"Rules have never been the problem, but the lack of understanding of their coherence has been," writes Jan Willem van de Groep, programmer, future thinker and publicist. With this, he responds to a critical letter from the Expertise Center for Construction Regulation to the Stoer committee of outgoing Minister Mona Keijzer.
When the STOER Advisory Group presented its report, it sounded like a breath of fresh air: construction faster, cheaper and less regulated. Lower ceilings, steeper stairs, looser noise requirements and a simpler environmental performance requirement were to pull the sector out of the morass of regulations. Minister Mona Keijzer eagerly embraced the proposals. Two days before the parliamentary debate on the Law on Strengthening the Control of Public Housing, she announced that she would implement almost all the recommendations. But according to the Expertise Center for Construction Regulation (ERB), that is precisely the problem. In a detailed letter to the Chamber, chairman Rob Wijnands argues that the STOER program is not evidence of deregulation, but of deregulation. It is not the rules that are the problem, but the loss of knowledge of why those rules were ever made. "Not STOER, but SLIM," he writes. A call for fundamental recalibration of the building system, not simplification of it.
The real pain is deeper
The letter points out that the Building Code and its successors have been amended numerous times in more than 30 years, often at the level of detail, sometimes with editorial or legal errors. That accumulation of minor changes has resulted in a system that has become internally inconsistent. The result: endless discussions, procedures and differences in interpretation. STOER proposes to tackle this tangle with a blunt knife. Delete, relax, let go. But according to ERB, that hits exactly the wrong spot. The supposedly unnecessary rules are often the last vestiges of carefully constructed coherence between safety, health and usability. Removing them also removes the logic of the system.
What STOWER proposes
Among other things, the advisory group advocates lowering ceilings from 2.60 to 2.50 meters, allowing steeper stairs and abandoning stricter daylight requirements in bedrooms. It also wants to call off the tightening of the environmental performance requirement (MPG) and give municipalities less leeway to set higher sustainability standards locally. According to STOER, this would result in a cost savings of thirty thousand euros per home. The Expertise Center points out that these calculations are poorly substantiated and completely ignore social costs. A lower ceiling seems a minor intervention, but affects the indoor climate and ventilation. Less daylight increases health risks. And relaxing noise standards directly affects quality of life. Wijnands calls it a return to the situation before the Building Code: a patchwork of minimum requirements that no longer protect the citizen, but the builder's margins.
The forgotten basics of regulation
To understand this, the letter harkens back to the genesis of building regulations. In the 1980s, the Building Code was designed as a uniform and technically coherent framework. It was based on the 1983 Action Program for Deregulation of Residential Building Regulations, which called precisely for clarity, uniformity and a minimum quality for safety, health and usability. Since then, much of that knowledge has evaporated. Rules have been simplified, renumbered or modified without awareness of their interconnectedness. What began as an integral balance of interests has degenerated into a mosaic of loose regulations. STOER sees mainly paperwork, but ignores the fact that behind every rule there is a balance between man and environment.
Don't scrap but recalibrate
The ERB therefore advocates not fewer rules, but a fundamental review: re-examining building regulations from the perspective of their original objectives as well as the current juncture. A "SLIM" approach, writes Wijnands: Simpler Legislation for the Internal Market. The rules must become understandable and consistent again, but without compromising the minimum quality of the built environment. This includes a reassessment of public values that are missing from the STOER report: health, accessibility, safety, climate resilience and circularity. The letter points out that these values have not only technical but also social returns. Those who lower requirements will ultimately see this reflected in higher healthcare costs, energy consumption and renovation expenditures.
Knowledge as the keystone
The letter touches a sensitive chord in the sector: the aging of regulatory knowledge. Where broad committees and sounding board groups used to work on the creation of regulations, that task now lies with a small number of officials without practical experience. University education also pays little attention to the development and background of building regulations. The result is a generation that knows the letter of the standard but not the spirit. This makes regulations vulnerable to simplification and opportunism. Wijnands therefore advocates the establishment of a chair of "building regulations" at TU Delft, and a network in which young professionals are trained to ensure the continuity of knowledge.
Another route to innovation
The letter ends with a concrete proposal: start a project to fully revise the Building Works Environment Decree (Bbl) in January 2026, with delivery of a first draft in December 2026. The intention is not to weigh down the system, but to make it understandable and coherent again, with clear distinctions between technical and administrative regulations. That perspective is substantially different from the STOER logic of "build more through fewer requirements." It asks what we actually want to build: homes that last 20 years or buildings that remain usable for a century.
Rules are never the problem
The discussion of deregulation in construction is not new, but this letter exposes its weakness. Rules have never been the problem, but the lack of understanding of their consistency has been. The choice is not between fast or slow, but between short-sighted and future-proof. Those who truly want to build for the future do so not by lowering the bar, but by understanding again why it was once there.
This article was written by Jan Willem van de Groep, programmer, future thinker and publicist. He is known, among other things, for the government program Building Balance.
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