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Terre des Hommes Netherlands welcomes the EU initiative to provide uniform standards for preventing gender-based violence, protecting victims and punishing offenders. We take note of the three proposed policy options. We strongly recommend pursuing and strengthening further the third policy option. Please find attached our feedback to the inception impact assessment.

The focus of the directive is to criminalise GBV. While this gives a strong signal that GBV is unacceptable in the European Union, it is an insufficient tool to combat violence and to protect victims, as the title of the draft directive promises. Criminalisation is not a solution that actually works, and it is not cost-efficient (see attachment). What does work and what is cost-efficient is prevention, i.e.

Tackling and preventing violence against women and their children must be a key strategic priority now and in the future, if the EU aims to improve the situation of crime victims, particularly in view of the ongoing COVID-19 pandemic.

Terre des Hommes Netherlands welcomes the initiative to revise EU legislation on victims’ rights to ensure a stronger, more holistic approach to ensure the rights of the victims of crime, including particularly vulnerable child victims.