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Clarity in the funding of higher education


Based on the Helderheid in de bekostiging van het hoger onderwijs (Clarity in the funding of higher education) memorandum (dated 29 August 2003 and the supplement dated 27 August 2004), the Ministry of Education, Culture and Science asks for clarity regarding the following funding-related matters:

Public-private policy rule

On 14 April 2021, the Ministry of Education, Culture and Science provided further clarification on the conditions under which the university may invest public resources in private activities. With this clarification, theme 2 (investing public funds in private activities) of the Clarity memorandum was superseded; this also applies to De Handreiking voor de inrichting van onderwijskundige publiek-private arrangementen (The Guideline for the Organisation of Public-Private Educational Arrangements), published in 2011.

The conditions are:

  1. The private activity is in line with the funded legal duty.

  2. The private activity in which the investment is made provides added value for the funded legal duty.

  3. Structural overcapacity in the funded duty that is used for private purposes is temporary in nature.

  4. The investment is proportionate.

  5. The investment must not lead to unfair competition.

  6. A positive result on private activities in which public money has been invested leads to an increase in public equity.

  7. The investments are accounted for in the management report.

On 28 September 2021, the Ministry of Education, Culture and Science postponed this last requirement until the 2022 reporting year, which means that theme 2 of the Clarity memorandum still applies to reporting in the management report for 2021.

The university understands its private activities and appropriate procedures to manage them.


  • Radboud University did not outsource any registered training programmes to other organisations in 2021

  • Radboud University did not use any public funds to carry out private activities in 2021. No educational public-private partnerships were concluded. The private activities are partly incorporated under Radboud University Holding B.V., a full subsidiary. The activities of Radboud University Holding B.V. are partly the result of the statutory valorisation obligation. The university does not want to enter into new participating interests and shareholdings, and wants to reduce the existing ones, partly to limit the associated risks. The university uses other methods for valorisation, such as patents/patent rights and start-up loans in the context of the KERN regulation. The holding company also includes an internal secondment agency for students. The starting principle is that no facilities or activities based purely on commercial considerations will be realised.

  • Radboud University only grants exemptions at the request of the individual student. Exemptions are granted by the Examining Board. The grounds on which exemptions can be granted are laid out in the Education and Examination Regulations. Exemptions are registered in the student file.

  • Radboud University only enrols foreign students if they fully comply with the relevant legislation and regulations.

  • Radboud University does not take part in the PhD education experiment, the demand financing experiment, or the learning outcomes experiment.

  • There are no art education or customised programmes.

  • Enrolment procedures are in accordance with relevant laws and regulations. Radboud University does not spend any of the government funding on offsetting the tuition fees that students have paid. If a third party pays the tuition fees on behalf of a student, then that is explicitly stated in the authorisation issued by the student.

  • Students who only follow part of a programme are registered as contract students in accordance with the Contractcursisten aanschuifonderwijs (contract courses in advanced education) scheme that applies at Radboud University. Their data is not shared with DUO.

  • The students themselves register and enrol for one or more study programmes in Studielink, without any intervention from Radboud University. Radboud University does not enrol students for study programmes other than those for which they have registered.

  • Teacher training modules. In the 2021–2022 academic year, nine students enrolled in this at Radboud University, one more than in the 2020–2021 academic year.