If you want a BKR record corrected, start with one question: is the information factually wrong, or is it correct but disproportionately harmful in your circumstances? These are different routes, requiring different requests, evidence and assessments.
Written by Onur Arslan, lawyer at Arslan Advocaten. Onur Arslan has many years of experience with private-law disputes, including insurance-law and BKR-related disputes. Last updated: 2 October 2026. This article concerns Dutch law.
This page helps you choose a route. For retention after repayment, see BKR after repayment (Dutch); for the meaning of codes, see BKR codes (Dutch).
Correction or reconsideration?
| Issue | Correction or completion | Removal after balancing interests |
|---|---|---|
| When? | Wrong date, code or amount; missing end date or recovery notification | The data is accurate, but continued registration has a disproportionate effect |
| Legal basis | Article 16 GDPR and Article 29 CKI General Regulations | Erasure under Article 17 GDPR and Article 30b CKI; objection under Article 21 GDPR and Article 30 CKI |
| What to establish | Which facts are wrong and what the record should say | The specific disadvantage and changed circumstances |
| Evidence | Bank statements, closure confirmation and lender correspondence | Dated rejection, financing condition, income and current expenses |
| Assessment | Identify incorrect or incomplete data and the necessary correction | Assess whether continued processing is justified in your individual circumstances; no result is guaranteed |
Keep the routes separate. Mixing factual errors and proportionality in one argument obscures what the lender must decide. If both apply, use numbered sections: first correction, then an alternative request for reconsideration if the data proves correct. This makes each request and response identifiable.
Beyond correction and erasure: the right to object
The CKI General Regulations distinguish rights with different purposes:
- Rectification under Article 16 GDPR and Article 29 CKI concerns inaccurate or incomplete data, such as an incorrect date or missing recovery or actual end date.
- Objection under Article 21 GDPR and Article 30 CKI challenges processing because of your particular circumstances. The lender must assess the competing interests. You need not claim the data is false where your concern is its disproportionate current effect.
- Restriction under Article 18 GDPR and Article 30a CKI may be requested where its conditions are met, while accuracy is checked or an objection assessed. This may matter for an imminent credit application.
Objection and erasure are often combined: you object to processing and request deletion if that objection is justified. Identify the legal basis explicitly so the lender decides on the appropriate right and any refusal can be assessed on that basis.
Who should receive the request?
Address the lender that reported the entry. It determines the reported content and is responsible for that processing. Stichting BKR manages the system and does not substantively verify every item supplied by lenders.
You may also approach Stichting BKR. If you address a removal request to BKR, it can seek information from the lender, which must cooperate within the legal framework.
If an entry or part of it is deleted, BKR informs lenders to which it disclosed your data in the three months before your request, unless impossible or requiring disproportionate effort. This can matter where another application is pending.
Suggested request structure
Adapt this outline to your facts. Send it by email with acknowledgement or registered post, and keep a copy. Do not retain statements that are untrue for your case.
Subject: request to rectify, or alternatively remove, my CKI registration
Name, date of birth, address, contract number(s), dateDear Sir or Madam,
1. The entry. The CKI contains an entry in my name reported by [lender], contract [number], credit type [type], registration date [date], code [code] and actual end date [date or none].
2. Rectification. I believe the data is inaccurate or incomplete in the following respects: [for each item, state the current entry, correct information and reason]. I request correction and any necessary completion under Article 16 GDPR. I attach [numbered documents].
3. Alternatively, objection and removal. If you consider the data correct, I object to continued processing under Article 21 GDPR and request erasure under Article 17. My specific interest is [application rejected on date, attachment X; financing deadline, attachment Y]. My financial circumstances changed on [date] because [fact], supported by [attachment Z]. [Describe and evidence any current arrears or their absence.]
4. Information. Please also identify exactly what you reported, on which date and basis, and whether and when recovery was reported.
Please provide a reasoned written response within the statutory period.
Yours faithfully, [name and signature]
Response and next steps
| Stage | What happens | Your action |
|---|---|---|
| Request received | GDPR response periods apply: normally one month, with a possible two-month extension for complexity or volume | Record sending and receipt and keep evidence |
| No timely answer | The period expires without a substantive response | Send a reminder referring to the statutory period |
| Refusal | The lender explains its grounds | Distinguish disputed facts from a different balancing of interests |
| Complaint | Depending on provider and product: Kifid, the Private Lease Disputes Committee, the municipality for a Wgs record, or the Dutch Data Protection Authority | Check jurisdiction and applicable deadlines |
| Court | A request concerning your GDPR rights | Assess the appropriate court route; urgent interim proceedings may be needed for an approaching financing deadline |
Keep procedural routes distinct. Kifid deadlines differ from court deadlines for GDPR rights. Kifid gives a binding decision only if both you and the lender choose that; otherwise the decision is non-binding and the court can reassess your case in full. In the case of a binding decision, the court in principle only reviews whether the decision was reached carefully and is adequately reasoned. Make that choice consciously.
Response deadlines and court proceedings
Separate the institution’s deadline to respond from your deadline to challenge that response in court.
| Issue | Response | Court petition |
|---|---|---|
| Basis | Article 12(3) GDPR | Article 35 UAVG, the Dutch GDPR Implementation Act |
| Period | Without undue delay and within one month of receipt | Within six weeks of receiving the response |
| Extension | Up to two further months for complexity or number of requests; notice and reasons within the first month | No equivalent automatic extension |
| No response? | If taking no action, the institution must explain why within one month and inform you about supervisory and judicial remedies | If no response is given within the GDPR periods, filing is not subject to that six-week limit; the response-triggered period has not started |
Where a decision is taken by a non-administrative body, such as a bank or insurer, Article 35 UAVG permits a written request to the district court concerning rights under Articles 15–22 GDPR. The court assesses whether the request is well founded and whether to order the controller to give effect to it.
Record two dates: when you sent the request and when you received the answer. Receipt of the answer starts the six weeks. If there was no answer within the applicable period, document that too.
What makes a request persuasive?
- Specific facts. Explain each disputed entry, the correct information and the reason. The regulations require a concrete explanation for correction or deletion.
- Dates and documents. “My application was rejected on 3 June, see attachment 2” is more useful than a general assertion that a mortgage is unavailable.
- Current information. Explain whether the original problems have ended, with evidence of income, repayment and current obligations.
- Facts rather than pressure. An approaching deadline is relevant evidence. State the date and attach the document, rather than treating urgency as a guarantee.
- Realistic expectations. Wanting a mortgage does not automatically entitle you to removal. Accurate records must still comply with the GDPR; an individual assessment cannot be replaced by a promised outcome.
Assessment and costs
We begin with your report and supporting documents: technical accuracy, reported dates and the appropriate route. We can then prepare a request and, if necessary, pursue a complaint or court proceedings.
Fees are agreed in writing beforehand. Recovery of some costs from the other party may be possible depending on procedure and outcome, but cannot be promised. If you have legal expenses insurance, check cover first.
See BKR removal costs (Dutch). If you do not know the recorded details, first request your report (Dutch). For debt arrangements or statutory debt restructuring, see BKR after a debt arrangement or Wsnp.
Contact us without obligation and have your credit report available.
A, H and special codes
Arrears notifications, recovery notifications and special codes describe different events. A concerns arrears; H concerns recovery during an ongoing agreement. Codes 1–4 have individual meanings, such as an arrangement, acceleration, write-off or inability to contact the borrower. Check the whole combination and dates.
An A2 or A3 does not automatically disappear when you pay. Accuracy and the necessity of continued processing require separate assessment. Retention must be calculated from the appropriate event, not simply restarted on the day of your request. See removing an A2 code.
Phones, private lease, overdrafts and business credit
Not every monthly bill is registered credit. The product, amount and applicable rules matter. Personal liability can be relevant for business borrowing, but a company loan does not create the same personal record for everyone involved.
Ask which contract and obligation the entry concerns and who is recorded as debtor. A product label on a bank statement may be insufficient to establish the legal credit relationship.
Correction and reconsideration in one request
Identify whether you challenge factual accuracy or seek removal because of your circumstances. Include payment history, causes, current stability and specific interests. A standard letter referring only to a desired mortgage is weaker than an individual file.
The Supreme Court addressed the GDPR basis and balancing of interests in ECLI:NL:HR:2021:1814. This is not an automatic removal guarantee. Kifid and courts have separate jurisdictional and procedural requirements.
Choosing paid assistance
Ask what the provider actually investigates, which steps are included and what happens after refusal. Guaranteed deletion is not a substitute for legal assessment. If you want a lawyer to draft your request or conduct the proceedings, read about help with BKR removal from Arslan Advocaten. See also compensation for an incorrect record (Dutch) and Kifid or court (Dutch).
Frequently asked questions
Should I approach BKR or the lender?
Start with the reporting lender, which determines the reported content. BKR manages the system. You may also contact BKR, which can request information from the lender within the legal framework. Obtain your report first if the reporting party is unclear.
What can I do after refusal?
First identify whether the disagreement concerns facts or proportionality. Depending on the product and provider, assess Kifid, the Private Lease Disputes Committee, the municipality, the Data Protection Authority or the competent court. Check deadlines and the consequences of choosing binding Kifid advice.
Can an accurate record be removed?
Yes, if continued processing is not justified under the GDPR. This is not automatic. Articles 21 and 17 may support objection and erasure, subject to the applicable assessment. Provide specific disadvantage and evidence of changed circumstances, and keep those arguments distinct from factual correction.
How quickly must the lender reply?
Normally within one month of receipt, with a possible two-month extension for complexity or volume, notified within the first month. If no substantive response arrives, remind the lender and retain sending evidence. Separately monitor the six-week court period after receipt of an answer.
