Entry for Company Register / Belgium


This is a discussion about the submission for Company Register / Belgium.

Can you please check again ? Since the comments on the review indicates an error, but going to the https://kbopub.economie.fgov.be/kbo-open-data/kbo-open-data/signup?form=&lang=en seems to work just fine on my computer, and it is the registration form for the complete download in CSV.

In addition, you may find this info useful:

Steps for registration

Info at the bottom of this page -

There is a link “Registratie voor Open Data en webservice Public Search”, which will lead to

Don’t change the language, just click on the link

Then you can switch to English (if needed)

And register at the bottom (“Registreren” or “sign up”)

After registration (for free), you’ll have access to the FTP-server with CSV files.

To summarize:

  • please change “publicly available to yes”, as the reviewer already mentioned the availability of the search page
  • please change “open and machine readable format” to yes, as the data can be obtained, after free registration, in CSV
  • please change “downloadable at once” to yes, as the data can be obtained, after free registration, in CSV


Dear @barthanssens

thank you very much for your feedback. As part of the public dialogue we will follow up on your input, and will get back to you in the coming days.

All the best,


Hi @barthanssens

I checked this again. This is a similar case where I have to refer the assessment to the dataset that is most representative for an open company register. The source that you mention in this link is indeed a portal that can lead to CSV and the link works now.

The issue I see is that only companies can register which are listed at BCE. If i would refer to this dataset, I would say the data is available online only with access controls (which are in any case closed access and should not be named as open data on the portal in my opinion).

Yes, the registration appears to be for free, but it is an important limitation that only companies can register.


Hello @dannylammerhirt

well, there is no limitation, individuals can register as well (just leave the company number field empty).
The signup form mentions at the bottom “(*) To be completed only when applicable”.

Admittedly the layout should be changed, since more often than not a “*” in webforms is used to indicate mandatory fields (which isn’t the case here)


Hi @barthanssens,

Thanks for the clarification, this is indeed confusing. I tried the service. It all works fine. I will then accept the link that you originally submitted during our submission phase.


Entry for National Statistics / Hong Kong

I don’t think the license would qualify as an open one: The document in this link states the following:

“Le preneur de licence s’engage à ce que les données ne soient pas altérées ni leur sens dénaturé.”

I would consider this a limitation of the modifiability which is not compliant with the OpenDefinition 2.1.


Ok, that is kind of a strange license clause indeed… I’ll pass it on to the administration.


There is a similar discussion going on here. Would be good to read both together for more context: Entry for National Statistics / Hong Kong


Can you check what this clause refers to @barthanssens? I imagine it is a standard clause, but it is important that we clarify whether modifiability would be affected


I’ve sent them an email to fully clarify the clause and double check, but it’s about not modifying e.g. a company name or the official list of economic activities etc.

There are companies in Belgium reusing the CSV export files (for example http://kbodata.be/) to build applications and prettier websites etc, and the administration is totally OK with it.


Hi @barthanssens,

not sure if we expected an answer from the agency, did you hear anything back from them? Another accepted practice would be to use indemnity clauses which do not pose reuse-restrictions but limit the liability of a data provider.


Not really, but the license text itself is a bit contradictory, since the article 1.2 says “Le présent contrat a pour objet d’autoriser les preneurs de licences à partager, modifier et utiliser les données publiques …”

Note that the framework for this license is defined in a Royal Decree (http://www.ejustice.just.fgov.be/cgi_loi/change_lg.pl?language=fr&la=F&cn=2008071822&table_name=loi) which is actually more clear about the subject, with indeed a indemnity clause :

(Art 2 §3 1° l’Etat belge ne peut être tenu responsable des erreurs ou lacunes relatives aux données fournies… and 2° l’Etat belge ne peut pas davantage être tenu responsable de la manière dont les données … sont réutilisées, combinées avec d’autres données ou transmises à des tiers par le preneur de licence;)

which boils down to not being held responsible for errors, nor for how data is being reused or combined by a third party. The Decree itself may need some updates, since i.e. the procedure for obtaining the data is now automated etc, but the bottom line is that reuse is allowed…


Great, thank you so much for the enlightening information. We will change the submission accordingly then


Hi Bart,

Hope all is well! I am currently looking a bit deeper into open licensing across government. We are particularly interested in Belgium and I was wondering - would you be available for a quick chat or know someone who would be willing to talk about the status of open licenses in Belgium?


Hello Danny,

well, it’s complicated :wink:
A few “larger” cities have their own open data license, the 3 Regions also have their licenses, and there are a few licenses on the federal level as well. Most licences, however, are more or less rebranded CC-BY licenses (IMHO, for PR and/or NIH reasons, but that’s just my personal opinion…)

At the federal level, we are working on a Royal Decree that will promote CC-Zero(-ish) license in a comply or explain way: CC-Zero(-ish) as default, CC-BY(-ish) as second license - with a motivation why CCO wasn’t good enough - and custom license - again with an explanation why CC0/CC-BY wasn’t selected.

I’m not sure if CC-Zero / CC-By will literally be mentioned in the formal text, to keep it flexible and avoid having to update the decree in case the CC-Zero would be updated…

Anyway, if you want to discuss this in detail, I’d suggest to contact the legal expert of the Simplification Agency (DAV/ASA), Ms.Martine Trznadel and/or Mr.Noêl Van Herreweghe (soon-to-be-retired open data program manager of the Flanders Region) and/or his successor Mr.Mathias De Schrijver)


Hi Bart,

Fantastic. Yes I was researching a bit about the situation in Belgium already and discovered your very insightful slide deck. It’s definitely useful to get a better overview what makes the decree authors to promote CC-(ish) licenses (be it the Federal decree, or the Wallonian and Flemish ones).

Even if it should be PR reasons, they seem to work pretty well, as we see in Taiwan, Singapore, and Norway. :slight_smile: Just to make sure I understand correctly - the Royal decree is still developing, but the Flemish and Wallonian decrees are already in place? I’d be interested to hear how effective the ‘comply or explain’ policy works.

Thanks a lot for the useful info, I’ll make sure to get in touch with your contacts!



Hello Danny,

I guess the correct term is Royal Order, because Decree is something slightly different in our legislation.

It boils down to a two-step approach for all the federal (national) and regional levels.

Due to the decentralised nature of Belgium, the PSI Directive has to be transposed in federal (Law) and regional legislation (called a regional Decree or Ordonnance), because e.g. Tourism and Culture are regional matters and e.g. (most of) Justice is a federal matter (so we need multiple legislative documents to cover opening up all data). This first step has meanwhile been done by the federal state and the 3 regions.

However, all these legislative texts off-load / defer the selection of licenses to a (royal) Order or a (regional government) Decision (makes it easier to update if needed).

  • Only the Flemish Region has published their preferred CC-like but “branded” licenses, so currently they are the only administration covering both two steps. They should be able to provide some information on how effective the comply-or-explain policy is working for them.

  • The Brussels Region is looking into the selection of licenses

  • The Walloon Region was/is considering ODBL but is also looking into other licenses.

  • At the federal level the Royal Order is inching towards being approved, focusing on CC / comply or explain.

The representatives of the Regions mentioned they are interested in harmonizing the licenses, but this will probably take some time.