: is that actually allowed? The Netherlands has a patchwork of rules around corporate gifts — from the Criminal Code to sector-specific codes of conduct. In this guide, everything is laid out clearly: what is allowed, what is not, and how to give compliantly without turning it into a dry compliance exercise.
Dutch law does not have a universal "gift limit" — the rules vary by sector. Public officials may receive up to €50, healthcare follows the CGR limit of €50, and the Criminal Code (art. 177 Sr) prohibits bribery without a fixed amount threshold. A choice gift through a transparent platform such as Cadeo — from €15 per recipient — helps you stay within all limits and provides an audit trail for your compliance team.
1. The legal landscape: which laws apply?
The Netherlands does not have one law that says: "A corporate gift may cost a maximum of X euros." Instead, several laws and rules apply side by side, depending on who gives the gift, who receives it, and in what context.
The basis is the Criminal Code. Article 177 Sr makes bribery of public officials punishable: anyone who gives an official a gift with the intent to persuade them to do or omit something in their official role risks a prison sentence of up to six years. Article 328ter Sr extends this to the private sector: bribing employees or directors of companies is also punishable. The crucial point: the law makes no distinction based on amount. A bottle of wine worth €15 can technically count as bribery if the purpose is to influence someone.
In addition, there are sector-specific codes of conduct that do name concrete amounts — think of the Government Integrity Code (€50 for public officials) and the CGR code for the pharmaceutical sector (€50 for doctors). And then there are tax rules: the Working Costs Scheme (WKR) and the VAT rules for corporate gifts (maximum €227 per recipient per year). No wonder many employers cannot see the forest for the trees.
Cadeo tip: intent matters more than amount
The intent behind the gift is legally more important than the amount. A transparent choice gift through a platform — with an invoice, audit trail, and a clear reason — is legally much safer than an envelope with a gift card of the same value.
2. Government & semi-government: the €50 limit and reporting obligation
The Government Integrity Code is the guideline for all central government employees. The core rule: gifts above €50 are not accepted. But there is an important nuance that many companies miss: the reporting obligation applies to all gifts, regardless of value. A public official who receives a gift worth €20 must still discuss it with their manager.
For municipalities and provinces, their own codes of conduct often apply, but most use the same €50 limit. The Ministry of Social Affairs keeps a separate register of gifts for senior officials. Some municipalities are stricter: Amsterdam has a strict gifts policy under which every gift must be reported, regardless of value.
In tender procedures, the rules are even stricter. During an active tender, any gift — no matter how small — is a risk. The complete guide to gifts for public sector employees covers timing: never give during a tender, but after it for relationship building. The Senior Public Office Remuneration Standardization Act (WNT) also sets limits on the total remuneration of top officials in the (semi-)public sector — gifts of significant value may count toward this.
Example calculation — Gift for a government contact
You supply software to a municipality with 200 employees. At contract renewal, you want to send a small token of appreciation.
• Choice: choice gift via Cadeo of €25 per contact person (5 people)
• Total: 5 × €25 = €125 — well within the €50 limit per person
• Timing: after award, not during the tender phase
• Documentation: invoice in company name, clear reason noted
Result: compliant, transparent, and still personal.
3. Healthcare & pharmaceutical sector: hospitality and the CGR code
The healthcare sector has the strictest gift rules in the Netherlands. The Code of Conduct for Pharmaceutical Advertising (CGR) — set by the Foundation for the Code of Pharmaceutical Advertising — states that pharmaceutical companies may not give gifts to doctors, unless they are items of minor value (maximum €50) that are relevant to the practice of their profession. A pen with a logo? Gray area. A choice gift as a thank-you? Not allowed if it comes from a pharmaceutical company.
The concept of hospitality goes beyond physical gifts. It also includes invitations to conferences, dinners, travel reimbursements, and hospitality. The Health and Youth Care Inspectorate (IGJ) actively enforces. There is also the Healthcare Transparency Register: all financial relationships between healthcare providers and suppliers of medicines and medical devices are publicly registered.
But note: these strict rules apply specifically to the relationship supplier → healthcare provider. A hospital giving its own healthcare employees a gift — for example on Healthcare Day or for an anniversary — falls under the WKR, not the CGR. That makes a big difference: as an employer, you can surprise your staff, as long as it stays within the free space.
Important difference
Gift from a pharmaceutical company to a doctor = CGR rules (max €50, professionally relevant). Gift from a hospital to its own staff = WKR rules (free space). Make sure your compliance policy makes this distinction.
4. Financial sector, Wwft & gift cards
Banks, insurers, and other financial institutions are supervised by DNB and AFM. Although there is no uniform "gift code" for the entire financial sector, most institutions use an internal gifts policy with reporting obligation — similar to the government. ABP (the largest pension fund), for example, applies a €50 limit in its 2025 code of conduct.
A specific complication for the financial sector is the Act on the Prevention of Money Laundering and Terrorist Financing (Wwft). This does not directly concern giving gifts, but it does affect the medium: gift cards. Gift cards can qualify as electronic money. Above a value of €150, an identification and verification obligation applies. For online spending, that threshold is already €50. That is why many issuers have set the online spending limit at €50.
This is an argument in favor of choice gifts through a platform rather than separate gift cards. At Cadeo, the recipient chooses a gift from 1,200+ products from local, impact-driven brands — without any anonymous payment instrument entering circulation. The invoice goes through the company, the recipient does not receive a financial instrument, and there is a full audit trail. That makes compliance easier than handing out a pile of gift vouchers.
Cadeo tip: avoid the Wwft risk
Using gift cards as a corporate gift? Check whether the issuer is Wwft-compliant. With a choice gift through a platform, you avoid this entire issue — there is no gift card, so there is no Wwft risk.
5. International legislation that also applies in the Netherlands
Dutch companies operating internationally must consider foreign anti-corruption laws. The two most important are the UK Bribery Act (2010) and the US Foreign Corrupt Practices Act (FCPA).
The UK Bribery Act is notably strict. Any commercial organization that does business in the United Kingdom, in whole or in part, can be prosecuted — even if the company is not British. The law penalizes not only active bribery, but also the failure to prevent bribery. That means: if your employee gives a gift abroad that is considered a bribe, your Dutch company can be prosecuted in the UK. The law pays little attention to local customs unless they are laid down in law.
The FCPA targets bribery of foreign public officials. Dutch companies listed on a US stock exchange or making transactions through the US financial system fall under the FCPA. The fines are enormous — sometimes hundreds of millions of euros. For years, KPMG and PwC have advised Dutch companies to set up an anti-bribery program with eight steps: from risk analysis to gift registration.
What does this mean for your gift policy? If you operate internationally, create a company-wide gifts policy with a universal upper limit that matches the strictest legislation you are subject to. A choice gift of €25–€50 through a transparent platform with invoice and registration is safe in almost every jurisdiction.
6. How to set up a corporate gifts policy (5 steps)
The best way to stay out of trouble: make sure you have a written corporate gifts policy. Not as a bureaucratic exercise, but as a practical document that gives your team direction. Here are five steps to put it in place:
Map your risks
Which sectors do you serve? Government, healthcare, finance? Each sector has its own rules. Create an overview of the strictest limit per relationship.
Set amount limits
Choose a universal upper limit (for example, €50 for regulated sectors, €100 for others). Document exceptions and the approval process.
Define the process
Who is allowed to give gifts? Who approves them? How do you register them? A platform like Cadeo provides an automatic dashboard with reporting.
Train your employees
Rules only work if people know them. Include the gifts policy in onboarding and discuss it every year. Give concrete examples: what is allowed (Christmas gifts within budget), what is not allowed (a gift during a tender).
Use a central platform
The biggest compliance risks arise with ad-hoc gifts: an employee who buys something themselves and expenses it. A central gifting policy via a platform gives you control: standard values, approval flows, and automatic registration.
The goal is not to make giving gifts impossible — it is to make it transparent and repeatable. A good corporate gifts policy protects both your company and your relationships.
7. Why a choice-gift platform makes compliance easier
Compliance with corporate gifts comes down to three things: transparency, registration, and proportionality. A choice-gift platform like Cadeo addresses all three:
| Compliance requirement | Ad-hoc gift | Choice gift via Cadeo |
|---|---|---|
| Value transparent | Receipt gets lost, amount unclear | Fixed value per recipient, visible in dashboard |
| Audit trail | Expense form if you are lucky | Automatic: who, what, when, which amount |
| WKR registration | Manually track per employee | Automatic per campaign, exportable |
| Enforce amount limit | Rely on employees | Built in: you set the value |
| Gift registration | Excel, if you are lucky | Dashboard with real-time overview |
| Wwft risk | Possible: with gift vouchers or open-loop cards | No: no financial instrument |
At Cadeo, you set the budget per recipient (from €15). The recipient chooses a gift themselves from the portal — from brands such as Rituals and Le Creuset to gift cards from Bol.com and Dille & Kamille, or a donation to Treebytree. The invoice goes through your company with all details: date, value, reason, recipient. Your compliance team can find everything in the dashboard. No envelopes with vouchers, no expense claims, no gray areas.
And perhaps most important: because the recipient chooses themselves, there is no risk that the gift will be seen as "custom-made for influence." A choice gift is neutral by definition — the giver determines the value, not the content.
Frequently asked questions
There is no universal maximum limit. The rules depend on the recipient's sector. For central government employees, the Government Integrity Code sets a limit of €50. In healthcare, the CGR code also uses €50 for gifts from suppliers to doctors. For the private sector, there is no legal upper limit, but the Criminal Code (art. 328ter) prohibits gifts intended to influence someone in their role. A written gifts policy with your own upper limit is therefore always recommended.
Yes, as long as the value stays below €50 and the gift is not meant to influence the official in an ongoing decision-making process. Never give a gift during a tender procedure. The official is required to report every gift to their manager, regardless of value. A choice gift worth €25 as relationship maintenance after a successful project is usually no problem. Always document the reason.
There is a crucial difference. Gifts from suppliers (pharmaceutical companies, medical devices) to healthcare providers fall under the strict CGR code: maximum €50, and only if the item is relevant to the practice of the profession. Financial relationships are recorded in the Healthcare Transparency Register. But a healthcare institution giving its own staff a gift falls under the WKR — normal tax rules for employer gifts apply there.
Possibly. The UK Bribery Act applies to any organization doing business in whole or in part in the United Kingdom, even if the company is not British. The law also punishes failure to prevent bribery. That means if an employee of your company gives a gift that is seen as a bribe, your company can be prosecuted. Set up an anti-bribery program if you have international customers or suppliers.
Gift cards can qualify as electronic money under the Wwft. Above a value of €150, the issuer has to carry out identification and verification. For online spending, the threshold is €50. This makes gift cards as a corporate gift more complicated than necessary. A choice gift through a platform such as Cadeo avoids this: no financial instrument is put into circulation, the recipient chooses a product, and the invoice goes through the company.
Start with a risk assessment: which sectors do you serve and which rules apply there? Set amount limits per category, define an approval process and registration duty, and train your team. Use a central platform for all gifts so that you automatically build an audit trail. The five steps in this article give you a practical plan. Review the policy every year, because regulations change.
A choice gift through a platform offers three compliance benefits at once. First: transparency — the value per recipient is fixed and visible in the dashboard. Second: audit trail — who, what, when, and which amount is automatically recorded. Third: neutrality — the giver determines the value, not the content, so the gift cannot be seen as custom-made for influence. That makes compliance easier for both giver and recipient.
