When you are faced with a CIS or EVR registration, the consequences are significant. You may encounter problems when taking out insurance, opening a bank 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.

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What is a CIS registration?

A CIS registration means that your personal data are recorded in the database of Stichting CIS (Central Information System). This database is accessible to almost 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 claimed a loss that the insurer deems irregular;

• your policy has been terminated due to risky behavior;

• you have caused damage while driving without insurance;

• a suspicion of fraud has been identified.

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

• Claims: When you regularly or conspicuously file claims, this may be grounds for a record.
• Revocation of driving privileges: If your driving privileges have been revoked, for example after a serious traffic offense, this can also be recorded in CIS.
• Confidential Notifications: Your insurer can place a Confidential Notification 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 discover much later that they are registered.

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What is an EVR registration?

The External Referral Register (EVR) is part of the Protocol for the 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 have 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 be shown that you acted deliberately with the aim of deceiving the insurer, for example by providing fraudulent information 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 requires the insurer to actually demonstrate that you acted intentionally. A case of mistaken identity, misunderstanding, or innocent mistake should therefore not lead to a 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 mandatory.If the intent criterion is not established, there are often good legal options to have your registration removed—whether or not via 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 denied;

• the registration up to 8 years can remain.

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

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

Yes, an EVR registration can unfortunately extend beyond just you. Because the registration with Stichting CIS is linked to your name and home address, housemates or family members who live at the same address can be indirectly affected by this.In practice, we regularly see that insurers are extra critical of applications from people who are 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 stipulates as a condition that you may not be listed as a regular driver on a car insurance policy.In short: an EVR registration can inadvertently affect the entire household. That makes it all the more important to assess whether the registration was justified and, where possible, to take legal steps to have it removed.

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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 history;

• causing damage while driving an uninsured car;

• a driving disqualification;

• suspected fraud;

• unclear or incorrect claims handling.

Especially when fraud is suspected, 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.

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How long does a CIS or EVR registration remain on record?

The retention periods vary by reason:

• 15 months – negative no-claim years

• 3 years – unmet financial obligations

• 5 years – damage involving 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 proportionate.
A lawyer can argue that a registration should be removed earlier if the impact is disproportionately large.

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What are the consequences of a CIS or EVR registration?

A registration can lead to:

• rejection by virtually all regular insurers;

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

• problems with mortgage applications;

• blocks on loans or credit cards;

• restrictions on business insurance (ZZP / BV);

• financial exclusion for up to 8 years.

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

Other common issues in insurance law

Besides 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 coverage. During that period you are not insured—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.
• No payout 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 reports thousands of car thefts in the Netherlands, but not every victim is compensated for their losses.
• Claim denials:
  Insurers can deny claims due to alleged inaccuracies in the application, or because they believe the policy terms have not been met. Sometimes the denial occurs without a clear explanation, or a client is referred to a complaints procedure without any real consideration of the substance.
• Premium increases or unilateral changes to policy terms:
  Some insurers sharply increase the premium after an incident, or change the coverage mid-term. This can have far-reaching financial consequences, especially for people who depend on a specific insurance policy.

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

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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 that states 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; to delete or amend data, you must follow the usual objection or correction procedure through the insurer that made the registration.

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Can a CIS or EVR registration be removed?

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

✔ Necessity

Is the registration necessary for fraud prevention?

✔ Proportionality

Is the impact on your life not disproportionately severe?

✔ Subsidiarity

Could the insurer have chosen a lighter measure?

✔ Correctness

Have the facts been correctly established?

✔ Evidence

Is there concrete evidence of fraud or negligence?

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

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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 evidence from the insurer;

3. whether the insurer has performed the balancing of interests 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.

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Step-by-step plan: Removing 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 authority / court

If needed, we escalate to:

• the Data Protection Officer of the insurer;

• Kifid;

• the civil court.

5. Registration is adjusted or removed

If the request is justified, 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 lawyer.
• With your permission, we will contact your legal expenses insurer directly to arrange the coverage and the follow-up process for you.

This means you can focus on your case while we take the legal coordination off your hands.This way you avoid unexpected costs and we are in a stronger position in the proceedings against the insurer.

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Examples from practice

• EVR registration removal 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 voided due to violation of proportionality.

Free legal consultation at Arslan Advocaten

Would you like to know if your CIS and EVR registration removed can be?
We carefully review your case and provide honest advice.

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

You are not alone — we will help you further.