Belgian coat of arms — L'union fait la force Amagi — first symbol of liberty

Handwerpen

On Surveillance, the State, and Belgian Life

The Road to Belgium

Handwerpen — Brussels, 2026


Drive out of Brussels on any arterial road and count. On the E40 toward Liège, on the R0 ring, on the approach roads through Jette and Molenbeek and Anderlecht. Count the gantries, the poles, the fixed cameras and the mobile units. Then ask yourself the question: what, precisely, are all of these for?

The answer, it turns out, is everything.

And therein lies the indictment.


I. A Foreword to Hayek

Hayek's Road to Serfdom was not a prediction about concentration camps. It was a structural argument about how free societies drift toward serfdom through mechanisms that are individually plausible, cumulatively catastrophic, and at each step institutionally endorsed.

The administrative state expands fuelled by the internal logic of problem-solving without limits: every problem requires a solution, every solution requires an instrument, every instrument requires justification, every justification generates new problems requiring new solutions.

The camera network of Belgium is a textbook case of this ratchet. It did not appear by decree. It accumulated, one purpose at a time, each step unremarkable, the totality never examined as a whole, the infrastructure always preceding the legal justification, and the legal justification always arriving to bless what already existed.

What follows is that examination — the one the Belgian parliament, press, and public have declined to conduct.


II. Chronology of the Creep

The timeline is not disputed. The comprehension, unfortunately, is lacking — and the consequences will arrive too late.

Before 2000 — the origin. Fixed-point speed cameras and early average-speed systems. The justification: measure speed, fine violators. The purpose was at least defined. The data transactional. Victimless conduct sanctioned with no specific victim. Millions of fines and euros extracted from their legitimate owners in the name of abstraction.

Early 2000s — the first expansion. ANPR cameras begin detecting stolen vehicles and checking freight compliance. A plate is captured, checked against a hot list, matches or it doesn't. Non-matching data retained — in direct conflict with data protection standards from the outset.

2008–2018 — the environmental parade. Brussels introduces its Low Emission Zone. Three hundred and fifty-three cameras installed across the Brussels-Capital Region, operating continuously, scanning every vehicle, twenty-four hours a day.

The state both incepts and exacerbates the problem it claims to solve. Designed barriers to entry: one-way streets, pro-bicycle policies that discriminate against commuters and workers already dispossessed of two-thirds of their earnings to feed the Gorgon. Communes favouring corrupt urban design — concrete mastodons rewarding affluent neighbourhoods with managed access while punishing others, those without connections at one of the eighteen mairies. An unfinished outer ring blocked for decades. An immigration policy that displaces the average Belgian into the suburbs and forces them to commute. Then the dystopian solution: cameras. Not at the points of entry. Everywhere.

Where Germany and France use less invasive means — windscreen badges, stickers — Belgium turns the camera on its subjects. The difference is not technical. It is a choice. A choice made by a class galvanised by the Bourgeois Bohème — the sons of the treacherous bourgeoisie, who privileged submission over freedom, and who imposed their guilt on everyone else's car.

2015–2016 — the fatality. Madrid. London. Stockholm. Cologne. Paris. Brussels. Islamic terrorism strikes European soil again. Within months, the federal government announces a national ANPR rollout. No parliamentary debate on architecture. No data protection impact assessment. No published necessity test. From the tyranny of terror to the tyranny of control. Civil society: accommodating, anaesthetised, indifferent, demoralised, absent. The corrupted elites, willing pillars to every Antigoon.

The terror justification was deployed exactly as the European Court of Human Rights had warned forty years earlier: states may not, in the name of the struggle against terrorism, adopt whatever measures they deem appropriate. Belgium did.

Klass v Germany (1978) — the surveillance limit ignored

ECtHR, Klass and Others v Germany, Application no. 5029/71, Judgment of 6 September 1978. The Court held that Contracting States "may not, in the name of the struggle against espionage and terrorism, adopt whatever measures they deem appropriate" and that the Court must be satisfied that "adequate and effective guarantees against abuse exist." The ruling is the foundational ECtHR authority on the limits of state surveillance. Belgium's post-2015 ANPR rollout was never subjected to this test.

2022–2025 — the endgame. Four thousand five hundred cameras, targeting ten thousand — spreading like a cancer. Then the decisive moment: the LEZ cameras are connected to the national police network. Four hundred and fifty cameras in Brussels, originally scoped for emissions checking, now providing live data and footage to all six Brussels police zones in real time. The purpose did not change on paper. The infrastructure was simply repurposed. The legal justification followed — enacted by all too willing politicians, civil servants, and magistrates.


III. The Anatomy of the Ratchet

The mechanism deserves precise naming: not through dramatic power grabs but through administrative accumulation.

Step one — justify via abstraction

Speed limits save lives. LEZ protects public health. Cameras fight terrorism. Each justification is real enough to preclude debate.

Step two — build infrastructure

The infrastructure, once built, has a cost that has been sunk and a capability that exists independent of the original justification.

Step three — connect it

Once multiple systems exist — LEZ cameras, speed cameras, ANPR — the efficiency argument for integration is overwhelming. Why maintain parallel databases when a single query could serve all purposes?

Step four — expand it

Each new use is measured not against a blank slate but against the already-existing infrastructure. The question is no longer "is this surveillance justified?" but "are there additional uses we could make of what we already have?" The necessity test — which requires asking whether the purpose could be achieved without the instrument — is never applied, because the instrument already exists. The expanded network justifies further expansion. Gaps in coverage become visible, and the logic of the network demands their elimination.


IV. The Regulatory Fiction

At each stage of expansion, propaganda assured citizens that data protection law provided meaningful protection. The assurance was substantially false.

The Belgian Data Protection Authority exists and can impose fines. The Flemish Supervisory Commission — the VTC — has issued substantive criticisms of camera deployment practice. But the gap between formal protection and practical reality is cavernous. Municipalities deploy cameras before establishing a legal basis. Purposes are defined after deployment. The same camera is attributed different purposes depending on which authority answers the citizen's inquiry. The police say one thing. The municipality says another. Neither is binding.

As for anonymisation — the assurance most frequently offered — it is a category error presented as a legal guarantee. A licence plate is not anonymous. It is directly linked to an identified owner. The face captured alongside it is biometric data, the highest protection category under GDPR. The movement profile built from plate captures across time and geography is, as the Court of Justice has recognised, more invasive than any single datum. What the authorities call anonymisation is access restriction. The distinction matters: access controls change — governments change, laws change, emergencies redefine what is authorised — while true anonymisation is permanent.

Be assured: tomorrow, only your designated jailers will access your stored data.

Regulatory dependency — VTC, DPA, and the fiction of independence

VTC (Vlaamse Toezichtcommissie voor de verwerking van persoonsgegevens): established by Flemish Decree of 18 July 2008, amended 2018. Structurally dependent on the Flemish Parliament and government it is mandated to oversee. Its 2022 and 2023 advisory opinions on ANPR deployment explicitly noted that municipalities routinely implement camera systems before establishing a legal basis — a finding that has produced no mandatory corrective mechanism. Annual reports: toezichtcommissie.be.

Belgian Data Protection Authority (GBA/APD): established by Law of 3 December 2017. Formally independent; structurally compromised. The GBA board is appointed by the Chamber of Representatives on proposal of the government, and its budget is determined by the legislature whose executive it supervises. In March 2026 the GBA issued a reprimand against a municipality for ANPR violations — the first such decision after years of documented non-compliance.

GDPR Art. 35: Data Protection Impact Assessments are mandatory for "systematic monitoring of a publicly accessible area on a large scale." The post-2015 ANPR rollout self-evidently meets this threshold. No DPIA was published before deployment. The Belgian DPA's 2021 opinion on ANPR noted the absence and described it as a serious procedural deficiency.


V. Feuerbach's Line

The detailed legal analysis is developed in the companion piece Against the Wig: Feuerbach's Line. The conclusion stated here: each declared purpose fails the necessity test when examined against the Feuerbachian principle — an identifiable victim, demonstrable harm, no consent, no less invasive alternative available.

Average speed enforcement. Compliance confirmed, record deleted. Instead: every passage logged, timestamped, geolocated, retained. The enforcement purpose is served by the measurement. The surveillance architecture serves something else.

LEZ compliance. Germany and France demonstrate that emissions can be verified without permanent camera networks. Belgium chose cameras over stickers. Under the necessity test, when a less invasive instrument would serve the purpose, the choice of the more invasive one is itself the violation.

Stolen vehicles. Insurance companies recover stolen vehicles through telematics, immobilisers, and VIN checks. The marginal contribution of population-wide ANPR to vehicle recovery has never been published. It should be the first question asked. It has not been asked.

Terrorism and organised crime. Security cannot justify whatever measures the state deems appropriate. The question is not whether terrorism is a serious threat. It is whether surveilling the entire population's movements is a proportionate and necessary response to a threat that, by definition, involves a minute fraction of that population. The answer is no. It has always been no.

Belgian public discourse focuses almost entirely on what the cameras catch. It does not focus on what they cost — and not primarily in euros. Drivers lose their licences. Not because they drove dangerously. Not because they endangered anyone. Because a camera recorded a speed that exceeded a statistical threshold at a particular moment. A life project is disrupted. A job is lost. A family's mobility is destroyed. These are real, identifiable harms inflicted by the state on identifiable persons, in the name of statistical risk.

The Feuerbach test reversed: identifiable harm imposed upon identifiable individuals in the name of statistical abstractions, with no relation to actual victims. Speed enforcement revenue in Belgium runs to hundreds of millions of euros annually. The regulators themselves had to explicitly rule out the financial motive as a legitimate justification — which tells you everything about why the ruling was necessary.


VI. The Democratic Deficit

The camera network was never voted on. Not its architecture. Not its integration. Not its purposes. Not its targets.

Individual Royal Decrees authorised specific deployments. Parliamentary questions were answered with technical specifics. The VTC issued recommendations that were noted and not acted on. The Belgian DPA found violations and issued reprimands. None of this constitutes democratic oversight of a decision to build infrastructure that tracks the movements of every person who drives in Belgium.

This is the Hayekian mechanism applied to surveillance: the administrative state makes decisions of fundamental constitutional significance through processes that are formally legal and substantively undemocratic. The decision to surveil an entire population is not made by parliament in a named vote. It is assembled from dozens of ministerial orders, technical specifications, procurement decisions, and database integration projects — none of which individually appears to warrant democratic deliberation, the cumulative effect of which is a surveillance apparatus that no democratic majority ever explicitly endorsed.

The independence of the regulatory bodies is a related fiction. The VTC oversees Flemish public bodies but is structurally dependent on the Flemish government whose bodies it supervises. The federal DPA operates within a legal framework written by the parliament whose executive it is supposed to constrain. These are not independent checks. They are internal audits with limited authority and no enforcement mechanism that the surveilled population can directly invoke.

Absence of parliamentary approval — references

Royal Decree of 26 November 2020 (ANPR@GPI): the primary legal basis for the federal ANPR network. Adopted under Article 108 of the Constitution — the royal decree power — without prior parliamentary authorisation of the network architecture, purposes, or data retention regime. Published in the Belgisch Staatsblad / Moniteur belge, 11 December 2020. No prior data protection impact assessment was published.

Parliamentary questions on ANPR (Chamber of Representatives, Questions écrites / Schriftelijke vragen): multiple written questions filed between 2020 and 2024 on ANPR deployment, data retention, and costs. Answers from successive Ministers of Interior confirmed deployment figures but provided no cost-benefit analysis, no necessity assessment, and no comparative analysis of less invasive alternatives. References: Q. no. 55031441C (2022); Q. no. 55033892C (2023) — available at lachambre.be / dekamer.be.

Council of State (Raad van State / Conseil d'État): the Council reviewed the legal basis of the ANPR Royal Decree and noted concerns about proportionality and the scope of authorised purposes. Its advisory opinion was non-binding. The decree was adopted without modification of the elements the Council flagged.

CJEU, Joined Cases C-293/12 and C-594/12, Digital Rights Ireland (2014): the Court struck down the EU Data Retention Directive as disproportionate, holding that "generalised and indiscriminate retention" of traffic and location data of all persons without distinction is incompatible with the Charter of Fundamental Rights. Belgian ANPR retention practices have never been subjected to this test in full. The parallel with the invalidated Directive is direct.


VII. The Alternative That Was Never Tried

There is a solution to the actual problems the cameras are deployed to address. It does not require cameras. It requires property rights, liability, and price signals.

Price the externalities: fuel taxes that reflect actual health costs, congestion pricing that charges for road use rather than monitoring compliance. Private road ownership aligns the incentives of users and owners — those liable for accidents on their infrastructure, those who want repeat customers. The evidence on private toll roads is consistent: better maintained, better safety records, no incentive to criminalise statistical membership in risk categories. Insurance companies recover stolen vehicles through telematics and immobilisers — contractual, consensual instruments leaving no population-wide movement database behind.

In each case the market mechanism — property rights clearly assigned, externalities priced, liability enforced, consent respected — would produce better outcomes without the surveillance infrastructure. The cameras were chosen not because they were necessary but because they were convenient for an administrative class that prefers control to price signals and compliance to freedom.


VIII. The Indictment

The Belgian state has built, over twenty-five years, a movement surveillance infrastructure covering its entire driving population. It did so without democratic mandate, without published necessity assessments, without genuine regulatory independence, and without honest accounting of costs against benefits.

The cameras are not a crime in the technical sense. They are something more troubling: they are what happens when a society allows the form of law to persist after its substance has been abandoned, and then congratulates itself on its legal sophistication.

Count the cameras on the E40. Then consider what it means that no one in a position of authority has ever been required to explain, in public, before a representative body, with access to the full data, whether the sum of what they have built is compatible with a free society.

It is not a difficult question.

It is simply one that has not been asked.

It is not.

Against the Wig: Feuerbach's Line — the legal foundation

Against Privilege — on the legal class and the denial of the essence of law