An allegation that an insurance claim contains incorrect information can have consequences beyond refusal of payment. The insurer may cancel cover, seek investigation costs or register information. Arslan Advocaten helps assess these decisions separately and prepare a response based on the actual documents.
From our Hague office, we discuss the policy, the investigation and what you want to achieve. Send the decision and any registration notice. State an approaching response date or urgent difficulty obtaining necessary insurance immediately.
070 450 03 00 · Request an appointment
Tell us immediately about any complaint, response or court deadline. An enquiry does not itself create an engagement or extend a deadline.
List every measure the insurer has taken
A single letter may refuse the claim, terminate the policy, demand costs and announce a registration. Create a separate entry for each measure, with its reason, effective date and consequences. The justification for one measure does not automatically establish the justification for every other measure.
Ask which evidence is relied on and whether an investigation report exists. A conclusion may be provided without showing which statement, photograph or discrepancy was decisive. Include earlier questions and answers so the context can be examined.
Distinguish an intended measure from a final decision. An invitation to respond before a decision is different from a definitive position. Note the response date and seek a reasonable opportunity to review the material if necessary. Requesting an extension does not mean it has been granted.
Not every CIS entry is a fraud registration
CIS contains different categories of information. An ordinary claim record, a termination entry and an external incident reference do not have identical purposes or effects. Calling every entry a “blacklist” can obscure the actual issue. Establish the type of record first.
You can request access to your information from Stichting CIS. The resulting overview identifies the participant responsible for a record. That party matters when seeking the background or a substantive correction. CIS explains correction requests.
Compare the overview with the insurer’s notice. Check names, dates, category and end date. If another insurer refuses an application, retain its explanation. This may demonstrate practical consequences, but it does not by itself prove that the original registration was unjustified.
Challenge the facts, grounds and duration separately
A response may concern inaccurate facts, insufficient supporting evidence or the proportionality and duration of a measure. Explain each separately. For factual objections, identify the document that supports the correction. A general denial may leave the insurer’s specific findings unanswered.
Even where some facts are undisputed, the purpose and severity of a registration can require assessment. Describe concrete effects, such as difficulties obtaining necessary cover, and attach the available correspondence. Not every adverse effect makes a registration unlawful, but the individual circumstances must be understood.
CIS states a maximum of eight years for an External Referral Register entry. That does not mean the maximum is automatically appropriate in every file. Its overview of registration types explains the categories. We assess possible correction, removal or reduction without promising an outcome in advance.
Answer investigation questions accurately
Separate what you personally observed from what someone told you and what you later inferred. If you cannot remember a detail, say so. A date or value reconstructed approximately should remain clearly identified as an estimate.
Read a written interview record before confirming it. If context is missing or an answer is inaccurate, identify the passage and provide a correction. Preserve the original and your response. A later clarification is easier to assess when the reason and date are clear.
Use authentic evidence. An internet photograph cannot establish that you owned an item or suffered particular damage. If a receipt is missing, identify genuine alternative records. Supplementing a file is different from creating or altering evidence. See our guide to a fraud allegation involving a motor claim.
Public judgment: internet photographs and an unsuccessful removal claim
In a public Hague case, a phone-damage notification used photographs from the internet instead of photographs of the insured device. The insurer refused cover, ended the insurance and entered registrations, including an EVR entry. This was not a case handled by our firm.
The insured sought removal in urgent proceedings, arguing among other things that employment opportunities could be affected. The court considered the indications of fraud sufficiently serious. Submission by the policyholder’s spouse was attributed to the policyholder, and the relatively small claim did not make the registration clearly disproportionate. The applications were dismissed.
The decision is dated 22 September 2026: Read the published judgment. The example illustrates the importance of authentic evidence and a considered response. It does not determine whether a different registration is justified.
Investigation costs and repayment demands
The insurer may seek money as well as refusing your claim. Ask for the legal basis, work performed and explanation of why the costs are attributed to you. A single total labelled “investigation costs” does not show the detail needed for assessment.
If earlier benefits are reclaimed, identify the relevant files and payments. Collect the original decisions and payment records. A dispute about one event does not automatically establish that every earlier claim was improper. Any alleged connection should be explained.
A payment request, collection letter and summons each require attention to their own content and deadline. Do not ignore a financial demand because you dispute the allegation of fraud. A registration objection and defence to a money claim may both be necessary. Any payment arrangement should clarify what is and is not being accepted.
Applying for new insurance while you object
A registration dispute can create practical problems when you need fresh cover. Keep the objection and the search for necessary insurance distinct. An ongoing complaint does not automatically compel another insurer to accept you.
Retain the exact questions and answers used in a new application. Do not state that a registration has been removed without confirmation. If a question about previous cancellation or claims is unclear, seek clarification and preserve the answer. Inaccurate information can create a new dispute.
Record the cover needed, refusals received and financial consequences. This may be relevant to urgency and your objection. It does not guarantee that urgent proceedings are available or that a new insurer must offer cover.
Non-disclosure when the original policy began
Pre-contract information is a different issue from the accuracy of a later claim. If the insurer alleges non-disclosure, obtain the application questions and original answers. What you knew at the time should be distinguished from later discoveries.
The Dutch Civil Code contains rules on disclosure and consequences, including Articles 7:928 to 7:930. Relevant questions can include the omitted information, acceptance position and alleged intent to mislead. The policy and any applicable mandatory protection also matter. A breach does not automatically justify every consequence.
Ask whether the insurer seeks a change in cover, cancellation, refusal of payment or another measure. The reasons and timing should be assessed for each. Our explanation of non-disclosure allegations provides further background.
A complaint should identify the result you need
State whether you want payment, restoration of the policy, correction of a record or withdrawal of a costs demand. Ask for a response to each issue. An answer about cover should not be mistaken for an answer about the registration as well.
For a possible Kifid route, check the service provider, subject, prior proceedings and deadlines against the eligibility requirements. Kifid is national; a Hague address does not determine access. Civil proceedings require a separate assessment of jurisdiction, evidence, cost and the requested remedy.
Your residential address alone does not always determine the competent court. Likewise, a binding Kifid outcome can affect the scope of a later challenge. Read the explanation of binding and non-binding decisions. Choose a route with its consequences in view.
Keep complaint periods and limitation under review
A registration response date, Kifid filing period and limitation of a payment claim are separate issues. Send the earliest report, every refusal and later communication. Do not assume that an insurer’s continued investigation indefinitely protects all claims.
Article 7:942 of the Dutch Civil Code sets a framework for insurance payment claims, including a three-year period and rules on written claims and unequivocal rejection. Liability insurance may involve different rules. Other claims, including those against an adviser, may need separate analysis.
Where a date is approaching, seek assessment before the entire evidence file is complete. Clarify who has accepted responsibility for the necessary action. Sending an enquiry or requesting access to records does not by itself extend a deadline.
Check every part of a settlement
A payment agreement may leave a registration, policy cancellation or costs demand in place unless those matters are addressed. Read the proposal as a whole and identify each issue it resolves. Otherwise, a practical problem can remain after the money dispute is settled.
Clarify what will happen to the relevant records, who must act and how completion will be confirmed. Do not rely on an informal assurance that everything will be dealt with. Final release can also affect other rights, so its scope requires attention.
We discuss whether additional evidence, negotiation or proceedings fit the case. No removal or payment can be guaranteed. The strength of the grounds, urgency and likely cost determine the sensible next step.
Your first assessment in The Hague
Our main Hague office is at Paletplein 80, 2526 GZ Den Haag. Call 070 450 03 00 to arrange an appointment. The firm also has a Hague office at Goeverneurlaan 445; confirm the appointment location when arranging your visit.
Provide the policy, refusal, registration notice and investigation material available. Prepare a timeline of reports, interviews and decisions, and identify the factual points you challenge. For several policies, make an overview per policy and case number.
The first assessment is free. Further work and funding are agreed before proceeding. Payment, registration and a money demand may require different tasks. We check conflicts before accepting the engagement. Tell us immediately about a summons, response date or imminent loss of necessary cover.
Frequently asked questions
Is every CIS record a fraud entry?
No. Different categories have different purposes and consequences. Obtain the record and identify its type and the party responsible before drawing conclusions.
Can an insurer register me simply because it refuses payment?
Refusal and registration are separate measures. Each needs assessment of the relevant grounds, evidence and circumstances.
Is an EVR entry always kept for eight years?
Eight years is the stated maximum. The appropriate duration and proportionality must be considered in the individual case.
Who should correct an inaccurate record?
Identify the insurer or participant that placed it. CIS provides access and information about correction procedures; the responsible party is central to the substantive decision.
Should I ignore a costs demand while challenging registration?
No. The financial claim may need a separate timely response. A registration objection does not automatically deal with collection or court proceedings.
Can I claim the registration is gone during a new application?
Only if that is accurate and confirmed. Answer new insurance questions carefully; inaccurate information can create another dispute.
Does a settlement automatically remove the registration?
Do not assume so. The written agreement should specify the registration, required action and confirmation, alongside any payment or policy issue.
How do I contact the Hague office?
Call 070 450 03 00. Our main office is at Paletplein 80, 2526 GZ Den Haag. Confirm the location when making an appointment.
Discuss your insurance dispute
Arslan Advocaten · The Hague
Paletplein 80, 2526 GZ Den Haag
070 450 03 00
Tell us immediately about any complaint, response or court deadline. An enquiry does not itself create an engagement or extend a deadline.
