Removing an EVR or CIS listing

Written by Onur Arslan, lawyer at Arslan Advocaten and, within the firm, responsible for the financial practice: EVR and CIS listings. Onur Arslan has many years of experience with private-law disputes, including insurance-law and BKR-related disputes. Last updated: 2 October 2026.

Can an EVR or CIS listing be removed?

Yes, but only if the listing is unlawful or works out disproportionately harshly. A listing that is factually correct and meets the requirements of the protocol will in principle remain until the retention period expires. Removal comes into play where the facts do not support the suspicion, where the procedural safeguards have not been observed, or where your interest in removal outweighs the financial sector’s interest in maintaining it.

That last point is, in practice, the heart of almost every case. The discussion is rarely about whether "something happened", and almost always about two other questions: is there enough evidence for the alleged fraud, and are the duration and severity of the listing proportionate to what happened?

When a request stands a chance in principle:

This table does not give a chance of success. What a case does depends on the documents and on the substantiation the institution gives. Note the difference between removal and shortening. Anyone who cannot get the listing itself overturned can often still achieve a reduction of its duration. In practice shortening the duration is often the more realistic outcome.

What is the difference between the EVR, the IVR, the CIS and the incident register?

They are four different registrations with different thresholds, different administrators and different consequences. In practice they are confused with one another, including by the institutions that create them. For your case it matters which of the four applies to you, because the requirements differ.

Watch out for the IVR. The text of the Protocol on the Incident Warning System for Financial Institutions (in the 2021 version and in the current 2026 version) speaks of an incident register with an external referral register linked to it. The Internal Referral Register is, in addition, a term from practice. According to the Dutch Banking Association (NVB), a bank records a limited set of data about an incident in its own IVR, which only its own staff can consult; in serious incidents the same data are also entered in the EVR. For insurers, the IVR appears in the Code of Conduct for the Processing of Personal Data by Insurers (Gedragscode Verwerking Persoonsgegevens Verzekeraars), as a register for internal use within the insurer or its group. Kifid also mentions the IVR as an example of a register you can complain about. If your documents refer to an IVR, ask the institution on what legal basis it keeps that registration and for how long.

The order is not a coincidence. An EVR listing always goes together with an entry in the institution’s own incident register: the external register refers, the internal register holds the file. A request that addresses only the EVR and leaves the incident register undiscussed therefore often solves only half the problem. Request both registrations at the same time, and with an insurer also your CIS entries.

Source: Protocol on the Incident Warning System for Financial Institutions 2026 (PIFI 2026, in force since 1 April 2026), articles 3.1, 5.1 and 5.2, and Stichting CIS for the CIS register. On that date the PIFI 2026 replaced the PIFI 2021; the article numbers referred to here are the same in both versions. If your listing dates from before 1 April 2026, the PIFI 2021 applied when it was made. For the question whether the listing may continue now, the PIFI 2026 may also be relevant; have that assessed for your file.

When is an EVR listing unlawful?

If not all the conditions of the protocol are met, or if the listing does not survive the proportionality test. An EVR listing is a far-reaching measure: it can seriously hinder someone’s access to a large part of financial life. The case law sets high requirements for it.

In practice the test falls into two layers.

Layer 1 — the factual threshold. Article 5.2.1 of the protocol sets three cumulative requirements. The conduct must pose a threat (or have posed one, or be capable of posing one) to the financial interests of clients or staff of a financial institution, to the institution itself, or to the continuity and integrity of the financial sector. In addition, it must be "sufficiently established" that the person concerned was involved in that conduct — and the protocol adds that this finding means that criminal offences are in principle reported to the police. And thirdly, the principle of proportionality must be observed.

That reporting requirement is more nuanced than it looks: the explanatory notes to the protocol expressly acknowledge that there are situations in which no report has (yet) been made while inclusion in the EVR is nonetheless called for. The absence of a report therefore does not automatically make a listing unlawful. Article 5.2.3 does, however, oblige the institution to record its decision not to report. If there is no report and that decision is recorded nowhere, the question remains open whether the criterion of being "sufficiently established" has been met. An error on a claim form, a forgotten disclosure or a clumsy statement does not in principle clear that threshold.

Layer 2 — the proportionality test. Even if the facts are correct, the institution must weigh up whether a listing — and if so, for how long — is proportionate. The factors that play a part include:

This is the section where most cases are won or lost. Institutions regularly list for the maximum period as a matter of course without making the balancing exercise visible. If that reasoning is missing, that in itself is a point of attack: anyone who takes a far-reaching decision must be able to show that they weighed up the interests.

By way of illustration. Someone reports damage to their car and fills in the form carelessly: a date is wrong and an earlier, minor claim is not mentioned. The insurer spots the inaccuracies, rejects the claim and lists for the full period. Two questions are then open. First, whether the established facts support a finding of intent to mislead, or whether this is a matter of carelessness — that distinction determines whether the threshold for listing was met at all. Second, if listing is permitted: was the chosen duration weighed against the size of the loss, the one-off nature and the consequences for the person concerned, and was that assessment also recorded? If that reasoning is missing, that in itself is the point of attack. This is an illustrative example of the rule, not a case handled by our firm.

In addition, there are procedural safeguards that the protocol does prescribe in mandatory terms:

The common thread: the protocol requires time and again that the institution records its assessment. If that record is missing, so is the evidence that the assessment took place — and that is precisely what you raise in a request or in proceedings.

Further reading: EVR listing after an acquittal or a decision not to prosecute: must the bank or insurer remove you?

How long does an EVR or CIS listing stay in place?

A maximum period of eight years applies to the EVR, and the protocol itself calls those eight years the starting point. That is an important nuance, because on the internet you often read the opposite. The explanatory notes to the protocol say: "The nature of the Incidents justifies in principle a retention period of 8 years in the EVR. That period may be departed from in special circumstances, to be assessed by the Participant."

So the fact that "EVR listing 8 years" is a frequently asked question is not because institutions wrongly treat a maximum as the standard — the protocol allows it. The point of attack lies elsewhere: eight years is not exempt from the proportionality test. The protocol expressly provides that the duration too must be tested against whether the interest in the entry prevails over the adverse consequences for you. Anyone who puts forward and substantiates special circumstances forces that test — and in practice that is the route to shortening.

The starting point is the entry in the incident register, not the conduct and not the moment you were told about it. That matters for your position: an institution that lists only late pushes the consequences years forward. Particularly where a lot of time passed between the incident and the listing, that is itself an argument in the proportionality test.

And note the word "at the latest". Eight years is an upper limit, not a standard period: the protocol expressly provides that the duration too is tested against the principle of proportionality. Article 5.3.1 also applies: as soon as the conditions of article 5.2.1 are no longer met, the institution must remove the listing of its own motion.

Time elapsed works in your favour. As the listing gets older and you demonstrably have no new incidents, the balance shifts. A request refused after four years may well succeed after six. It pays to submit a refused request again after some time has passed, provided it comes with fresh substantiation.

How do I find out whether I am listed?

By making a separate access request to each party involved. There is no single desk that shows you all listings at once. That is why people often first hear about their listing when an application is refused.

By way of illustration. Someone wants to switch to another car insurer and unexpectedly has the application refused, with the message that there is "a report" in their name. They knew nothing about it: no decision was ever sent to them. That is immediately the first point of attack, because the institution is supposed to notify the entry at the latest at the moment of first disclosure. The order is then: request the file from the institution that made the report, and with an insurer also from Stichting CIS, and expressly ask for the reasoning and the period set. Without those documents there is nothing to argue against. This is an illustrative example of the rule, not a case handled by our firm.

1. From the institution itself — the bank or insurer that reported the incident. Ask for access to the incident register and to the decision to make the EVR listing, including the reasoning and the period set.
2. From Stichting CIS — for what has been recorded about you in the CIS register.
3. From the party that refused you — an insurer or lender that refuses your application on the basis of a listing ought to be able to say which source it consulted.

Make those requests in writing and expressly ask for the underlying documents: the investigation report, the correspondence and the decision in which the duration was set. Without that reasoning you cannot challenge the proportionality test — and the absence of reasoning is itself an argument.

Time limits. The protocol obliges the institution to respond without delay and in any event within one month of receiving your request (article 9.3.3). For a complex request it may extend that period by a further two months, but it must then notify you of this within one month of receipt. Stichting CIS indicates that with a written request you can view your listings within one month; through the web app (identification with Yivi) it is quicker.

The protocol contains one important exception: access may be refused in the exceptional situations of article 9.3.4 — among other things where that is necessary for the prevention, detection and prosecution of criminal offences. That assessment too must be recorded by the institution.

Can I still get car insurance with a CIS listing?

Often not with mainstream insurers, but you can through a specialist route. Insurers consult the CIS as a matter of course when an application is made. Where a report points to fraud or a cancelled policy, a refusal or a heavily increased premium generally follows.

After removal this is the question we are asked most often. The practical situation:

That last line is the most important one on this page. Anyone who fails to disclose their listing or policy cancellation on a new application breaches the duty of disclosure and risks a second listing on top of the first. The way out runs through challenging the listing, never through concealing it.

→ See also: cancellation of your insurance policy and its consequences, and the duty of disclosure when taking out insurance.

What does an EVR listing mean for my mortgage and bank account?

An EVR listing can block a mortgage application and, in the worst case, lead to your bank account being closed. For lenders the EVR is a heavier signal than a BKR listing: a BKR listing says something about your payment behaviour, an EVR listing about integrity.

The distinction people often do not know:

Anyone with both a BKR and an EVR listing must tackle them separately: they are different registers, different administrators and different assessment frameworks.

→ See also: what a mortgage lender really sees: the BKR or the EVR, and removing a BKR listing.

How do I apply for a listing to be removed?

First, with reasons, to the institution that placed the listing, and then to the Kifid or to the courts. The register itself removes nothing on its own initiative: Stichting CIS and the administrator of the EVR carry out what the affiliated institution supplies. Your request must therefore go to the source.

1. Request all the listings. You cannot challenge what you do not know precisely — including the period set and the reasoning.
2. Submit a reasoned request for removal to the institution. Address separately: why the facts do not support the suspicion, and why the listing is disproportionate in any event.
3. Substantiate your personal consequences with documents. Refusal letters from insurers, a refused mortgage application, a closed bank account. This is where most requests founder: a request without documented detriment is a request with no weight in the balancing exercise.
4. Ask in the alternative for shortening. Anyone who asks only for full removal gives the institution just one way of saying no.
5. If refused: the Kifid or the courts. See the next section.
6. If it is urgent: summary proceedings. If there is a concrete mortgage or insurance application with a deadline, summary proceedings for removal are a realistic route. Speed is then itself the argument.

The protocol sets a hard deadline here. On a request for rectification or erasure (article 9.4.2) and on an objection (article 9.5.2) the institution must inform you in writing, without delay and in any event within one month of receipt, whether and to what extent it grants the request. If it refuses, that must be done with reasons, and it must point you to the dispute resolution arrangement in article 10 of the protocol. Where the matter is complex the period may be extended by two months, provided it lets you know within the first month.

That is more than a formality: a refusal without reasons is contrary to the protocol, and you take that fact with you to the Kifid or the courts.

Can I go to the Kifid with a complaint about a fraud listing?

Yes, provided you have first been through the institution’s internal complaints procedure. The Kifid — the Financial Services Complaints Institute — handles consumer complaints about banks and insurers. The institution must first be given the opportunity to deal with the complaint itself; only if you cannot resolve matters together, or if the institution fails to respond in time, is the route to the Kifid open.

The protocol regulates this itself, in article 10. In a dispute about the accuracy and lawfulness of the processing you first turn to the board or management of the institution concerned. If that does not produce a solution, the protocol names four further routes: the Kifid; the SKGZ where the dispute concerns health or medical expenses insurance; the Dutch Data Protection Authority; or the court with jurisdiction. Where a processing request is refused, the institution is moreover obliged to point you to that dispute resolution arrangement.

The choice is largely a question of time. If no concrete application is pending, the Kifid is an inexpensive route. If a mortgage or an insurance policy is at stake with a hard deadline, summary proceedings are usually the only route that produces a result in time.

Source: Kifid, conditions for submitting a complaint.

What if the insurer accuses me of fraud and starts an investigation?

Cooperate, but not without knowing where you stand. The investigation that precedes a listing is the moment at which the case is decided. Statements you make there come back in the listing decision and in any later proceedings.

What matters at that stage:

• Ask exactly what the investigation is about and on what legal basis it is taking place.
• Do not let yourself be pressed into a statement that you do not fully grasp. A meeting can be rescheduled.
• Say nothing whose accuracy you cannot verify. A careless statement is hard to take back later.
• Ask for a record of the interview and for the opportunity to respond to it.
• Refusing to cooperate is rarely wise — that can in itself have consequences for your cover.

An investigation is not the same as a finding. And a finding of inaccuracy is not the same as a finding of intent — and that distinction is precisely what makes the difference between an EVR listing and no EVR listing.

→ In depth: fraud investigation by the insurer and your rights and the burden of proof in insurance fraud.

Who has to prove that fraud was committed?

In principle the institution that places the listing. Anyone who lists someone for years with such consequences must be able to establish the facts underlying that. A suspicion, a statistical improbability or an unusual claims history is in principle not enough.

That is an important starting point, because in practice it often feels the other way round: the listing is there, and you are expected to prove your innocence. Legally that is not how it is divided.

What you do have to substantiate is the other side of the scales: your interest. The consequences you suffer are for you to put forward and support with documents. That is where your burden of proof lies, and it is one that documents can readily discharge.

That starting point follows from the protocol itself: article 5.2.1 places the requirement that it be "sufficiently established" that you were involved in the conduct on the institution, and according to the explanatory notes to the protocol it documents its assessment of the duration. Whoever must document must also be able to show.

Checklist — before you submit a request

1. Have you requested all the listings — the institution’s incident register, the EVR, and with an insurer also the CIS?
2. Do you know the exact duration that has been set, and the reasoning for it?
3. Is there an investigation report, and have you seen it?
4. Were you informed and heard beforehand?
5. Do the established facts support the conclusion that there was intent to mislead?
6. Have you gone through the proportionality test point by point?
7. Do you have documentary evidence of the consequences — refusals, cancellations, a mortgage you missed out on?
8. Are you asking in the alternative for shortening, alongside removal?
9. Is there a pending application with a hard deadline? Then speed is itself an argument.

Your situation in particular

What does it cost and how long does it take?

The first assessment of your listing is free of charge with us. We read the listing decision and tell you whether a challenge stands a chance. Starting hopeless proceedings costs you money without a result, and that is not what we advise.

Everything after that first assessment is paid work. These are the phases, in order of increasing cost. You hear from us what a phase costs before we start on it, never afterwards:

Why speed matters more here than with other listings: an EVR listing runs for eight years in principle and in that period affects your insurance, your financing and sometimes your work all at once. Every month you wait is a month you do not get back. What is more: the fresher the file, the better the facts can still be reconstructed. Witnesses remember more, documents are still available.

Time limits. Challenging a listing is subject to time limits. For the Kifid: file within one year of reporting the complaint to the institution, or within three months of its final position if it pointed out that period to you, or within a reasonable period after you knew or should have known that you could complain. The period most favourable to you applies. For a request to the institution itself there is no limitation period — you can in principle make your request at any time, and again after some time has passed — but the institution must decide on it within one month. Do not wait with any of this until you happen to run into the consequences.

State-funded legal aid. On a low income the Legal Aid Board may bear part of the cost; you then pay an own contribution.

Legal expenses insurance. If you have one, check whether listing disputes are covered — that is not always the case, and with a suspicion of fraud in particular policies sometimes exclude cover.

An EVR listing after account misuse or incorrect income documents

A suspicion of account misuse is something other than established involvement in fraud. Read which facts and circumstances are relevant in an EVR listing after a money-mule suspicion or identity fraud. With a mortgage application the dispute can be about the origin of a document, an administrative error or deliberate deception. We deal with that in an EVR listing because of a false payslip or employer’s statement.

Besides the listing, your access to payment services can be a separate problem. An EVR entry is not in itself an automatic statutory ground for refusing every basic payment account. So also read about a refused basic payment account.

Have your listing assessed

Send us the listing decision and the refusals you have received. We will tell you whether removal or shortening stands a chance, and what is needed for it.

Arslan Advocaten handles insurance and registration cases from offices in The Hague, Rotterdam, Amsterdam, Utrecht, Tilburg and Eindhoven. Besides Dutch we also speak Turkish and Polish.

Call the office nearest to you — the direct numbers are below — or send us your question through the contact form. We will tell you where you stand and what the next step is.

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.

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

What does an IVR listing mean for you?

An IVR listing has an internal function within a financial institution or group. The fact that a listing is not an EVR listing does not mean it has no consequences. So ask what data have been recorded, why that was done and for how long. Only then can it be assessed whether the listing is factually accurate, necessary and proportionate. A request for removal always calls for an assessment of your specific circumstances.

Further reading: How does an IVR listing work at banks?

First: what kind of listing is it?

Not every entry is a fraud listing. The CIS database contains different kinds of listings: ordinary claim reports, guarantee fund reports, a disqualification from driving, confidential notifications on cancellation, and the External Referral Register (EVR). Only the last of these presupposes that you deliberately crossed a line. An ordinary claim report therefore says nothing about fraud, and the route to challenge it is a different one. So first establish which kind of listing appears in your letter or access overview and who the responsible party is; that determines the legal basis, the retention period and the procedure to follow. See Stichting CIS on the kinds of listings.