What constitutes denial differs within each country, as do the laws. In the Netherlands for example, even slightly downplaying the significance of the events is considered denial and falls onder the discrimination laws (articles 137c en 137e). On the other hand, in France there is the Gayssot Act which makes it an offense to question the existence or size of the category of crimes against humanity as defined in the London Charter of 1945, on the basis of which Nazi leaders were convicted by the International Military Tribunal at Nuremberg in 1945-46 (art.9). As a final example, in Austria there's the National Socialism Prohibition Law (1947) which in 1992 was amended to prohibit, as stated, "denial or gross minimisation". Thus, the Dutch regulation of Holocaust denial is much stricter than the Austrian one, though punishments may be harsher in the latter country.

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