This paper develops and applies a governance-centred legal-administrative framework to evaluate Dutch green subsidy schemes, focusing on the established Incentive Scheme for Sustainable Energy Production and Climate Transition (SDE++) and the forthcoming two-way Contract for Difference (CfD). It also discusses how these financial tools are situated within the European Union (EU) legal framework. Moving beyond cost-effectiveness and political-economy analyses, it offers a novel framework that operationalizes good governance through four observable indicators – policy design, administrative procedure, oversight and review, and stakeholder engagement – linking classic normative principles such as transparency, participation, accountability, and effectiveness to concrete features of subsidy practice. The paper further conceptualizes subsidy governance as not merely procedural but inherently strategic: the design and implementation of subsidy schemes determine both their domestic legitimacy and the Netherlands’ contribution to Europe’s strategic autonomy in a fragmenting geopolitical order. Drawing on Dutch administrative law, delegated instruments, and implementation practice, the paper finds that while SDE++ has mobilized large-scale renewable investment, its cost-based design and complex procedures favour established actors. The forthcoming CfD promises price stability but risks similar barriers without clearer rules, proportionate access, open data, and independent review. The paper suggests how embedding good governance principles more systematically would enhance the fairness, effectiveness, and legitimacy of Dutch green subsidies while reinforcing their coherence with Europe’s broader ambition of achieving strategic autonomy and a just energy transition.
Ruhela et al. (2026) studied this question.