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Security report for registergroenverklaringen.nl

Stichting Milieukeur (SMK) · Government · Netherlands

Medium risk. 9 critical or high findings in GDPR outside view, Security headers and 1 other check.

Security score

53/100

Risk levelMedium

0–100, higher is better. How it is calculated

The Register Groenverklaringen website serves as a public registry for sustainable new construction projects in the Netherlands that comply with the Regeling groenprojecten, a government initiative. Managed by Stichting Milieukeur (SMK) and supported by the Ministries of Infrastructure and Water Management and Finance, the platform facilitates the issuance of Groenverklaringen certificates, which are important for accessing green mortgage products. The target audience includes contractors, developers, and potential homebuyers interested in sustainable building projects. Technically, the website employs a modern front-end stack including jQuery, Foundation CSS framework, DataTables, and TinyMCE, with analytics powered by Google Tag Manager and Goliath Analytics. The site is mobile-optimized and provides a good user experience with clear navigation and relevant content. However, some technical improvements are recommended, such as enabling DNSSEC and adding security headers to enhance security posture. From a security perspective, the site uses HTTPS and secure form inputs but lacks explicit security headers and privacy/cookie policies, which impacts privacy compliance. No critical vulnerabilities or exposed sensitive data were detected. WHOIS data is transparent and consistent with the website's Dutch government-related purpose, supporting legitimacy. Overall, the website is professionally presented and trustworthy but would benefit from enhanced privacy compliance and security best practices to improve user trust and regulatory adherence.

Scanned

NIS2 and GDPR posture

GDPR outside view
10/ 100 · Critical
Checks completed
7of 7

NIS2 Art. 21(2)

  1. (a) Risk analysis and security policies: Not visible from outside
  2. (b) Incident handling: One indicator
  3. (c) Business continuity, backups and crisis management: Not visible from outside
  4. (d) Supply chain security: Not visible from outside
  5. (e) Secure acquisition, development and maintenance, including vulnerability handling: Partly checked
  6. (f) Assessing the effectiveness of security measures: Not visible from outside
  7. (g) Cyber hygiene and security training: Not visible from outside
  8. (h) Cryptography and encryption: Partly checked
  9. (i) HR security, access control and asset management: One indicator
  10. (j) Multi-factor authentication and secured communications: Not visible from outside

This scan rated NIS2 with an earlier keyword method that is no longer shown; rescan for the per-article view. Risk management, continuity, supply chain, training, MFA, management oversight (Art. 20) and incident reporting (Art. 23) need internal evidence, and Guard cannot tell whether NIS2 applies to this organisation.

GDPR is indicative only, based on publicly visible signals: Articles 7, 12, 13 and 32 of Regulation (EU) 2016/679 and Article 5(3) of the ePrivacy Directive. Not a certification or legal assessment.

Priority findings

9 findings rated critical or high. Fix these first.

  1. GDPR outside view

    These are the privacy signals visitors and data protection authorities look for under GDPR.

    • Critical

      EU business without adequate privacy measures

      EU businesses are subject to strict GDPR requirements

      What to do: Implement comprehensive GDPR compliance including privacy policy, cookie consent, and data protection measures

    • High

      No Privacy Policy found

      GDPR requires a clear and accessible privacy policy

      What to do: Add a comprehensive privacy policy page and link to it prominently

  2. Security headers

    Security headers are instructions your web server sends to every visitor’s browser. Missing ones leave visitors more exposed to attacks such as clickjacking and injected scripts.

    • High

      Missing Strict-Transport-Security header

      Forces HTTPS connections

      What to do: Add "Strict-Transport-Security: max-age=31536000; includeSubDomains; preload"

      • CWE-319
      • OWASP A04:2025
      • ASVS V3.4.1
    • High

      Missing X-Frame-Options header

      Prevents clickjacking attacks

      What to do: Add "X-Frame-Options: DENY" or "X-Frame-Options: SAMEORIGIN"

    • High

      Missing Content-Security-Policy header

      Controls resources the browser is allowed to load

      What to do: Implement a Content-Security-Policy appropriate for your application

      • ASVS V3.4.3
      • OWASP Secure Headers: OWASP Secure Headers Project recommends Content-Security-Policy: default-src 'self'; form-action 'self'; base-uri 'self'; object-src 'none';…

Need hands-on remediation? Email guard@offseq.com

Keep watching registergroenverklaringen.nl

This scan found 29 issues across 6 checks. Monitoring re-runs those checks daily, emails you when something material changes and records each fix, so you can show progress.

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Recommended

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  • TLS certificates and expiry
  • DNS records
  • SPF, DKIM and DMARC
  • Security headers
  • GDPR and NIS2 posture
  • Exposed services
  • Third-party trackers
  • Security score drift

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Results by check

Each check with its score, findings and the evidence it collected.

How this score is calculated

The security score runs 0–100, higher is better. It is the plain average of the security checks that completed in this scan, each counted equally. A check that could not run is left out: it counts neither as a pass nor as a fail.

Counted in this score

SSL/TLS
62
Security headers
15
Email security
70
DNS health
60
Network security
100
GDPR outside view
10
Average
53

Not counted

  • NIS2 outside view: Re-weights evidence from the TLS, email, DNS, network and hygiene checks, so counting it would count that evidence twice. Shown on its own.
  • OffSeq Observations: An AI reading of the site, useful context but not reproducible evidence. Shown on its own.

Findings that cap the score at 49

Each of these is serious on its own, so while any is present the site cannot rate better than high risk, however good the other checks are.

  • The certificate is not trusted by browsers
  • The website is not served over HTTPS
  • A database, remote desktop, file-sharing or Telnet service is reachable from the internet
  • The page loads a script from a compromised source
  • The domain registration has expired
  • SPF authorises every server to send mail as the domain

Partial scans

When the site blocks Guard or most checks cannot run, the score covers only the checks that ran (usually DNS and email), is capped at 75 and is shown as partial, without a risk level.

Risk levels

  • Critical0–25
  • High26–49
  • Medium50–75
  • Low76–100

Technical appendix

Business context, site observations and technical notes gathered during the scan, and the standards behind each reference.

Business context

Business profile

The Register Groenverklaringen operates in a niche government-related sector focused on sustainable construction certification in the Netherlands. Its competitive advantage lies in its official backing by Dutch ministries and management by SMK, providing credibility and authority. The business model revolves around maintaining a public registry and facilitating certification issuance, targeting contractors, developers, and homebuyers seeking green mortgages. Revenue streams are likely indirect, linked to government funding or certification fees. The partnership ecosystem includes RVO and SMK, which are critical to its operations. Growth potential is tied to increasing demand for sustainable building and green financing products.

Security posture

The website demonstrates a moderate security maturity level with HTTPS enabled and no visible sensitive data exposure. However, the absence of security headers such as Content Security Policy, HSTS, and X-Frame-Options reduces its defense-in-depth. Lack of published security policies and incident response contacts indicates limited transparency in security governance. Privacy compliance is weak due to missing privacy and cookie policies and no consent mechanism, which could pose regulatory risks under GDPR. The use of third-party analytics without clear user consent further impacts privacy posture. Overall, the security culture appears basic and would benefit from formalized policies and technical enhancements.

Recommendations

  1. Implement comprehensive privacy and cookie policies with explicit user consent mechanisms to ensure GDPR compliance.
  2. Add standard security headers (CSP, HSTS, X-Frame-Options, Referrer-Policy) to strengthen security posture.
  3. Enable DNSSEC on the domain to improve DNS security and prevent spoofing.
  4. Publish a security policy and incident response contact information to enhance transparency and trust.
  5. Regularly audit and update third-party scripts to mitigate potential vulnerabilities and privacy risks.
Site observations

Automated reading of the public site. Ratings are indicative.

Business

Company
Stichting Milieukeur (SMK)
Description
Publiek register voor nieuwbouwprojecten die voldoen aan de Regeling groenprojecten, beheerd door SMK, met als doel het faciliteren van Groenverklaringen voor duurzame bouwprojecten.
Key services
Registeren van nieuwbouwprojecten, Aanvragen en beheren van Groenverklaringen, Informatievoorziening over duurzame bouwprojecten
Content quality
good
Branding
consistent

Technology

Stack
jQuery, Foundation CSS Framework, Foundation Datepicker, DataTables, TinyMCE, Google Tag Manager, Goliath Analytics
Frameworks
Foundation
Performance
moderate
Mobile
good
Accessibility
basic
SEO
basic

Security

Observed score
65/100
Good practices seen
  • Use of HTTPS (implied by URL)
  • No exposed sensitive data in HTML
  • Secure form inputs (basic search form)

Analytics and tracking

Services
Google Tag Manager, Goliath Analytics
Tracking level
moderate
Privacy practices
poor

Advertising

Tracking pixels
Goliath Analytics
Marketing tools
Goliath Analytics
Transparency
basic

Site quality

Design
good
User experience
good
Content relevance
good
Navigation
good
Professionalism
good
Trustworthiness
high

Key observations

  1. Website is fully accessible with no blocking or WAF detected.
  2. No explicit privacy or cookie policy found on the site.
  3. Terms of service and disclaimer pages are present.
  4. Contact information is only available via a contact page, no direct emails or phone numbers found.
  5. Website uses multiple third-party analytics and tracking scripts without visible cookie consent mechanism.
  6. No security headers detected in provided data; DNSSEC not enabled.
  7. WHOIS data is transparent and consistent with business location and purpose.
  8. Website content is in Dutch and focused on sustainable building certifications.
  9. No social media links or direct company emails/phone numbers found in HTML content.
  10. Logo is present at /content/img/logo.png in header area.
Technical notes

Notes

The website uses a solid front-end technology stack with Foundation framework, jQuery, and DataTables, providing a responsive and interactive user experience. Analytics integration via Google Tag Manager and Goliath Analytics supports user behavior tracking but lacks visible privacy controls. The site appears moderately performant with no major technical debt visible in the HTML content. However, the absence of CMS identification and hosting provider details limits full infrastructure assessment. Opportunities exist to modernize security configurations and improve accessibility and SEO optimizations.
Standards and sources

Reference chips under each finding point to the standard, regulation or specification the finding relates to. They are taken from the official datasets below and mapped conservatively: a finding with no defensible link shows none. NIS2 and GDPR references mark where a finding is relevant evidence, not a compliance verdict. Implementing Regulation (EU) 2024/2690 binds digital infrastructure and digital service providers; for other entities it is the most detailed public reading of the Article 21 measures. WCAG, EN 301 549, European Accessibility Act and Web Accessibility Directive references name the requirement an automated accessibility rule relates to; they are not a conformance verdict.

Retrieved 2026-10-25

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