Suppose you live in Lombok and commute daily via the A27 to work. After a claim, your new car policy is refused. The cause is often a registration in the Centraal Informatie Systeem (CIS), which insurers use to share suspected fraud without you always noticing.
Practical consequences for residents of Utrecht
- Refused policy applications with virtually every affiliated insurer
- Higher premiums upon acceptance under conditions
- No mortgage if the buildings insurance falls through
- Termination of existing policies in certain cases
- Influence on credit applications when banks consult financial databases
Which registers does the CIS maintain?
The system has three levels of information:
1. External Referral Register (EVR)
The most serious category. It contains individuals and companies with established or strongly suspected fraud. Registration can last up to 8 years. In practice, insurers almost invariably refuse new policies.
2. Incidents Register
Lighter registrations for elevated risk without proven fraud. Typical duration: 5 years.
3. Risk Register
General data on elevated claims risk, such as prior claims or residence in a high-risk neighbourhood. Not always fraud-related.
Insurer access
Almost all Dutch health, non-life, life and disability insurers are affiliated. Every new application triggers an automatic check. A hit usually results in refusal or stricter conditions.
Requesting access
Under the AVG (Article 15) you have the right of access. Send a written request to Stichting CIS, Antwoordnummer 4860, 3500 ZL Utrecht. Identify yourself with a certified copy of your ID. Within one month you will receive an overview; access is free.
Steps to remove an incorrect registration
Follow this procedure:
Step 1: request the file
Request the complete fraud file from the insurer that made the registration.
Step 2: lodge an objection
Send a reasoned objection with explanation, supporting documents and a request for removal. The insurer responds within four weeks.
Step 3: Kifid
If rejected, you can go to Kifid. Processing time 6-12 months, complaint fee € 50.
Step 4: court
For complex cases: summary proceedings (kort geding) or proceedings on the merits (bodemprocedure) before Rechtbank Midden-Nederland in Utrecht, or engage the Juridisch Loket Utrecht.
Damages
According to the Hoge Raad, an insurer is liable for damage caused by an incorrect registration, including missed policies and higher premiums. Compensation ranges from several thousand to tens of thousands of euros.
Important time limits
- Limitation period: 5 years from becoming aware of the registration (Article 3:310 BW)
- Maximum EVR duration: 8 years, after which automatic removal
- Kifid time limit: within 1 year after written rejection
Practical advice
Discover a refused policy without a clear reason? Request access immediately. Many Utrecht residents only discover a registration later due to an error. Early correction prevents years of restrictions. Contact a specialist such as the Arslan office at Vredenburg 40, 3511 BD Utrecht (030 - 8200 200).