A forged payslip submitted with a mortgage or credit application can lead to rejection, termination of an account or credit and an EVR registration in the External Reference Register. The bank must, however, sufficiently substantiate what is incorrect and what involvement you had in it. It must then assess separately whether external registration and the chosen duration are proportionate. The fact that no loan was paid out does not automatically rule out registration for an attempt.
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Written by Onur Arslan, attorney at Arslan Advocaten. Registered in the Netherlands Bar’s register of practice areas for employment law and personal injury. Last updated: 17 September 2026.
Do you dispute that you altered a document or knowingly used it? Then request the original application file and the specific discrepancies. If an adviser or another third party submitted documents, the origin and transfer of those documents are essential. A careful file distinguishes between a mistake, deliberate deception and the personal consequences of registration.
Why banks examine income documents
With a mortgage or loan, the lender must assess whether credit can responsibly be granted. Income data play an important role in this. A payslip, employer’s statement or other source of income must therefore be reliable and consistent with the other data.
A discrepancy can have various causes. Think of an administrative correction, a draft document, the wrong month or a genuinely manipulated amount. The bank may ask for an explanation and source documents. Not every discrepancy is thereby proven fraud, but it may justify a targeted investigation.
Ask what exactly the bank has established. Does it concern the amount, the employer, the employment relationship, the layout or an inconsistency with payment data? A general statement that a document “is not right” is often not clear enough to allow a substantive response.
Which consequences can arise side by side?
| Measure | Separate question |
|---|---|
| Rejection of the application | May the bank refuse the credit on the basis of the data |
| Calling in existing credit | Is there a valid contractual and statutory ground |
| EVR or incident registration | Are the factual basis, involvement and proportionality sufficient |
| Internal registration | Which internal purpose, scope and duration apply |
| BKR special note | Which credit event has been registered and is it correct |
| Police report or damages claim | Which criminal or civil legal basis is being relied on |
An objection to one measure does not automatically cancel the others. If you only request removal of the EVR entry, a letter calling in a loan may in the meantime have consequences of its own. For each decision, therefore, keep track of the date, the reason, the action requested and any deadline.
What must the bank prove for EVR inclusion?
PIFI, the Dutch financial institutions’ incident warning protocol, sets requirements regarding the conduct, sufficiently established involvement and the proportionality of external registration. For criminal personal data, a higher factual standard applies. A bank cannot confine itself to a vague suspicion without substantiating the relevant circumstances.
On the other hand, a criminal conviction is not required in every case. The bank may proceed to registration on the basis of a sufficiently concrete set of facts. For example, the content of the document, your communications and verification with the source may together be relevant.
PIFI 2026 has applied since 1 April 2026. For older applications or registrations, it must be established which version applies to inclusion and continuation. An old template objection may therefore not fit the current file adequately.
A mistake in a document is not always deliberate deception
A payroll department may correct an error, or an employer may issue an unclear statement. Ask the original source for a written explanation and the correct version. Keep both documents and the dates on which they were provided, so that the change remains verifiable.
It is a different matter when data are deliberately altered to suggest a higher income or a different employment relationship. Knowingly using a document forged by someone else may also be relevant. The question is therefore not only who made a change on a computer, but also what the applicant knew and did.
Do not alter files afterwards to make the application appear consistent. Correct an incorrect answer transparently and add the source data. A clear explanation of a genuine mistake is easier to assess than a series of new versions whose origin can no longer be established.
If a mortgage adviser submitted the documents
Ask the adviser for the complete communications and the exact file sent to the bank. Compare it with the document you supplied yourself. Keep e-mails with attachments in their original form and note who had access at what time.
The involvement of an adviser does not automatically release you from responsibility for information you knew to be incorrect. Conversely, the bank may not assume without investigation that every change was made by you or knowingly used by you. The specific transfer and knowledge are decisive.
If the adviser made a mistake of their own, a liability question may also arise. That assessment stands alongside the objection to the bank registration. For this, read about the liability of the mortgage adviser.
If the employer provided incorrect data
An employer’s statement may differ from payslips or bank credits. Ask the employer to explain the cause in writing. A difference may, for example, relate to a correction or a variable component, but this must be apparent from verifiable data.
Make sure the explanation addresses the bank’s specific question. A general statement that you “are indeed employed” does not always answer a dispute about the contract term, salary or the date on which a document was drawn up. Relevant source documents must support the data stated.
If you knew that the employer was giving incorrect information and used it anyway, the legal outcome may be different. Be complete about the course of events. An objection is not helped by pointing to a third party without discussing what you yourself knew or confirmed.
No payout does not automatically mean no incident
A bank may discover a misleading application before any money is advanced. The absence of an actual payout does not in itself rule out conduct that threatens the interests or integrity of the financial sector. A sufficiently substantiated attempt may also be relevant under PIFI.
The nature of the application, the consequences and the stage at which the bank intervened may, however, play a role in balancing the interests. Ask how the bank weighed those circumstances. A general reference to the maximum conceivable risk is not the same as individual reasoning for the duration.
Also keep the distinction from damages in view. The fact that an incident may justify registration does not automatically prove that every amount claimed by the bank is owed. Examine costs, legal basis and causation separately.
What recent Kifid rulings show
In Kifid 2026-0711 (Kifid is the Dutch Financial Services Complaints Tribunal), the use of a forged payslip in a credit application had been admitted. The bank had already shortened the duration. The committee saw no ground in the circumstances put forward for a further reduction. A general wish to buy a home had not been substantiated in sufficiently concrete terms.
In Kifid 2026-0345, external registrations and a separate BKR code were assessed. The case shows that a fraud investigation can have consequences for existing credit and that several registers must be examined side by side.
These rulings concern credit applications with their own facts. They do not provide a standard outcome for every mortgage case. What matters are the established conduct, admission or dispute, the specific interests and the reasoning for each measure.
Eight years is a maximum, not a fixed penalty
External registration is intended as a warning and a means of risk management, not as a criminal penalty imposed by the bank. PIFI sets a maximum period and rules on the term. The bank must give reasons why the chosen duration is necessary and proportionate in your case.
Circumstances such as seriousness, preparation, repetition, knowledge and attitude after discovery may be relevant. The adverse consequences and the passage of time also count. Admitting a mistake can be a factor, but does not give an automatic right to a certain number of years’ reduction.
Ask not only why inclusion is said to be justified, but also why a shorter registration would be insufficient. A decision may be adequately reasoned on the first point and still be open to debate on the second. An alternative request for a reduction can therefore be useful.
Making a housing interest concrete
An EVR entry can make a mortgage application more difficult. Substantiate whether the registration is actually the obstacle and whether financing would appear feasible on other points without that registration. A statement from an adviser and a specific rejection can help with this.
Also describe why the move is necessary. A general wish to live in a larger home may carry different weight from demonstrably unsuitable housing. Let the documents clarify the situation without pretending that every housing wish automatically outweighs the interest served by the warning.
Do not enter into purchase obligations in the expectation that removal is certain to succeed. An approaching contract date makes the file urgent, but does not in itself change the substantive assessment. Make sure that the financing condition and legal steps are coordinated in good time.
A fictitious example of document origin
An applicant sends his original payslip to an intermediary. The bank later receives a file showing a higher salary. The applicant denies any knowledge of the change. A useful investigation compares the original attachment, sending times, messages and the file actually received by the bank.
If the documents confirm that the applicant supplied the correct document and had no knowledge of the change, that is relevant to his involvement. If, on the other hand, messages show that he proposed or approved the higher amount, the assessment may be different. The presence of an intermediary therefore does not automatically decide the matter in one direction.
A summary such as “the adviser arranged everything” is therefore too limited. The file must show who provided which information, which questions were asked and which answers were confirmed. This makes the discussion about involvement factual and verifiable.
Which documents should you keep?
- The application and the exact document about which the bank has questions.
- Original payslips, employer’s statements and relevant salary credits.
- E-mails and messages with the employer, adviser or other parties involved.
- The bank’s questions, your answers and confirmations of conversations.
- All decisions regarding the EVR, the incident register, the Internal Reference Register (IVR), BKR and termination of credit.
- Documents on specific consequences and your current personal circumstances.
Keep the original files; make a separate, organised copy for handling the matter. Do not remove unfavourable messages from the timeline. If a criminal investigation is looming, have a lawyer assess how relevant documents and statements should be handled in the various procedures.
Responding to questions from the security department
First read the specific questions and the deadline given. Ask for clarification if the bank does not state which document or which discrepancy it means. If you need more time for source documents, request an extension with reasons before the deadline and supply the information already available.
Answer truthfully and distinguish your own observations from information from others. If you do not know who altered a file, say so and explain what information you have requested. A suspicion about a third party should not be presented as an established fact.
Where criminal consequences are possible, it is wise to obtain legal advice beforehand. The way in which you answer a question from the bank may also become relevant outside the registration procedure. Being careful does not mean hiding documents; it means that facts, rights and consequences are considered together.
An objection with primary and alternative grounds
If you dispute involvement, put that first, with specific supporting documents. Ask the bank which facts underlie the inclusion and why your explanation is considered insufficient. Then address, to the extent necessary, the proportionality of inclusion and duration.
You can request a reduction in the alternative without thereby admitting the facts you primarily dispute. State this explicitly. Ask for a separate decision for each register and measure, so that a favourable response on one element is not confused with full restoration.
An objection should also state which practical result is needed: removal, a shorter duration, correction of incorrect data or restoration of services. Not every result follows automatically from another. A removed EVR entry, for example, does not in itself reopen a mortgage application that was previously rejected.
Deadlines, Kifid and the courts
For GDPR requests, a response period of one month applies in principle, with a possible extension for which reasons must be given. After a refusal, a period of six weeks may apply for the special application procedure under Article 35 of the Dutch GDPR Implementation Act (UAVG). Have that deadline assessed immediately.
A consumer may, under certain conditions, turn to Kifid if the institution is affiliated and the complaint falls within its rules. In urgent cases, where you act in a different capacity or where a specific procedural question arises, the court may be the appropriate forum. Choosing binding advice has consequences for later review.
Criminal proceedings or a complaint against the adviser do not automatically preserve deadlines against the bank. Therefore draw up an overview of decisions, opposing parties and deadlines. This allows a coherent approach to be chosen without any important element being left unaddressed.
A corrected document does not yet explain the earlier document
A new employer’s statement can remedy an administrative error. The bank will, however, also want to understand why the earlier document contained different information. Keep both versions, therefore, and ask the author to explain which data were wrong, how that happened and when the correction was made. A statement that merely says the latest version is correct may leave the origin of the discrepancy unresolved.
Do not alter original files and do not delete messages about how they were supplied. A clear document history can help determine whether there was a mistake, a misunderstanding about variable income or a deliberately altered representation. If someone else drew up the document, describe what checks you carried out yourself and what you knew at the time.
Remain precise about your knowledge. A statement that you never saw the document is different from saying that you did forward it but did not notice a particular error. That distinction can be important for the assessment of involvement. A legally substantiated objection must be based on the actual facts, even when those facts are uncomfortable for you.
Frequently asked questions about false income documents and the EVR
Can an ordinary administrative error lead to an EVR entry?
A discrepancy does not automatically justify external registration. The bank must sufficiently substantiate the relevant facts and involvement and assess proportionality. In the case of a genuine administrative error, provide verifiable source information and a clear explanation.
Am I always responsible if my adviser submitted the document?
That does not follow solely from the fact of submission. Examine what you supplied, knew and confirmed. Knowingly using a document altered by someone else may also be relevant. The chain of transfer of the files is therefore important.
Can the bank register me if the mortgage was never paid out?
The absence of a payout does not automatically rule out registration. A sufficiently substantiated attempt at deception may fall within the conditions of the protocol. The circumstances and consequences do, however, remain relevant to the separate proportionality test.
Will the data disappear if I apologise?
Not automatically. Admission and attitude may be taken into account, but do not by themselves determine the outcome. The bank must also assess seriousness, the passage of time and specific interests. There is no standard reduction.
Can my existing loan also be called in?
The bank may attempt this, but it requires a separate contractual and statutory assessment. A registration letter is not the same as a valid demand for repayment. Check the conditions, the reason and the consequences, including any BKR code.
What help does Arslan Advocaten offer?
Arslan Advocaten can assess the document investigation, the involvement, the registration period and related measures. Send us the original documents and the complete correspondence. Where criminal law issues or an impending mortgage deadline are involved, the approach is tailored accordingly; costs are discussed in advance.
Further reading on this topic
Sources and legal basis
- Dutch Banking Association (NVB) on PIFI 2026.
- PIFI 2026, the Dutch financial institutions’ incident warning protocol (Protocol Incidentenwaarschuwingssysteem Financiële Instellingen 2026).
- Kifid 2026-0711 on a forged payslip and the registration period.
- Kifid 2026-0345 on external registrations and a separate BKR code.
- Supreme Court of the Netherlands (Hoge Raad), 15 September 2023, on GDPR proceedings.
Sources checked on 16 September 2026. A factual discrepancy in a document, knowing involvement and the proportionality of each measure must be assessed separately.
