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Illustration of a kidney with an airplane, symbolizing cross-border organ trafficking

Frequently asked questions about the Reporting Point for Organ Transplant Travel

As of July 1, 2026, healthcare providers must report cases where a patient living in the Netherlands has traveled abroad for an organ transplant. Below are the frequently asked questions about this reporting point. Is your answer not listed? Please contact the NTS at nfp@transplantatiestichting.nl.

General

What is the Reporting Point for Organ Transplant Travel?

The Dutch Transplant Foundation (NTS), through the Reporting Point for Organ Transplant Travel, collects data on the travel behavior of residents of the Netherlands traveling abroad for organ transplants. This information is reported to the NTS by healthcare providers—for example, when a patient has received a donor kidney abroad and then returns to the Netherlands. A healthcare provider is often the first, and sometimes the only, person aware of such a transplant. To gain insight into these transplants, more and better knowledge and cooperation are required, both nationally and internationally. The NTS collects the obtained information and shares it with the Council of Europe, commissioned by the Ministry of Health, Welfare and Sport. By collaborating within Europe to map out travel movements for organ transplants, it becomes clear whether there are destinations people frequently travel to without a legitimate reason.

Is it mandatory to make a report?

Yes, making a report is mandatory as of July 1, 2026. This is established in Article 8e of the Body Material Safety and Quality Act. Every travel movement of a Dutch resident abroad for the purpose of an organ transplant must be reported to create a complete picture of such travel movements. By making it mandatory to report all cases, healthcare providers do not need to assess whether or not an illegal transplant might be involved. Because the reporting obligation is anchored in law, making a report does not violate professional secrecy.

What do I need to report to the reporting point?

When a patient living in the Netherlands has traveled abroad for a transplant, the healthcare provider makes a report regarding this patient. This does not necessarily involve illegal activities. Every report helps us gain insight into the travel movements that patients make for a transplant. The report consists of 24 questions in content. These questions relate to, among other things, the transplant and the travel movement. The patient's name is never included in the report.

Why is reporting important?

It is known that patients worldwide travel for organ transplants. By collecting and sharing data on travel behavior abroad for organ transplants, the scale of this is being mapped out at the European level for the first time. This information helps build knowledge for identifying and combating organ trafficking. The data also contributes to any necessary policy measures for the required cross-border cooperation in the field of transplantation, aiming to increase the safety of patients and donors. With the introduction of the Reporting Point for Organ Transplant Travel, the Netherlands joins other European countries that already have such a reporting point. In addition, several European countries are currently developing one. The Reporting Point for Organ Transplant Travel is expressly not intended for the investigation or prosecution of the individuals to whom the report relates.

Does the reporting point apply to both living and deceased donation?

Yes. The reporting point applies to all Dutch patients who have received an organ abroad. No distinction is made between the different types of donation (deceased or living). Furthermore, the reporting point applies to every type of organ transplant (kidney, liver, heart, lung, pancreas, small intestine).

Who is the client and executor of the Organ Transplant Travel Reporting Point?

The Dutch Transplant Foundation (NTS) has been commissioned by the Ministry of Health, Welfare and Sport to manage, operate, and further develop the Reporting Point for Organ Transplant Travel. Through this, the NTS collects information on travel behavior related to organ transplants by Dutch patients. The NTS shares the information from the Dutch reports with the Council of Europe.

Making a report

How do I make a report?

When you want to make a report, go to www.transplantatiestichting.nl/meldpunt-reisbewegingen-orgaantransplantaties. Here you make an initial report by leaving your contact details (name, phone number, and email address). You will then receive the questionnaire by email in preparation. A policy officer from the NTS will go through the questionnaire with you over the phone. The answers you provide are entered directly by the relevant NTS policy officer into the specially built portal of the Council of Europe. Once the questionnaire is completed, the report is finalized. The reporter's contact details are immediately deleted.

What happens to my report?

The NTS collects the information from Dutch reports and shares it in the Council of Europe portal. Because multiple European countries do this, a picture emerges of travel behavior in the context of organ transplants at the European level. The patient the report is about will not be contacted by the NTS or the Council of Europe. The reporter's contact details are deleted as soon as the report is completed.

Why was a telephone reporting method chosen?

The information collected about the patient's travel movements contains sensitive data about a potentially vulnerable patient. By discussing this information over the phone, the collected data does not need to be stored in an additional location. During the phone call, the data is entered directly into the secure registry of the Council of Europe. By choosing this working method, the data does not need to be stored at the NTS. In addition, the NTS policy officer can provide support with making a report over the phone where necessary.

Do I also have to report it if the transplant took place a long time ago?

The new Safety and Quality of Body Material Act enters into force on 01-07-2026. From then on, reports regarding international travel movements must be made. This means that if you, as a healthcare provider, discover after 01-07-2026 about a travel movement for an organ transplant that took place before 01-07-2026, you must also report it. You are therefore expected to report retrospectively if you discover the travel movement after 01-07-2026.

Do I also have to report it if I am certain or have a very strong suspicion that the transplant was legal?

Yes, the travel movement must be reported even then. It is necessary to map all travel movements in order to also gain insight into potential illegal travel movements. When making the report, you can indicate, for example, whether the patient had a referral letter. A referral letter can be an indication that the transplant took place legally. Making the distinction between legal and illegal transplants does not need to be done by the person making the report.

Who can make a report?

Every healthcare provider in a hospital who has a treatment relationship with the patient in the context of organ transplant care can make a report. This can be, for example, a (resident) physician, a medical social worker, or a nurse specialist. In the event that multiple healthcare providers make a report about the same patient, this will be recognized by the NTS.

What if I am in doubt whether I should make a report?

Every travel movement of a resident of the Netherlands abroad for an organ transplant must be reported. Are you in doubt, or would you like advice on making a report? You can always contact the NTS via nfp@transplantatiestichting.nl. We will then contact you as soon as possible.

What if I discover afterwards that my report was incomplete or incorrect?

If you later discover that the information you provided to the Organ Transplant Travel Reporting Point is incorrect, we recommend contacting the NTS via nfp@transplantatiestichting.nl. We will then do our best to make sure the information is corrected.

The patient

Do I need to tell my patient that I am making a report?

There is a statutory reporting obligation for making a report to the Organ Transplant Travel Movements Reporting Office. This means that no consent from the patient is required to make a report. The KNMG guideline 'Dealing with medical data' recommends that, even in the event of a statutory reporting obligation, a healthcare provider should inform the patient about the provision of information if possible.

Will my patient be approached by those who can view the report?

No, your patient will never be approached by the NTS or by the Council of Europe. These are the only parties that can view the reports. Even within the NTS and the Council of Europe, not everyone can view the report. The number of employees who can view this is kept to a minimum.

What if making a report puts pressure on the treatment relationship I have with my patient?

It is understandable that making a report can cause tension in the treatment relationship. At the same time, the reporting obligation is laid down by law and applies to all healthcare providers. The report must therefore still be made. Communicate openly and clearly with the patient about the report. Explain the usefulness and purpose of the reporting office. Also explain that the reporting office is explicitly not intended for criminal prosecution. This can prevent or remove anxiety in patients.

Is reporting a breach of professional confidentiality?

No. The reporting obligation is laid down in Article 8e of the Body Material Safety and Quality Act (Wet veiligheid en kwaliteit lichaamsmateriaal - Wvkl). This provides a legal basis for sharing data and does not breach professional confidentiality. For more information on breaching medical professional confidentiality, see Article 7:457 of the Dutch Civil Code (WGBO).

What should I do if my patient explicitly asks me not to make a report?

Even in that case, the reporting obligation continues to apply. The obligation to report is laid down by law in Article 8e of the Body Material Safety and Quality Act (Wvkl). The reporting obligation does not depend on the patient's consent. Communicate openly and clearly with the patient about the report. Explain the usefulness and purpose of the reporting office. Also explain that the reporting office is explicitly not intended for criminal follow-up. This can prevent or remove anxiety in patients.

What should I do if a patient tells me that he/she intends to undergo a transplant abroad?

When a patient indicates an intention to travel abroad for a transplant, it is important to support the patient in making an informed decision. Provide clear and understandable information about the ethical, medical, and psychosocial risks of illegal transplant practices, including the potential and often severe harm inflicted on the donor. Also pay explicit attention to the risks to the health and safety of the patient themselves. Discuss the dangers of illegal organ transplants, such as insufficient donor evaluation, deficient or missing medical screening, unsafe surgical conditions, postoperative complications, an increased risk of infectious diseases, the lack of adequate aftercare and continuity of care, and the long-term risks for transplant recipients.

Can my patient gain insight into the report?

Every patient can submit a formal access request to the client of the reporting office. This is the Ministry of Health, Welfare and Sport. For information on how to submit an access request, see https://www.rijksoverheid.nl/ministeries/ministerie-van-volksgezondheid-welzijn-en-sport/privacy.

 

For more information on the rights of data subjects, see Rights of Data Subjects Organ Transplant Travel Movements Reporting Office.

Are reports shared with other agencies, such as the IGJ, the police, or the Public Prosecution Service?

The NTS collects the information from the Dutch reports. Subsequently, the NTS shares the necessary information exclusively with the Council of Europe. Information about the reports is never shared with other agencies, such as the IGJ (Health and Youth Care Inspectorate), the police, or the Public Prosecution Service.

Will the report end up in my patient's medical file?

The report regarding travel movements is made to the NTS. The reporting point is separate from the patient's medical file, which is managed by the hospital. The healthcare institution's usual guidelines apply to recording information in the medical file.

Data and information

What data is required to make a report?

To obtain a clear picture of the international travel movements of patients traveling for an organ transplant, a certain amount of data is required. This includes data that says something about the transplantation (such as the type of organ and the country where the transplantation took place) and data that says something about the donor and the recipient (such as age and gender). Please note: the patient's name is not recorded anywhere.

What is done with the patient data?

Part of the data collected at the reporting point says something about the patient. This is, naturally, sensitive information. This information is collected by the NTS over the phone and directly registered in the registry managed by the Council of Europe. This way, this sensitive information never has to be stored at the NTS. The contact details of the person making the report are deleted immediately after the report is registered.

How is data security ensured?

The information retrieved by phone is entered into the registry managed by the Council of Europe. The data processed in this registry is managed in accordance with the Council of Europe's regulations on data protection, and in accordance with the principles of lawfulness, fairness and transparency, purpose limitation, data minimization, accuracy, storage limitation, security, and accountability.

Collaborations

Is the information I provide used for any other purposes?

The information collected via the reporting point is used to gain insight into transplant travel movements and for (inter)national policy development. The reporting point is not used for criminal investigation or prosecution. The data collected at the reporting point is shared exclusively with the Council of Europe.

Why is it important for European countries to cooperate in this matter?

There may be valid reasons for a patient to travel abroad to undergo a transplantation. However, it is illegal to be involved in an organ transplantation involving coercion or trafficking. Illegal forms of travel movements for organ transplants mostly appear to take place outside our national borders. By cooperating within Europe to map out travel movements for organ transplantation, it becomes clear whether there are destinations to which people frequently travel without a legitimate reason.