Dispute with a bank or credit provider

A blocked account, a terminated banking relationship or a loan that has been called in can have an immediate impact on your income, your home or your business. Arslan Advocaten helps assess and deal with disputes with banks and credit providers. We examine the reason for the measure, your evidence and the appropriate next step: a targeted response, a complaint, negotiation or proceedings.

In an urgent case, clarity about deadlines and essential payments comes first. In a damages claim, the central question is which obligation was breached and what loss resulted from it. An unfavourable decision by a bank is not automatically unlawful, but it must be tested against the applicable rules and your circumstances.

What is your dispute about

Several problems can arise together. A Wwft investigation can lead to termination and an internal registration. A disputed credit application can have consequences for an existing loan. We therefore map out all decisions and the outcomes you want, so that no important part is left out of view.

Wwft investigation and questions about your money

Banks must carry out customer due diligence to prevent money laundering and terrorist financing. They may ask about identity, activities and the origin of money. A check is not automatically an accusation of a criminal offence, but insufficient answers can have consequences for the services you receive.

A useful answer links each relevant flow of money to an explanation and the available source documents. Think of agreements, statements of account and payment trails. A large number of loose documents without explanation can actually raise new questions. We help assess which information really answers the question.

At the same time, a request for information must be relevant and appropriate. If questions are unclear or documents are not reasonably available, a targeted explanation or an alternative may be needed. Read how to answer Wwft questions from your bank.

Bank account blocked or frozen

A block can have various causes, such as security measures, an investigation, an attachment or another legal impediment. The first step is to establish which measure applies and which functions are affected. Are you unable to make transfers, is only a card blocked, or is the entire balance unavailable?

Where the consequences are urgent, we gather evidence of essential payments, such as housing costs or business obligations. We then examine whether the bank can explain, limit or lift the block. A request for a temporary practical solution can be made alongside an objection on the merits.

A block imposed by the bank is not the same as an attachment by a bailiff. The legal basis and the opposing party may differ. Read the steps for a blocked bank account and, where relevant, the separate article on attachment of a bank account.

The bank terminates your account

In the event of termination, contractual powers, statutory obligations and circumstances must be examined. What reason does the bank give? Which questions preceded it? Was a reasonable notice period used and were the consequences taken into account? A general reference to policy is not sufficient in every case.

Sometimes customer due diligence that could not be completed obliges the bank to end the relationship. In other situations there may be a dispute about the factual basis or about due care. The answer depends on the file. We therefore assess both the substantiation and the options for supplementing information or requesting another arrangement.

For private account holders, the article on the bank terminating your account describes the main steps. A complaint does not automatically suspend the closing date. If a deadline is approaching, ask in good time for an assessment of the action required.

Business account for entrepreneurs and the self-employed

Without a business account, invoicing, salaries and day-to-day operations can grind to a halt. A bank has freedom of contract and integrity obligations, but its role in society may, in certain circumstances, also entail obligations towards businesses. The Supreme Court has confirmed that this assessment is not relevant only to private customers.

For entrepreneurs, a concrete business file is important: activities, ownership structure, expected transactions, flows of money and alternative account options. A sector with increased risks does not by itself mean that every individual application must be treated in the same way.

A consumer’s right to a basic payment account cannot simply be used for business payments. Read the separate explanation about a refused or terminated business account. We examine the product requested and the concrete need.

No account any more and a basic payment account needed

A consumer may, under certain conditions, be entitled to a statutory basic payment account. The bank must test the application against the specific statutory grounds. A regular banking package, a statutory basic payment account and a basic bank account under a covenant are different arrangements.

An EVR or internal listing is not in itself a separate statutory ground for refusing the basic payment account. The underlying facts may, however, be relevant, for example if necessary customer due diligence cannot be completed. An individual assessment therefore remains necessary.

We can help establish which application was made and whether the right rules were applied. The article on a refused basic payment account sets out the conditions, supporting documents and next steps.

Your credit called in or terminated

A letter in which the entire loan is called in can create great financial pressure. Examine the contractual basis, any arrears, the prior communication and the protection that applies. A disagreement with the bank does not automatically make the debt due and payable, but a valid demand for repayment must not be ignored either.

We also assess the consequences for securities, a payment arrangement and BKR. If a claim is disputed, it must be clear which amount and which ground are in dispute. Where a debt is partly correct, a practical arrangement can be explored alongside an objection on the merits.

Read more about a bank or credit provider suddenly calling in your loan. For problems between a private lender and borrower, or about a joint loan, the overview loans, credit and BKR offers further routes.

Irresponsible lending and unaffordable repayments

Within the applicable rules, a credit provider must examine whether credit is responsible. Where there may have been an error, we look at the data and standards at the time the credit was granted or amended. Later unemployment or payment problems do not automatically prove that the original assessment was careless.

Relevant factors include income, existing outgoings, other debts and foreseeable future changes. The application form and the original calculation are therefore essential. It must then be established what loss any error has caused.

The explanation of irresponsible lending and the bank’s duty of care develops this subject further. A claim cannot simply be quantified as all the interest or the entire loan; that requires a proper comparison of the loss.

Interest and costs that are not right

A dispute may concern the interest rate applied, unclear powers to change terms, fees or collection costs. We compare the agreement, the information provided when it was concluded and the amounts actually charged. A higher rate is not automatically unlawful, but it must rest on a valid basis.

With variable interest, the interpretation of the agreement and relevant case law can be important. With costs, it must be examined which service or event justifies the item. A specified overview helps limit the dispute to amounts that can be checked.

Read the in-depth page on unjustified interest and costs on a loan. Keep old statements and terms and conditions; current product information is not always enough to assess an earlier period.

Bank helpdesk fraud and unauthorised payments

After payment fraud, reporting quickly is important to secure access and limit further loss. For reimbursement, it must be established who gave the payment orders. The use of a code or technically correct authentication does not in itself prove that you consented to the specific payment.

For unauthorised payments a special statutory refund scheme applies, with exceptions. For transfers you carried out yourself, the assessment may be different. Kifid’s Appeals Committee clarified this distinction in 2026.

We examine the timeline, technical data, communication and the ground for rejection. The article on bank helpdesk fraud and compensation also deals with the duty of care and any goodwill payment. No route gives guaranteed reimbursement without an examination of the file.

BKR and internal or external registrations

A BKR credit registration must be distinguished from the EVR (External Referral Register), the IVR, the incident register and an internal Wwft-related registration such as CAAML. The reason, the consequences and the conditions for removal differ. We first map out which data are actually being processed.

With BKR, the issue may be technical accuracy, an incorrect end date or an individual balancing of interests. With the EVR, strict requirements apply as to involvement and proportionality. A maximum duration is not an automatic standard for every file. The consequences of several registrations together may also be relevant.

For further assessment you can read about removing a BKR listing, removing an EVR listing and CAAML after a Wwft investigation. Each measure gets its own request and its own monitoring of time limits.

Mortgage advice and investment losses

In an advice dispute, the engagement is central. What information had to be investigated, what warning was needed and what work had been agreed? A missed financing deadline or an application that was not submitted can have different consequences from a product choice that turns out less favourable in hindsight.

In investing, we distinguish between execution only, advice and asset management. Normal price losses are not automatically recoverable. A claim requires a concrete failure and a realistic comparison with the situation had due care been exercised.

Read the separate routes for liability of a mortgage adviser and investment losses. For a dispute with an insurer, we refer you to insurance law.

How do we assess your file?

We start with the bank’s letter, the agreement and a short timeline. We then map out the outcome you want: restoration of the account, continuation of services, correction of data, a settlement or compensation. These goals do not always call for the same procedure.

We then examine the relevant obligations and the evidence. Which documents are missing? Which facts are disputed? What can be resolved with a targeted addition? We identify strong and weak points, so that you can make a balanced choice.

In an urgent case, we first look at what action is needed to preserve rights or practical options. Where there is loss, separate substantiation of the amount and causation follows. We do not start from the assumption that every error justifies the full compensation claimed.

Kifid or the court

A consumer can often use Kifid against an affiliated financial services provider, provided the dispute falls within the rules and time limits. The internal complaints procedure usually comes first. A binding decision can later be reviewed by the court only to a limited extent.

For entrepreneurs, Kifid is not available for every bank dispute. A route for certain small business financing does not mean that every business payment account or fraud claim falls under it. With cross-border services, jurisdiction, the applicable law and the correct opposing party must also be examined.

The court may be appropriate in an urgent case, for a specific GDPR (AVG) procedure or for another substantive choice. We discuss costs and litigation risks. A complaint or negotiation does not automatically safeguard statutory time limits; monitoring time limits is therefore part of assessing the file.

What you can gather in advance

• The bank’s latest decision and any deadline it mentions.
• The agreement and applicable terms and conditions, including relevant older versions.
• Your earlier questions, answers and complaints and the responses received.
• Bank statements or transactions directly related to the dispute.
• Evidence of concrete consequences, such as essential payments or rejections.
• A short description of the outcome you want to achieve.

At first contact, do not send an unnecessary full copy of your identity document, security codes or passwords. We discuss which documents are needed and how they can be provided appropriately. An organised, limited start is often enough to determine the first follow-up question.

Costs and an appropriate approach

We discuss the work, the costs and possible next steps in advance. A first assessment of the file, a letter and proceedings differ in scope. External experts and litigation costs may also play a role. You get clarity about what is being proposed for your case.

Subsidised legal aid may be possible in certain cases, depending on factors such as income, assets, the interest at stake and the type of case. This is assessed separately and is not available for every financial or business dispute. Legal expenses insurance may also play a role; check the cover in good time.

A settlement can sometimes be an efficient solution. We then assess not only the amount or the restoration, but also final discharge and any remaining claims. The chosen approach must match your interests, your evidence and the risks.

A file with several problems needs a clear order

A bank dispute can affect your day-to-day payments, a loan and a registration at the same time. The first step is then to determine which problem cannot wait. An account that closes tomorrow calls for a different approach from a calculation of the loss from advice given several years ago. We set out the decisions and time limits side by side and discuss which practical arrangement is needed first.

We then distinguish the documents that are relevant to several parts from the information that concerns only one point of dispute. A statement about the origin of money can be important for a Wwft investigation, but does not in itself prove that a BKR code is incorrect. Likewise, an objection to an EVR listing does not automatically resolve a credit being called in. Each measure must be assessed on its own basis.

When the bank makes a proposal, we therefore look at the arrangement as a whole. Does the account remain available? Is a registration adjusted? How is the balance settled and which claims might you be giving up? Sometimes a targeted temporary arrangement creates room to sort out the rest of the file carefully. In other cases a definitive position or proceedings are needed. The appropriate route depends on the documents, the urgency and the achievable solution.

Frequently asked questions about disputes with banks

Do I always have to answer Wwft questions?

Relevant questions for necessary customer due diligence must be answered seriously. If a question is unclear or evidence is missing, ask for an explanation and offer a verifiable alternative. Simply not responding can have serious consequences for your account.

Can a lawyer unblock my account immediately?

An immediate result cannot be guaranteed. First, the reason, scope and urgency must be established. A targeted request or, if necessary, proceedings can then be considered. So send us the notice of the block or termination in good time.

Can the bank call in my loan if I file a complaint?

Filing a complaint is not in itself a general ground for calling in a loan. The bank must be able to rely on a valid contractual and statutory basis. A separate arrears or other event may, however, be relevant and must be examined.

Can I go to Kifid as a self-employed person (zzp’er)?

Not in every dispute. Your capacity, the service and the applicable rules determine access. Have this checked before submitting. Consumer rules cannot simply be applied to a business account or business financing.

Does removal from BKR mean I will definitely get a mortgage

No. The lender also assesses income, outgoings, product conditions and other risks. Removal can take away an obstacle, but it is no guarantee of financing. A concrete mortgage assessment helps substantiate the interest in the request.

How do I discuss my case with Arslan Advocaten?

Contact us with a short description, the latest letter from the bank and any deadline. State whether it concerns a private or a business relationship and what outcome you are seeking. We will then discuss the documents needed, the approach and the costs of an assessment.

Sources and legal basis

• DNB on customer due diligence and combating money laundering.
• Supreme Court 5 November 2021 on access to business accounts.
• Kifid 2026-0022 on unauthorised payments.
• Kifid 2026-0026 on payments carried out by the customer.
• Kifid rules and articles of association.

Sources checked on 16 September 2026. The applicable legal rules and procedure depend on the financial service, the agreement, your capacity and the specific facts.

Looking for the overview of all topics within financial law — BKR, EVR, CIS, the banking relationship, credit and duty of care? Then see Financial law: registrations, banks and credit.

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Not sure which office is most convenient? Then call 070 4500 300 or send your question through the contact form; we will put you through to the right colleague.