Financial law: registrations, banks and credit

Financial law concerns your position towards a bank, a credit provider, an insurer or a register administrator. A BKR or EVR registration, a terminated account, credit that has been called in or loss caused by wrong advice are legally different matters, but they come down to the same thing: an institution has taken a decision and you want to know whether that decision stands. This page sets out, per topic, what applies and where you can read more.

Written by Onur Arslan, lawyer at Arslan Advocaten. Registered in the areas-of-law register of the Netherlands Bar for employment law and personal injury. Last updated: 17 September 2026.

The firm handles these cases through four entry points: removing a BKR listing, removing an EVR listing, a dispute with a bank or credit provider and loans, credit and BKR. If you do not know which entry point fits, start below with the topic that applies to you.

What usually determines the assessment

In almost every financial dispute, the same three questions come back. Is the factual picture on which the institution relies correct? Was the procedure that goes with that decision followed, such as a prior warning before arrears are reported? And is the consequence for you still proportionate to the interest the institution is protecting? That third question is often decisive in the case law, and at the same time it is the part on which a request without substantiation fails.

BKR registration and codes

A negative registration with BKR blocks a mortgage, a loan and sometimes even a phone contract. Whether removal stands a chance depends on the code, the prior warning and whether the registration is still proportionate in your case.

• Klarna, Riverty and BKR: how does buy now, pay later work?
• BKR registration due to identity fraud: disputing unknown credit
• BKR registration because of your ex-partner: what can you do?
• Removing an A3 code: write-off, repayment and your rights
• Removing an A2 code at BKR: what options do you have?
• What does it cost to have a BKR registration removed?
• BKR registration without a warning: can you have the registration removed?
• Request for BKR removal rejected: which next step do you choose?
• Refused after a credit check: BKR, a credit reference agency or an automated decision?
• BKR codes explained: A, A1 to A5, H and the special codes
• Summary proceedings for BKR removal
• Proportionality test for BKR
• Business loan with a negative BKR
• Removing BKR at ING / Rabobank / ABN
• BKR and student debt
• Mortgage with a BKR registration: what is possible?
• BKR registration after a payment arrangement – what are your rights?
• BKR recovery code: when and how do you get one?
• Negative BKR codes: consequences, periods and what you can do about them
• Unjustified BKR registration: step-by-step plan for removal
• Requesting your BKR registration: see how you are registered in 3 steps
• All about BKR and EVR registrations: explanation, risks and solutions
• Common misunderstandings about BKR and EVR registrations
• BKR or EVR: what does a mortgage lender really see?
• BKR registration: complete basic guide
• Removing a BKR registration after repayment – your rights explained
• Unjustified BKR registration
• Negative BKR registration by a phone provider or private lease – what now?
• BKR registration after a debt arrangement or WSNP – can you have it removed?
• Correcting a BKR registration: step-by-step plan and model request
• Compensation for an incorrect BKR registration

EVR, IVR, CIS and the incident register

Fraud registrations at banks and insurers have a heavier impact than a BKR report: they affect all your financial dealings. The registers differ in purpose, duration and standard of review, and that determines which route stands a chance.

• EVR because of a false payslip or employer’s statement: what now?
• EVR on suspicion of acting as a money mule or identity fraud: your rights
• EVR registration after an acquittal or a decision not to prosecute: must the bank or insurer remove you?
• GDPR (AVG) and CIS registrations
• How long does a CIS registration stay in place?
• Burden of proof in CIS disputes
• Summary proceedings over a CIS registration
• Objecting to a CIS registration
• Removing an unjustified CIS registration
• CIS registration and a mortgage
• Proportionality test for a CIS registration
• When is a CIS registration permitted?
• CIS, IVR and EVR: what is the difference?
• IVR registration at banks
• CIS registration: legal consequences
• Removing a registration: legal routes that work
• CIS registration at insurers: types, access and correction
• CIS registration at banks: which register is it really?
• Blacklisting at banks – what does it mean for you?
• Insurer accuses you of fraud – what now?
• Removing a CIS registration: what is it and how do you remove it?
• Fraud registrations at banks and insurers (EVR, IVR, CIS and the incident register)
• EVR registration for fraud: when does a bank go too far?
• EVR registration: when is it unlawful and how do you get it removed?
• Removing an EVR registration: what are your rights and options?
• Shortening the EVR registration period

Your banking relationship: termination, blocking and the Wwft

A bank may terminate the relationship or block an account, but not just like that. The bank’s policy has to be weighed against your interest in access to payment services and, for entrepreneurs, also the continuity of the business.

• CAAML registration after the bank terminates: access, objection and removal
• Basic payment account refused: when are you entitled to an account?
• Business bank account refused or terminated: what can you do?
• Bank terminates your account: what are your rights?
• Bank account blocked or frozen: what can you do?
• Wwft investigation by your bank: how do you answer questions about your money?
• Complaint against your bank: Kifid or the court?

Duty of care, investment and advice losses

Banks, asset managers and advisers have a special duty of care. If it turns out afterwards that you were not sufficiently warned or were able to borrow too much, that may be a ground for compensation.

• Investment losses: when is the bank or asset manager liable?
• Mortgage adviser liable for wrong advice: your options
• Insurance adviser made a mistake: can you recover your loss?
• The bank’s duty of care: when can you claim compensation?
• Irresponsible lending and the duty of care with an excessive loan
• Investment fraud or a fake platform: can the bank be liable?

Credit, loans and repayment

From a private loan to a family member to business credit that is suddenly called in: the discussion is almost always about when the loan became due, evidence and limitation.

• Disputing repayment of a loan: how to substantiate your defence
• Reclaiming a shareholder loan in a conflict within the private limited company
• Business loan not repaid: what can you do?
• Suretyship for a loan: what if you are held liable?
• Bank or credit provider suddenly calls in your loan
• Reclaiming money invested in your partner’s home
• Limitation of a private loan and asking for repayment in time
• Reclaiming a family loan when there is a dispute over loan or gift
• Joint loan after a separation and an ex who does not pay
• Reclaiming money from your ex-partner: loan or gift
• Money lent without a contract and reclaiming your money
• Unjustified interest and costs on a loan: checking and disputing them
• Mortgage called in by the bank

Payment fraud and your loss

In the case of unauthorised payments, the bank must in principle refund, subject to statutory exceptions such as fraud or gross negligence by the payer. In bank helpdesk fraud where the customer carries out the transfer himself, that refund rule does not simply apply. Any claim then depends on, for example, a separate breach of the duty of care or an applicable goodwill scheme.

• Unauthorised payment: when do you get money back from the bank?
• Bank helpdesk fraud: when does the bank compensate your loss?
• Compensation for an unjustified registration
• Money transferred to the wrong account number

Debt collection, summons and proceedings

If you receive a collection letter, a visit from a bailiff or a summons, what matters most is what you do in time. Costs are capped by law and a defence must be filed within the time limit.

• Unjustifiably high collection costs: what are your rights and how can you challenge them?
• Debt collection and bailiffs: everything you need to know
• Received a summons or petition? What now and how do you put forward a defence?

Frequently asked questions

What does financial law cover?

Disputes between private individuals or entrepreneurs and banks, credit providers, insurers and register administrators. In practice these concern registrations with BKR, the EVR, the incident register and CIS, termination or blocking of a bank account, credit and loans, and loss caused by faulty advice or a breach of the duty of care.

Can a BKR registration simply be removed?

No. Removal requires a substantiated request. First it is checked whether the registration is factually correct and whether you were warned in advance. If the registration is correct, the question follows whether maintaining it is still proportionate in your situation. Full repayment helps in that assessment, but does not automatically erase a correct code.

What is the difference between BKR and EVR?

BKR registers credit and payment arrears. The EVR is a fraud warning register of financial institutions. An EVR registration has a heavier impact, usually lasts longer and requires stronger substantiation from the institution, namely a concrete suspicion that could withstand scrutiny under criminal law.

Can a bank simply terminate my account?

A bank may terminate the relationship, but must weigh your interest in access to payment services. A private individual also has a right to a basic payment account; for a business, continuity is taken into account. A termination without a sound reason or without a reasonable notice period can be challenged.

What do proceedings about a registration cost?

That depends on the route. A request to the institution and a complaint to Kifid cost considerably less than summary proceedings. We discuss in advance which route is realistic in your case and what it costs; the first consultation is free of charge.

Sources and legal basis

• Dutch Civil Code, Book 6: tort and compensation.
• Financial Supervision Act (Wet op het financieel toezicht): duty of care and lending.
• Supreme Court 3 December 2021: GDPR (AVG) legal basis for a BKR registration.
• Kifid and Stichting BKR.

Having your financial dispute assessed

State which decision the bank or credit provider has taken, from when it applies and what you want from the institution. Gather the written notice, the questions asked, your answers and the documents about the consequences. Mention any specific time limit straight away at intake.

With a blocked or terminated account, we first discuss what is needed to protect your payments and any business. With a BKR registration, we assess the data and possible grounds for correction or removal. Consultation, a complaint and proceedings are weighed against purpose, urgency, costs and uncertainties. Put your financial dispute to Arslan Advocaten.

Our offices: visiting address and direct telephone number

Each office has its own direct number. The first conversation is free of charge and confidential; besides Dutch we speak Turkish, Polish and English.

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.