Statecraft

08 · Symptom

Performative maturity

Why more code, more supervision and more compliance worsen the dissociation rather than heal it

May 2026 · by Jacob Huibers · Lees in het Nederlands →

Jacob Huibers — Statecraft, May 2026

Symptom paper IV in the series Dissociated Organisations

Context for readers outside the Netherlands

A brief primer on Dutch institutions and codes is useful before reading the paper proper.

Code Good Public Administration (Code Goed Openbaar Bestuur), 2009, is a non-binding statement of administrative principles drafted under the Ministry of the Interior. CODIO (Code Goed Digitaal Openbaar Bestuur), 2021, extends those principles to digital governance.

Code of Conduct Integrity Central Government (Gedragscode Integriteit Rijk), 2019, sets behavioural norms for civil servants at central level. VNG model codes, 2021, are model codes published by the Association of Dutch Municipalities for political office-holders and civil servants.

Act on the Promotion of Integrity and Functioning of Decentralised Government (Wet bevorderen integriteit en functioneren decentraal bestuur), in force from 2022, and the Whistleblower Protection Act (Wet bescherming klokkenluiders), in force from February 2023, provide statutory anchoring of integrity arrangements at municipal and central level.

Open Government Act (Wet open overheid, WOO), May 2022, is the Dutch freedom-of-information regime, comparable to the UK FOIA but with a phased rollout to 2029.

Audit Service of Central Government (Auditdienst Rijk, ADR) is the internal audit service of central government, operating within the Ministry of Finance. It certifies the financial audits used by the Court of Audit (Algemene Rekenkamer), the constitutionally independent national audit office.

Inspectorate Justice and Security (Inspectie Justitie en Veiligheid) is one of several departmental inspectorates that supervise specific public-sector domains.

Roemer norm and WNT — the 2010 cap on hourly rates for external hire, and the Public Sector Senior Officials (Standards for Remuneration) Act, both intended to constrain external hire and senior pay.

The folder and the dossier

Anyone who begins as an interim executive at a Dutch executive organisation receives in the first week a folder for signature. The integrity declaration, the code of conduct, the manual on reports of unwanted behaviour, the secondary employment regulation, the information security declaration, the privacy statement of the employer, the conflict-of-interest declaration, sometimes also a separate declaration on gifts and invitations. In a municipality of one hundred and fifty thousand inhabitants where I came in some years ago as a cluster director, the folder counted eleven documents. The signing took fifteen minutes. The bundle went into a digital filing cabinet of which I did not know whether it was ever again consulted.

In the second week of the same assignment, a dossier landed on my desk that was not formally meant for me. A team leader who over five years had produced an accumulation of complaints about the way he dealt with staff, with the common features that the complaints were filed anonymously, that the trusted person had handled them in good consultation with HR, that none of the reports had been formally escalated to the integrity reporting point, that the personnel file mentioned nothing relevant, and that the team leader had in the meantime been positively appraised twice and promoted once. The dossier reached my desk through the detour of a department head who herself was leaving and for whom the topic of departure was not the same as what she wanted to leave behind as her last act of trust. What she told me fell formally under none of the eleven documents I had signed in week one. What she told me was something none of the processes covered by those documents had made visible, and that was meanwhile damaging the organisation from the inside.

What this example shows is what this paper addresses. The folder works. The integrity arrangement works. The trusted person works. The reporting point works. The personnel file works. Each of the instruments does what it is supposed to do. And what the instruments do not see remains invisible until someone, outside all the instruments, passes it to a departing colleague in a conversation. That is no failure of the arrangements. It is what arrangements do when they take the place of the judgement for which they were once an aid.

The cycle

In the introduction to this series I set out in one sentence the thesis this paper develops: more supervision, more code and more compliance worsen the dissociation rather than heal it.1 That thesis sounds provocative, and it is meant to push against the dominant response of administrative Netherlands of the past decade. To every fundamental administrative crisis the response has been the same. The benefits scandal produced a new code of conduct, an extension of the Whistleblower Protection Act and an upgrading of the position of the Inspectorate for Taxes, Benefits and Customs. Groningen produced an Institute for Mining Damage and a new State Supervisor. Schiphol-nitrogen and grid congestion produce coordinating bodies, frontrunner programmes, an integral assessment framework and a national programme. At municipal level, integrity affairs involving aldermen produce the Act on the Promotion of Integrity and Functioning of Decentralised Government, and beneath it the model codes of the Association of Dutch Municipalities.2 At central level, every generation produces its own version of what was called the Code Good Public Administration in 2009 and the Code Good Digital Public Administration (CODIO) in 2021.3

The pattern is unambiguous. Scandal, then code, then supervisory framework, then inspection framework, then compliance function, then training programme, then disclosure requirement. Each layer adds something to the exterior of the apparatus. None of the layers replaces the substantive judgement that was missing in the original crisis. The previous layer is rarely withdrawn. The new layer lands on top. Whoever places a twenty-year-old integrity arrangement of a municipality alongside its 2025 version sees not a simplification. She sees a sequence of expansions, with as common thread that each new shell formally covers something the previous shell did not materially solve.

One of the architects of the 2009 Code Good Public Administration, Meine Henk Klijnsma at the Ministry of the Interior, gave in 2025 a diagnosis of his own work that is usable for this paper.4 He described how the code had been intended as an instrument for reflection. It should be an occasion for the conversation about good administration, not a norm against which organisations would be tested. That conversation, in his own words, disappeared after the first launch of the agenda — including at the Ministry of the Interior itself. What took its place was integrity policy more tightly shaped through rules and training trajectories. He called this the spirit of the present time, a harder time in which criminal law is never far away. What he describes here is precisely the shift this paper addresses. An instrument intended for substantive reflection is replaced by an instrument for compliance, and the substantive reflection disappears at the second site even faster than it disappeared at the first.

The catalogue

A municipality or executive organisation of any size in 2026 works under the simultaneous operation of a substantial number of codes and arrangements. The General Administrative Law Act and the general principles of good administration provide the legal foundation. The Code Good Public Administration (2009) and CODIO (2021) provide informal value frameworks. The Code of Conduct Integrity Central Government (Government Gazette 2019) and the VNG model codes for political office-holders and civil servants (2021) provide the behavioural-normative layer. The Act on the Promotion of Integrity and Functioning of Decentralised Government (2021/2022) and the Whistleblower Protection Act (February 2023) provide the statutory anchoring. The Open Government Act (May 2022, phased to 2029) provides the transparency regime. The General Data Protection Regulation and the Police Data Act provide the information regime. Sectoral codes provide professional norms, and at the level of interim management, the codes of the various professional associations and the disciplinary regulations of the IM-Register cumulate.5

Alongside these documents stands an institutional architecture. The Audit Service of Central Government (ADR) certifies annually around ninety-five per cent of the financial audits the Court of Audit uses, and provides on-request research to the administrative and political leadership under which it itself sits.6 Departmental inspectorates operate under their own statute and with their own framework. Every major executive organisation has an internal audit function or equivalent. At municipal level, most municipalities have an audit chamber or audit committee, a works council with extensive co-decision rights, a trusted person, an integrity reporting point, sometimes an ombudsman function. For the political-administrative triangle there is the triangle mayor–prosecutor–police chief with its own consultation and accountability structures.

What stands out in this enumeration is not its length but the absence of convergence. None of the instruments displaces the others. They all run alongside each other. A gemeentesecretaris who in 2026 receives an integrity matter must operate four or five regulations simultaneously, with procedural rules that overlap and reporting obligations that in practice are only aligned after an incident has occurred. For the line manager beneath her the instrumentation is in fact impenetrable. For the staff member who is considering reporting something, the threshold is not the absence of a channel but the presence of too many channels, none of which reliably show what becomes of the report.

Here a pattern becomes visible that returns in the other papers in this series. The architecture of the instrument is in order. The substantive function for which the instrument was originally built is thinned out. The apparatus holds onto what it was instructed to hold onto. It no longer sees what it was instructed to see.

What compliance cannot do

Michael Power described in 1997, in The Audit Society, how the desire for verifiable accountability in modern states leads ever more activity to fold itself into the demands of what can be audited.7 What does not lend itself to audit disappears from view. What does lend itself to audit acquires the predicate “managed”. The relationship between the predicate and reality becomes diffuse. Power described this as a sociological outcome, not malicious intent. An organisation surrounded by audit and code develops its own mechanisms to serve that audit and code, which then develop separately from its primary work. Those mechanisms acquire their own specialists, their own language, their own career lines. At some point they form their own column within the organisation. Just as reputation in paper I developed into an architectural layer, compliance develops into a comparable layer.

Nils Brunsson described in 1989 a related dynamic under the name “organised hypocrisy”.8 Organisations with conflicting demands (legitimacy outwards, executability inwards, support upwards, support downwards) develop decoupled layers of talk, decision and action. What the organisation says is consistent with the external demands. What it decides is consistent with the executable approach. What it does is consistent with actual practice. The three layers no longer flow into one another. The organisation becomes functional as long as the decoupling is stable. Brunsson’s analysis was not primarily critical. He described how organisations with conflicting expectations can survive. But his frame helps to see that the increase of codes and arrangements is not intended to lift this decoupling. It enables and stabilises it.

For John Meyer and Brian Rowan, formal structures in modern organisations were primarily a ceremony with which organisations reproduced their legitimacy, decoupled from their actual work.9 An organisation that adopts a code of conduct signals to its environment that it is mature and meets the spirit of the times. Whether the code of conduct shapes its actual behaviour is another question. For the signalling, that question need not be answered. For the organisation itself, the signalling is often enough.

These three anchorings, taken together, supply a sufficient theoretical frame to understand this symptom. Performative maturity is what arises when an institutional architecture once built to carry substantive weight is reshaped into a ceremonial layer that secures external legitimacy without the substantive function it grew out of. The environment accepts it as evidence of maturity. The organisation gives that acceptance back by visibly maintaining it. The substantive work happens elsewhere, or no longer happens. What characterises a dissociated organisation is precisely that this state is stable. No one inside or outside it feels reason to change it.

Two illustrations

It is tempting to bring up the childcare benefits scandal or Groningen here. Both are widely documented, and both show the pattern. But precisely because they have been worked through so extensively, their illustrative power for this paper is limited. Two less visible examples show the mechanism more sharply.

The first concerns the Audit Service of Central Government itself, the body that formally serves as the independent internal auditor of central government. In 2020 the European Commission wrote to the Netherlands that it could only partially rely on the ADR’s controls of the implementation of European agricultural subsidies, because the ADR announced controls in advance, took along inspectors of the food and consumer products authority on re-inspections, and dropped established errors from the final report.10 The Court of Audit raised question marks in 2022 about the independence and quality of ADR controls. An evaluation by the University of Amsterdam recommended that the ADR be less sensitive to feedback from principals, and signalled that principals exert pressure on the formulation of findings — sometimes also to suspend or postpone investigation. In 2025 the Minister of Finance chose not to place the ADR with the Court of Audit but to intensify cooperation. In January 2026 the House of Representatives nonetheless voted, by a motion, to transfer the certifying audit of the ADR to the Court of Audit.11

What this example shows is not that the ADR does poor work. The ADR’s work is professional, in line with professional rules, and produces real insight. What it shows is that an internal auditor operating within the department it tests, and dependent on the principalship of the parties it must control, cannot meet the function for which the outside world reads it as evidence of maturity. Ninety-five per cent of the Court of Audit’s financial audits leans on ADR work. The Court builds on a foundation that has been grey territory for twenty years. The external observer sees a complete control architecture. The internal practice is that the architecture functions structurally incompletely, and that strengthening it is repeatedly deferred. Between the two faces runs a gap that the apparatus of compliance cannot bridge.

The second example concerns the Inspectorate Justice and Security. In 2021 the ADR established that at this inspectorate there was an appearance of impermissible influencing of reports.12 Research questions were partly drafted by the organisations under supervision. Conclusions in reports were changed or reformulated on suggestion of those organisations. Conclusions were softened by the Inspectorate’s own leadership. The influence of external advisers was not transparent. The ADR judged that it had not established interventions that could be determined to be impermissible, but that influencing did seem to be present. What this example shows is that even the Inspectorate function — on paper the heaviest internal supervisory form in central government — is in practice dependent on what the supervised organisations are willing to deliver and on how its own leadership is willing to stand up for that. The Inspectorate is a link. The organisations under supervision are links. The chain produces reports. Whether the chain at any given moment corrects the evident error in a research question depends not on the inspection function but on who has the courage to speak outside it.

Both examples show what compliance cannot do. It cannot create the place where substance weighs more than procedure. It can design a procedure within which substance is supposed to weigh, and it can report whether the procedure has been followed. Whether the substance has actually been weighed it cannot verify without itself being the place where that weighing happens. And precisely that is what compliance, as an architectural layer, no longer does.

What this does to the other symptoms

In the introductory paper of this series four symptoms were identified.13 Performative maturity is not a stand-alone symptom. It connects with the other three, and it is useful to make those connections explicit.

The reputation architecture, described in the first symptom paper, supplies the apparatus that makes compliance materially possible.14 A code of conduct on its own does little. A code of conduct supported by a communications department that makes it visible on the intranet, a training function that obliges its annual delivery to staff, and a governance advisor who incorporates it in the alderman’s review process, acquires institutional presence. The reputation architecture and the compliance architecture reinforce one another. The first delivers the visibility, the second the framework. Together they deliver what the outside world reads as maturity and what within the organisation further marginalises the substantive column.

The reproduction inwards, the second symptom, arises in part in the wake of the compliance architecture.15 A senior official who rotates every four years learns in her first post the instrumentation of her department, not the substance of its policy. In her second post the same curve repeats. By the time she is director-general she masters several instrumentations and no single substantive dossier in depth. The system teaches her that this is the correct competence. Compliance lends itself par excellence to rotation. It is similar enough everywhere to be quickly learned, and specific enough to seem to carry weight. For substantive work the relation is the inverse: it must be built up over years to acquire weight. Whoever knows compliance as her main column finds in the substantive column a foreign tongue.

The absorbed debt without integration, the third symptom, arises in part because the response to a recovery operation is reflexively cast in compliance terms.16 A childcare benefits scandal is answered with a Recovery Operation Act, a commission of wise persons, an ombudsman function, a separate executive organisation. Those answers are not wrong. They are often only insufficient, and they themselves produce a new layer whose execution shows over time patterns comparable to the original execution. The Tax Authority’s benefits service entered into the error under heavy compliance dressing. The recovery operation stands under still tighter compliance dressing. Whoever looks at the difference sees more shells, not more integration of what caused the original error.

Read together the four symptoms reinforce one another. The reputation architecture produces the visibility under which compliance is adopted. Compliance produces the framework under which the substantive column further thins. Substantive thinning brings rotation within reach and makes mentoring within a dossier institutionally unfeasible. And the whole produces recovery operations that absorb the original error without integrating it. It is a closed cycle. Performative maturity is its exterior.

What would work

What does not work here is more code. That is no sceptical position but an observation from a decade of practice. Whoever wishes to shape the response to a new crisis through expansion of the existing compliance arsenal adds a shell to precisely the structure that did not see the crisis. The question is no longer whether one or another code is better. The question is how the chain can again acquire places where substance can land. That is a design question, not a regulatory one.

Three design choices are not in themselves revolutionary, but cut against current practice. The first is the cleaning-up of the existing instrumentation before new policy is added. When a municipality hears of a new integrity matter and the alderman proposes drafting a new code, the first question should be which existing code lapses with it. That sounds bookkeeperly. It is precisely what does not happen in practice. Dutch governing practice has, since 2009, hardly removed a single code of conduct from any organisation. It has added countless. Whoever wants more room for substantive weight must do that by demanding less, not by adding more. Cleaning up need not be legislation. A gemeentesecretaris or secretary-general who within her own organisation only accepts a new arrangement if an old one lapses, performs in her own sphere already considerable de-cluttering.

The second is the separation of the substantive judgement function from the compliance function. An evident error in a dossier should not be established by the department that watches over the procedural rule, but by someone with substantive weight in the primary process. Whoever combines both roles ends up over time with only procedural-rule monitoring and no substantive judgement. At large executive organisations this principle is now scarce. The interim executive I named in my opening received the dossier from her predecessor not via the integrity reporting point and not via the trusted person. Both existed; both had operated; both had produced nothing. It came in via a voluntary handover in a farewell conversation. That type of place — where substantive weight is transferred apart from procedural rule — is in every organisation scarce and in every organisation necessary.

The third is the statutory requirement of direct source access for supervision where this supervision performs an external role. That holds for the Court of Audit relative to central-government execution. It holds for local audit chambers relative to municipal execution. It holds for parliamentary inquiries relative to the apparatus they investigate. In the introductory paper of this series I named this principle as a design choice, and here it touches the compliance architecture directly.17 A supervisor dependent on reports pre-processed by the supervised organisation is no supervisor. She is a new link in the same chain. Direct source access breaks this dependency not by imposing more compliance, but by ceasing to accept a specific part of the compliance architecture as a necessary intermediate station. This is an Aiki movement in the sense in which the forthcoming book uses that word: the self-interest of the supervised organisation is neither denied nor forced, but redirected through a design in which the incentive to withhold information becomes less rewarding than the incentive to deliver it on time.18

What none of these three choices requires is a new act or a new code. The instrumentation to carry them through is in all cases already available. What they require is a different weight in daily decision-making. The current reflex is that a new matter must lead to a new arrangement. The administrative courage consists of the opposite: taking a new matter as occasion to look critically at an existing arrangement before it is replaced by a heavier variant of itself.

For interim management practice

For the interim executive or project lead, performative maturity is the substrate of her assignment. She receives in week one the folder I described in the opening. She is in week two confronted with dossiers she would not have reached via the folder. She makes in her final report the choice whether she writes about the inversion at the level of processes or at the level of the chain behind it.

Two disciplines help. The first is, in the Strategic Triangle, at every diagnosis to distinguish explicitly which type of tension is at play.19 An execution problem with sufficient support and clear goals is operational. A well-functioning execution apparatus without an adequate compliance architecture seems a legitimacy problem but is in fact a design problem. An organisation with full compliance but stuck in execution is not a legitimacy problem. It has too much legitimacy-oriented architecture and too little operational capacity. The difference between these diagnoses determines what type of intervention can be delivered. Whoever does not make the difference delivers an intervention that worsens the symptoms rather than removing them.

The second is, in the handover phase of the assignment, to test explicitly what is anchored and what depends on the instrumentation. An interim assignment closed with a new code of conduct, a new protocol and a new reporting arrangement, and in this way intending to establish transfer value, is an assignment that has served performative maturity.20 An assignment closed with a re-design of the place where substantive weight in the organisation lands, even if that re-design is less visible in a formal dossier, is an assignment that has worked at the cause. The difference is for a principal often hard to read. For the organisation itself, two years later, it is visible in where the problems the interim did not see again did or did not become visible.

The open question

The introductory paper closed with a question about what recovery means if the norm towards which recovery directs itself has itself shifted.21 For the symptom of this paper a related question can be asked. Performative maturity is, unlike the other three symptoms, adopted by the system as evidence of its own improvement. The childcare benefits scandal did not only fail the system. It also justified the system in tightening itself in a specific direction. Every new code, every new arrangement, every new inspection function is presented as improvement, and is also read as such by press, politics and public. Whoever argues that these improvements worsen the problem argues something against the current of felt progress.

Whether it is possible, in a political-administrative climate that after every crisis demands more compliance, to organise a counter-movement that demands less compliance and more substantive weight, I do not know. What I suspect, and cannot prove, is that this only becomes thinkable when a specific crisis arises that cannot be solved through more compliance and in which the shortage of substantive weight is itself the scandal. Whether that pattern compels response or whether the pattern adapts itself to the new crisis by reformulating it in compliance terms is an empirical question that cannot be answered in advance. What can in the meantime be done is, at the scale of the own organisation, to deliver the design where the place for substance is regained. That is what this paper formulates as the action perspective. It is not the recovery of the system. It is the recovery of a place where the system can still be corrected.

Colophon

“Performative maturity” is the fourth symptom paper in the Statecraft series Dissociated Organisations. The series builds on Navigating versus Planning, the paper on vacation real estate and the invisible policy, the paper on scarcity, and the architecture of silence. The introductory paper Dissociated Organisations appeared in April 2026. The symptom papers I (The reputation architecture), II (The reproduction inwards) and III (The absorbed debt without integration) appeared earlier in 2026. The closing synthesis is foreseen for 2027.

Statecraft is the platform of Jacob Huibers for strategic reflection on public-service delivery. The content connects to the forthcoming book The Direction of Movement: Interim Management in the Public Sector (autumn 2026).

Response and counter-argument via Statecraft.

Jacob Huibers is an interim manager with more than twenty years’ experience in the Dutch public sector. He has worked as cluster manager, cluster director and project lead for municipalities ranging from fifty thousand to over two hundred thousand inhabitants and for regional inter-municipal partnerships.

Footnotes

  1. Jacob Huibers, Dissociated organisations: Why evident errors no longer land, and what that asks of public restoration, Statecraft, April 2026, section “Connection as intervention”. ↩

  2. Act on the Promotion of Integrity and Functioning of Decentralised Government, Stb. 2021, 565, phased into force in 2022 and 2023; Whistleblower Protection Act, Stb. 2023, 28, in force from 18 February 2023. ↩

  3. Ministry of the Interior and Kingdom Relations, Dutch Code of Good Public Administration: Principles of sound government, June 2009; Utrecht University (USBO) on commission from the Ministry of the Interior, Code Good Digital Public Administration (CODIO), presented to the House of Representatives 10 June 2021. ↩

  4. Meine Henk Klijnsma, in interview with Audit Magazine, April 2025. Klijnsma was head of Constitutional Affairs at the Ministry of the Interior in 2008–2009 and a member of the working group, chaired by Andrée van Es, that prepared the code. ↩

  5. For a workable inventory of the cumulative character of these codes for interim practice see The Direction of Movement: Interim Management in the Public Sector (forthcoming autumn 2026), chapter 4. ↩

  6. Court of Audit, Central government in execution: findings and considerations on the ADR function, May 2025; Letter from the Minister of Finance to the House of Representatives on the positioning of the Audit Service of Central Government, April 2025. ↩

  7. Michael Power, The Audit Society: Rituals of Verification, Oxford University Press, 1997. ↩

  8. Nils Brunsson, The Organization of Hypocrisy: Talk, Decisions and Actions in Organizations, John Wiley & Sons, 1989; revised edition Copenhagen Business School Press, 2002. ↩

  9. John Meyer and Brian Rowan, “Institutionalized Organizations: Formal Structure as Myth and Ceremony”, American Journal of Sociology 83 (1977), 340–363. ↩

  10. European Commission to the Netherlands, letter 2020, obtained via the Open Government Act; published by Follow the Money, “Government accountant concealed errors in fraud check on farmers”, December 2024. Court of Audit, 2021 Accountability Investigation and supplementary report 2022. ↩

  11. House of Representatives, motion of 20 January 2026 on consolidating certifying audit at the Court of Audit; Transition plan ADR – Court of Audit, in preparation at the Ministry of Finance, scheduled to reach parliament in summer 2026. ↩

  12. Audit Service of Central Government, Investigation into the working method of the Inspectorate Justice and Security, March 2021. ↩

  13. Huibers (2026), section “What comes next”. ↩

  14. Jacob Huibers, The reputation architecture, symptom paper I in the series Dissociated Organisations, Statecraft, April 2026. ↩

  15. Symptom paper II, The reproduction inwards, in preparation for publication 2026. ↩

  16. Symptom paper III, The absorbed debt without integration, in preparation for publication 2026. For the financial dimension see also Recovery State Netherlands Position Paper, Statecraft, March 2026. ↩

  17. Huibers (2026), section “Connection as intervention”, sub-item “direct source access for supervision”. ↩

  18. For the Aiki method as design principle rather than intervention technique see The Direction of Movement, chapter 10. ↩

  19. Mark H. Moore, Creating Public Value: Strategic Management in Government, Harvard University Press, 1995. For the Dutch application see The Direction of Movement, chapter 3, and the Statecraft publication Navigating versus Planning (April 2026). ↩

  20. For the concept of transfer value see The Direction of Movement, chapter 9. ↩

  21. Huibers (2026), section “The open question”. ↩