When you are faced with a CIS registration or EVR registration, it has major consequences. You may encounter problems taking out insurance, opening an account, applying for a mortgage, or even a lease contract. Many clients experience such a registration as a barrier that puts their lives on hold for years.

Good news: removing a CIS or EVR registration is difficult, but not impossible.
At Arslan Advocaten we carefully assess whether your registration can be legally challenged and fully guide you through the removal process.

---

What is a CIS registration?

A CIS registration means that your personal data are included in the database of Stichting CIS (Central Information System). This database is accessible to virtually all insurers in the Netherlands.
Although some registrations are administrative, others can be very harmful.

Reasons for a CIS registration

You are included in CIS, among other things, when:

• there are payment arrears to the insurer;

• you have made a claim that the insurer deems irregular;

• your policy has been terminated due to risky behavior;

• you caused damage while driving without insurance;

• a suspicion of fraud has been identified.

Note: CIS Foundation does not only maintain registrations related to fraud. Other situations can also lead to a listing, such as:

• Damage claims: When you frequently or conspicuously submit damage claims, this can be grounds for a registration.
• Disqualification from driving: If you have been disqualified from driving, for example after a serious traffic offense, this can also be recorded in the CIS.
• Confidential Communications: Your insurer can place a Confidential Communication if, for example, you do not pay the premium (even after a reminder) or do not cooperate with a claims investigation.

In addition, there is the External Referral Register (EVR), a separate registration within the CIS system, which is mainly used in cases of (suspected) insurance fraud.

Many clients only find out much later that they are registered.

---

What is an EVR registration?

The External Referral Register (EVR) is part of the Protocol Incident Warning System for Financial Institutions (PIFI).
It includes reports of serious incidents, including insurance fraud.
Think of situations in which an insurer believes that you knowingly provided incorrect information.

The importance of intent in an EVR-registration

Before an insurer may include you in the EVR, an important principle applies: intent. It must appear that you acted deliberately with the aim of deceiving the insurer, for example by providing fraudulent information in order to receive a payout.A mere suspicion of fraud is not sufficient. According to the Protocol Incident Warning System for Financial Institutions (PIFI) and case law require that the insurer must actually be able to demonstrate that you acted intentionally. A case of mistaken identity, misunderstanding, or innocent error should therefore not lead to an EVR-registration.Why is this so important? An EVR-registration is far-reaching, as described above: it significantly limits your options in the financial market. Due care and evidence are therefore required.If the intent criterion is not established, there are often good legal options to have your registration reversed—whether or not through the courts.

An EVR-registration is far-reaching because:

• it is shared with banks, insurers, and financial institutions;

• you often cannot take out a new insurance policy;

• loans, mortgages and financial products are refused;

• the registration up to 8 years can remain on record.

An EVR registration is therefore comparable to a fraud alert — but not every alert is justified. We regularly see insurers register too quickly.

Can an EVR registration have consequences for housemates or family members?

Yes, unfortunately an EVR registration can extend beyond just yourself. Because the registration with Stichting CIS is linked to your name and home address, housemates or family members living at the same address can be indirectly affected by this.In practice, we regularly see insurers being extra critical of applications from people registered at the same address. Sometimes housemates or partners are not accepted for a new insurance policy, simply because of the address. There are even situations in which an insurer makes it a condition that you may not be listed as the regular driver on a car insurance policy.In short: an EVR registration can unintentionally affect the entire household. That makes it all the more important to assess whether the registration was rightly placed and, where possible, to take legal action for removal.

---

When does a CIS or EVR registration occur?

Registrations can result from, among other things:

• failure to comply with payment arrangements;

• termination of the insurance due to adverse claims experience;

• causing damage while driving an uninsured car;

• a driving ban;

• suspicion of fraud;

• unclear or incorrect claims handling.

Especially in cases of suspected fraud, things often go wrong.
Insurers sometimes register too quickly, with insufficient evidence or without a balancing of interests — something that is not legally permitted under the GDPR and the PIFI protocol.

---

How long does a CIS or EVR registration remain?

The retention periods differ by reason:

• 15 months – negative claim-free years

• 3 years – unmet financial obligations

• 5 years – damage with an uninsured car, breach of contract, or driving disqualification

• 8 years – EVR fraud registration

Note:
These time limits are the maximum allowed, but not automatically proportional.
A lawyer can argue that a registration should be removed earlier if the impact is disproportionately large.

---

What are the consequences of a CIS or EVR registration?

A registration can lead to:

• rejection by almost all regular insurers;

• significantly higher premiums with special “second-chance insurers”;

• problems with mortgage applications;

• a block on loans or credit cards;

• limitations with business insurance (ZZP / BV);

• financial exclusion for up to 8 years.

EVR registrations in particular can affect an entire professional life — for example in professions that require trustworthiness.

Other common problems in insurance law

In addition to CIS and EVR registrations, there are other situations in which policyholders encounter unexpected problems. Consider the following:

• Suspension of coverage due to premium arrears:
  When a premium is not paid (on time), your insurer may decide to temporarily suspend the coverage. You are then uninsured during that period—even if you pay later after all. Many people only notice this when they want to file a claim, but afterwards turn out not to be covered.
• Non-payment after car theft:
  Has your car been stolen, but the insurer refuses to pay out? This happens more often than you might think. Causes can range from allegedly incomplete information to doubts about the legitimacy of the claim. Each year, Stichting Verzekeringsbureau Voertuigcriminaliteit thousands of car thefts in the Netherlands, but not every victim has their loss covered.
• Rejection of insurance claims:
  Insurers can reject claims due to alleged inaccuracies in the application, or because they believe the policy terms have not been met. Sometimes the rejection occurs without clear reasoning, or a client is referred to a complaints procedure without any real consideration of the merits.
• Premium increases or unilateral changes to policy terms:
  Some insurers significantly increase the premium after an incident, or change the coverage mid-term. This can have far-reaching financial consequences, especially for people who rely on a specific insurance policy.

Regardless of the problem: insurers always have a duty of care and there is a legal framework within which decisions must be made. An independent assessment often proves necessary to arrive at a fair solution.

---

How do you request your CIS registration?

You have the right of access under the GDPR.
You can request your data via Stichting CIS:

👉 External link:
https://stichtingcis.nl

You will then receive an overview stating whether and why you are registered.

Note: Unfortunately, it is not possible to contact Stichting CIS and to have the registration removed. You can only request access to your registration; for the removal or modification of data you must follow the usual objection or correction procedure via the insurer who made the registration.

---

Can a CIS or EVR registration be removed?

Yes — but only if there are legal grounds.
A registration must, according to law and protocol, comply with:

✔ Necessity

Is the registration necessary for combating fraud?

✔ Proportionality

Is the impact on your life not disproportionately severe?

✔ Subsidiarity

Could the insurer have chosen a less severe measure?

✔ Correctness

Have the facts been correctly established?

✔ Evidence

Is there concrete evidence of fraud or negligence?

If any of these elements is missing, removal can be compelled.

---

How does Arslan Advocaten assess your registration? 

Our lawyers have extensive experience with:

• CIS registrations

• EVR fraud registrations

• Disputes with insurers

• GDPR procedures

• PIFI assessments

• Correction and deletion requests

We assess:

1. the legal basis of the registration;

2. the supporting documents from the insurer;

3. whether the insurer’s balancing of interests has been carried out correctly;

4. whether the registration is proportionate is;

5. whether the registration can be removed earlier.

In many cases we find that insurers register too strictly without sufficient evidence or without a balancing of interests — that is unlawful.

---

Step-by-step plan: Remove CIS and EVR registration

1. Request your registration

You do this yourself via Stichting CIS.

2. Legal analysis

We analyze whether there are grounds for removal.

3. Objection to the insurer

We submit a formal, legally substantiated request based on:

• GDPR

• proportionality

• subsidiarity

• PIFI-protocol

4. If necessary to complaints body / court

If needed, we escalate to:

• the Data Protection Officer of the insurer;

• Kifid;

• the civil court.

5. Registration is adjusted or removed

If a request is well-founded, your registration will be removed in whole or in part.

Legal expenses insurance: support with disputes

Do you have legal expenses insurance that covers disputes about CIS or EVR registrations?Then your insurer can reimburse the costs of legal assistance, including engaging a lawyer when necessary.How does it work in practice?

• You report the dispute to your legal expenses insurer (such as Achmea, ARAG or DAS).
• If it is insured, legal costs are usually reimbursed — even if the proceedings have to be conducted by an external attorney.
• With your permission, we will contact your legal expenses insurer directly to arrange the coverage and the next steps for you.

This means that you can focus on your case, while we handle the legal coordination.This prevents unexpected costs and makes us stronger in the proceedings against the insurer.

---

Practical examples

• Removing EVR registration after false suspicion: Removed after balancing of interests.

• CIS registration due to administrative error: Corrected within two weeks.

• Suspicion of fraud without evidence: EVR registration expunged due to violation of proportionality.

Free legal consultation at Arslan Advocaten

Do you want to know whether your CIS and EVR registration removed can be?
We carefully review your case and provide honest advice.

📞 Call us for immediate legal advice
✉️ Or fill out the contact form on our website

You are not alone — we will help you further.