You apply for a mortgage and discover a negative BKR registration you knew nothing about (BKR is the Dutch central credit registration office). Should the lender have warned you first? There are rules on a prior warning before an arrears code is registered. If those rules were not complied with, that may be a reason to challenge the code. However, it depends on the type of registration and the evidence. The fact that you do not remember receiving a letter does not automatically mean that removal will follow.
Nederlands: Lees dit artikel in het Nederlands: BKR-registratie zonder waarschuwing: kunt u de registratie laten verwijderen?
Türkçe: Bu makaleyi Türkçe okuyun: Uyarı yapılmadan BKR kaydı: kaydı sildirebilir misiniz?
Responsible attorney: Onur Arslan, Arslan Advocaten. Content updated on 21 September 2026.
For which BKR registration is a warning required
First distinguish between registering a credit agreement, reporting payment arrears and adding a special code. These are different data items in BKR’s Central Credit Information System (CKI).
Article 39(2) of the General CKI Regulations contains the prior warning for an impending arrears report. The lender must point out, in good time and in writing, the consequences of further delay in payment. According to Article 13(4), no separate duty of advance notice applies to reporting a special code. An objection about a missing warning must therefore always be linked to the correct registration. See the General CKI Regulations.
The publicly available version on Mijn Kredietregistratie dates from 1 February 2024. For an older report, you need to check which version applied at the time. For this purpose, also consult the overview of the CKI Regulations.
What should you check on your BKR overview?
For each agreement, note the lender, contract details, codes and dates. A combination such as A2 contains an arrears indicator and a special code. The absence of a valid warning for the A code does not, without further assessment, mean that every other data item for that agreement is incorrect.
| Question | Why this matters |
|---|---|
| Are the arrears stated in the letter correct? | A report based on an incorrect amount or an incorrect date can be challenged |
| Did you actually receive the advance notice? | The lender must warn you in advance |
| Was the letter sent to your current address? | Sending it to an old address affects the question of whether you were warned |
| Did you pay before the announced reporting date? | In that case the report should not be made or should be corrected |
| Was a debt collection letter presented as a warning? | A debt collection letter is not the same as a BKR advance notice |
Also check whether the name of the current lender differs from that of the original provider. Where a claim has been assigned, older letters and system data may come from a predecessor. That requires a watertight reconstruction of the file. More explanation of the codes can be found under A, A2, A3, A4 and H codes.
What is the purpose of the advance notice?
The warning must still give you an opportunity to clear the arrears and prevent the arrears report. The advance notice is discussed, among other places, in Kifid 2024-0620 (Kifid is the Dutch Financial Services Complaints Tribunal). Therefore compare the date of sending, the opportunity to pay that was offered and the date on which the A code was actually reported. A message sent only after that report is not a prior warning for that earlier report.
Moreover, an ordinary payment reminder is not automatically an adequate BKR warning. Read whether the letter makes clear that further delay may have consequences for registration. The assessment concerns content and timing, not merely the heading of the letter.
Is a debt collection letter the same as a BKR warning?
A debt collection letter may demand payment, announce collection costs or refer to the credit being called in. That does not mean the letter also contains the required warning for an arrears report. A single letter can serve several purposes, but its wording must then actually support those purposes.
Put the letter next to the date and type of BKR report. Ask which part, according to the lender, constitutes the advance notice and how much opportunity to pay remained. A general reference to the existence of BKR in the credit terms is something different from a specific warning of an impending arrears report. Also check whether the letter relates to the correct agreement; if you have several credits, that difference may be decisive for your objection.
What if you paid before the announced BKR report?
Gather the proof of payment and check when the money reached the correct recipient. Note what amount, according to the warning, was needed to clear the arrears. A partial payment alone, or a promise to pay later, does not necessarily remove the announced consequence.
If you paid in full and on time, ask why an arrears report was nevertheless made. Send the warning and the payment together, so that the lender can check the timeline. Where payment was made to a debt collection agency, it may also be relevant how that payment was processed in the credit file. Ask for a detailed response if the lender maintains that arrears still existed on the reporting date.
What if you never received the letter?
Where receipt is disputed, it is not only relevant whether a letter was drawn up. Under the rules on receipt, it must be assessed whether it was sent to an address at which the sender could reasonably reach you and whether it arrived there. Circumstances that prevent a message from reaching you may also be at your risk.
In Kifid 2025-1043 the registration was upheld. The consumer had moved abroad and had not notified the lender of the change of address. In that case the lender was entitled to rely on the address previously provided. The argument that the consumer had not seen the letter was therefore insufficient.
If you did pass on your new address, gather the confirmation of that. Think of an email, a confirmation of the change or a dated screenshot from the customer portal. Registering at a new address with the municipality does not in itself mean that every lender has received that change.
Moved house and the BKR warning was sent to an old address
Draw up a timeline of your move, the change of address you notified and the warning. Proof that you notified the lender of the change in good time may result in a different situation than merely a new registration with the municipality. Also keep correspondence showing that the lender was already using the new address.
Where the data are contradictory, ask which address was in the system at the time of sending and how that was verified. An old address line on a sample letter that has been produced does not necessarily say everything about the actual sending; conversely, a current customer profile does not in itself prove which address was used at the time. Focus your objection on the data relating to the specific report. If you have moved several times, a chronological overview is often clearer than separate documents.
Which documents must the lender be able to show?
Ask for a copy of the advance notice and details showing when, how and to which address it was sent. Article 39(3) CKI refers to a copy or system printout as a way of demonstrating sending. The significance of such data depends on the file; a system entry must actually say something about the relevant message.
The absence of the original letter is not always decisive. In Kifid 2025-0282 Kifid considered a standard letter that had been produced, combined with a screenshot from the system, sufficient for the advance notice. The consumer had not further disputed the explanation afterwards either. The specific evidence, and your response to it, therefore matter.
In the case of a digital message, also ask for information about the content, when it was made available, the contact address used and any notifications. A reference to a digital customer portal does not in itself answer all questions. Have the arrangements on electronic communication and the technical data assessed together.
Which data are relevant for a digital advance notice?
For a warning sent by email or in a customer portal, you examine more than the date shown on a printout. Ask which message was sent, to which email address or account, whether a notification was sent and what data are available about delivery or access. Check the arrangements on how the lender communicates important messages to you.
The absence of a read receipt does not in itself prove that no valid warning was given. Nor does the existence of a digital system make every warning demonstrable. Compare this with your own data, for example a changed email address, notifications about a blocked account or an error message. Keep the original email where possible, because it may contain more sending details than a screenshot.
A phone financing agreement or private lease without a warning being received
A negative registration may also relate to handset credit or a private lease. Check on the BKR overview which agreement and which credit provider are listed. The trade name on your phone bill or lease contract is not always sufficient to establish who reported the credit data.
Request the agreement, an overview of the payment arrears and the warning that was used. With a phone subscription, keep the handset financing separate from other charges on the bill. With a lease, termination and a remaining claim may also raise separate questions. The fact that a bill is disputed does not automatically mean that any registration is prohibited. A proper assessment starts with establishing the obligation and the data item reported. See also BKR’s explanation of phone credit and private car leasing.
How do you build a targeted removal request?
A request becomes stronger if you do not merely deny that you were warned, but explain which part of the file is missing or incorrect. For example, use this order:
- Identify the agreement, the A code and the registration date to which your request relates.
- Ask for the warning, the sending details and the contact details used.
- Explain why you dispute that a timely, valid advance notice was given.
- Enclose evidence, such as a change of address or correspondence showing a different timeline.
- Ask for a reasoned decision on correction or removal and for an explanation of any remaining codes.
Keep the complete correspondence and proof that your request was received. If the lender sends new documents, respond to them on the merits. Check whether the standard letter actually related to your agreement and whether the date matches the system data. Do not draw conclusions based solely on a missing signature or the absence of registered post.
To whom should you submit your request
Usually start with the bank or lender that supplied the data in question. That party holds the credit file and the records of what was sent. You can also ask BKR for information about, and access to, your registration. The CKI Regulations also provide for GDPR requests to BKR; it is therefore too categorical to say that BKR itself can never deal with a request.
If in doubt about the responsible party, ask for confirmation. You can read more about building a file under an unjustified BKR registration.
What if the warning turns out to be valid?
A separate question may then still arise: is continuing the registration justified in light of all the circumstances? A technically correct registration is not the same as a registration that must remain in place under all circumstances. An appeal to your interests must, however, be substantiated concretely.
Describe, for example, what led to the arrears, how and when payment was made, what your finances look like now and what demonstrable disadvantage you are suffering. Merely repaying or merely wanting a mortgage is no guarantee of removal. Read more about BKR removal after repayment. If the lender rejects your request, read which next steps after a rejected BKR request are possible.
Example of a useful timeline where a warning is missing
Suppose that, according to the lender, a warning was sent on 4 March, you paid on 12 March and an A code was reported on 18 March. These dates are a fictitious example. You would then need to examine what amount was outstanding, what opportunity to pay the letter offered and when your payment was processed. The sequence alone does not yet prove that the report is incorrect.
Next to each date, place the corresponding document: warning, sending details, proof of payment and BKR overview. Add your change of address if receipt is in dispute. This produces a verifiable question for the lender. This method also helps where a claim has been assigned and data from the original provider and the current creditor need to be brought together.
Was the required warning sent?
Ask which report required a prior warning and on what date it was sent. Check the content, the address details and the available information on sending or receipt. A credit agreement containing general information is not automatically the same warning as a specific announcement of an arrears report.
The consequences of a missing or defective warning must be assessed according to the applicable regulations and the circumstances. Not every registration is subject to exactly the same prior obligation.
Also read about damage caused by an incorrect BKR registration.
Frequently asked questions
Must the BKR warning always be sent by registered post?
Do not assume so. The method of sending and the proof of receipt must be assessed. The absence of a registered letter is not in itself proof that the warning is invalid.
Will my debt lapse if the A code is removed
No. A decision about personal data is something different from a decision about the underlying payment obligation. Therefore discuss a dispute about the credit separately.
Can I wait before responding to a rejection?
First have the applicable procedural time limits assessed. For certain decisions on a GDPR request, a six-week time limit may apply to a petition under Article 35 of the Dutch GDPR Implementation Act (UAVG). Therefore keep the rejection and the date of receipt. See Article 35 UAVG.
Is every negative BKR code invalid without a prior letter?
No. The prior warning for an arrears report must be distinguished from the rules on special codes. With an A2 or A3 combination, therefore check each element separately. A defect in the A code does not automatically prove that all other credit data must disappear.
Is an ordinary reminder sufficient as a BKR warning?
That depends on the content and the timing. To serve this purpose, a reminder must clearly point out the impending arrears report and still leave a reasonable opportunity to pay. A mere request to pay an outstanding bill does not answer that question.
Can the lender prove that I received a letter without a signature?
The absence of your signature does not rule out proof. The available sending details, address details and other circumstances must be assessed together. Ask for the specific file; a general assertion that all letters are always sent is not the same as evidence about your warning.
Is a warning by email always invalid?
No. The method of communication, the arrangements and the evidence must be examined. Ask for the message, the contact details used and information about sending and delivery. With electronic communication too, it must be clear which warning reached you before the arrears report.
Can the lender remedy a missing warning afterwards?
A later letter does not automatically make the earlier report correct with retroactive effect. However, it must be examined separately whether a new report after a proper warning is possible. That depends, among other things, on the current payment arrears and the applicable registration conditions.
Must I keep to a payment arrangement while I am objecting?
An objection to your BKR registration does not automatically suspend your payment obligations. Keep to your arrangements and discuss a substantive dispute about the credit separately. New arrears may have consequences for your financial situation and for the assessment of your removal request.
Will I get money back straight away if the registration was made without a warning?
No. Correction or removal and compensation are separate questions. To obtain compensation, you must substantiate, among other things, the damage and its link with the unlawful registration. Keep evidence of additional costs and rejections, but do not assume a fixed amount of compensation.
Have the warning and registration assessed
Arslan Advocaten can assess your registration and the warning. Have your BKR overview, letters and any change of address to hand. Read more about removing a BKR registration or contact us.
