An entry in the CIS-register can have major consequences. Think of not being able to take out insurance, being refused a mortgage, or problems when applying for financing. Many people only find out late that they are registered — often after a rejection, without a clear explanation.
In this blog we explain what the CIS-register is, when you can end up in it, what the consequences are and above all: what you can do if you are wrongly or for too long listed.
What is the CIS register?
The CIS register is managed by CIS Foundation (Central Information System). In this system, insurers share information with each other about (suspicions of) fraud, irregularities and other incidents.
The purpose of the CIS register is the prevention and combating of insurance fraud. In practice, this means that insurers warn each other about people or companies who, in their view, pose an increased risk.
When do you end up in the CIS register?
A registration in the CIS register usually arises in the following situations:
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A suspicion of insurance fraud
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Incorrect or incomplete information when taking out an insurance policy
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Conflicting statements in an insurance claim
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An insurance claim that, according to the insurer, does not add up
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Involvement in an incident that is classified as “irregular”
⚠️ Important:
A registration means not automatic that fraud has indeed been proven. In practice, we regularly see that people are registered based on suspicions or assumptions.
Which registers exist within CIS?
Within the CIS system there are several sub-registers, including:
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Incident Register
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Internal Referral Register (IVR)
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External Referral Register (EVR)
In particular an EVR registration is far-reaching, because it is visible to all affiliated insurers.
What are the consequences of a CIS registration?
The consequences can be far-reaching:
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Insurance policies are declined or terminated
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Premiums are increased substantially
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Mortgage applications stall
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Lease or financing applications are rejected
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Business insurance policies are difficult or impossible to obtain
Many clients only notice anything when they “suddenly” can no longer get insurance — without it being clear why.
How long does a CIS registration remain on record?
That varies by situation, but in practice we often see:
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3 to 8 years registration
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Sometimes even longer, without active reassessment
A registration is not automatically removed when the term has expired. Taking action is therefore often necessary.
When is a CIS registration unlawful?
A registration is not always permitted. It can be unlawful if:
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There is insufficient evidence for fraud
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The registration is disproportionate
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No hearing of both sides has taken place
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The balancing of interests is missing or incorrect
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The registration takes too long
Insurers are obliged to act with due care. If they do not, removal can be enforced.
What can you do about a CIS registration?
Step 1 – Request access
You have the right of access to your CIS data. This makes clear:
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why you are registered;
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in which register;
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for what duration.
Step 2 – Legal assessment
Assess whether the registration:
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is legally tenable;
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meets proportionality and due care;
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may remain in place.
Step 3 – Removal request or procedure
Is the registration unjustified or too severe? Then you can:
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a removal request be submitted;
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or a legal proceeding be initiated against the insurer.
Why legal assistance is crucial
Insurers have files, protocols, and legal departments. Without legal knowledge, you’ll quickly be 1-0 behind.
At Arslan Advocaten, we assess:
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whether the registration is lawful;
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which arguments are promising;
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how quickly removal can be enforced.
Our assistance is free of charge for clients, because in many cases the costs are recovered from the liable party.
CIS registration? Don’t wait too long
The longer a registration remains, the greater the damage — financially and personally. Early intervention significantly increases the chance of successful removal.
Need help with a CIS registration?
Are you dealing with a CIS registration or do you suspect that you are registered? If so, contact Arslan Advocaten. We will examine your situation carefully and explain clearly what you can expect and which steps you can take.
