Document Overview
This is a guideline and warning (richtlijn en waarschuwing) from the Vlaamse Toezichtcommissie (VTC, Flemish Supervisory Commission), published on the Vlaanderen.be website. Its subject is the use of ANPR cameras (automatic number plate recognition) and section control (trajectcontroles) by cities and municipalities. The guideline, dated November 2024, was sent to all general directors and colleges of mayors and aldermen. The page also lists related items: a guideline for local authorities from October 2023, a VTC decision of 20 September 2024 on a complaint against a municipality, a Council of State decision of 26 February 2025, and a checklist published in November 2025.
How the Guideline Describes ANPR Cameras
- The guideline calls the common description that cameras 'read and register number plates' too simple.
- Cameras usually take photos with a considerable resolution of at least one side of the vehicle, normally the front. Software analyses the image and detects the number plate.
- If only the plate is kept and the original images are deleted, the guideline calls this a relatively minimal but still risky processing operation.
- The original photo is often kept in case of disputes. Persons in the vehicle may be recognisable, and the location and time are stored regardless of whether the original image is kept.
Concerns Raised by the VTC
- The VTC notes that more ANPR cameras are being installed and that they are increasingly used for additional purposes, a development sometimes called function creep, partly to improve the return on investments.
- It states that the risk to citizens' rights and freedoms grows with the number of cameras and uses, increasing the possibility of surveillance, tracing and profiling.
- It notes with concern that decision-making often follows the wrong order: infrastructure is set up first, purposes are defined afterwards, and only then is a legal basis sought. Purposes are later revised and extended.
- Automated and widespread identification and location technologies are described as particularly threatening to privacy and to the freedom to move anonymously.
Recommendations to Municipalities
- Hold a thorough political debate on the necessity, desirability and intended benefit of the cameras, with concrete, specific purposes rather than general aims such as 'increasing safety'.
- Carry out a DPIA (gegevensbeschermingseffectbeoordeling) at legislative level to map risks, looking in particular at cumulative effects.
- Identify a clear legal basis, limited to the defined purposes and aligned with existing camera legislation.
- Carry out a DPIA for every local implementation, which the guideline states is mandatory under the VTC's DPIA list.
- Work out alternatives in depth, including the technical configuration options such as storing only number plates and not the accompanying images. Less privacy-intrusive methods should be preferred where they can reasonably achieve the objective.
- Deploy and use the cameras only once the risks are sufficiently covered.
- Assess the added value of camera surveillance within the proportionality test, and evaluate use regularly in the DPIAs.
Related Decisions and Publications
- The Council of State rejected, on 26 February 2025, a request for suspension of a VTC measure following a complaint against a municipality about placing ANPR cameras for section control. It pointed to the importance of alternatives to the cameras.
- The VTC published its decision of 20 September 2024 to avoid misunderstandings about the reasoning and scope of that decision.
- A checklist published in November 2025 lists points that administrations should check before placing cameras.
Purpose of the Guideline for Cities and Municipalities
The guideline is addressed to cities and municipalities and their administrative and political leadership. It sets out the VTC's expectations before ANPR cameras are placed. The VTC states that it is always willing to advise on DPIAs and projects.