An entry in the CIS register can have major consequences. Consider not being able to take out insurance, being refused a mortgage or problems applying for financing. Many people only find out that they are registered late — often after a rejection, without clear explanation.
In this blog we explain what the CIS register is, when you can end up in it, what the consequences are and above all: what you can do if you have been registered incorrectly or for too long.
What is the CIS register?
The CIS register is managed by Stichting CIS (Central Information System). In this system, insurers share information about (suspected) fraud, irregularities and other incidents.
The purpose of the CIS register is to prevent and combat insurance fraud. In practice, this means that insurers warn each other about persons or companies that they believe pose an increased risk.
How do insurers use the CIS register?
When you apply for car insurance, for example, insurers often consult the CIS register and the Roy data database. This way they can view your insurance history:- Claim-free years: How many claim-free years have you accrued, and are there any negative years?
- Claimed damages: How often have you claimed damages in the past?
- Criminal history: Are there any incidents or fraud?
When will you be included in the CIS register?
A registration in the CIS register usually arises in the following situations:
-
A suspicion of insurance fraud
-
Incorrect or incomplete information when taking out insurance
-
Contradictory statements in a claim for damages
-
A claim for damages that the insurer believes is incorrect
-
Involvement in an incident classified as “irregular”
⚠️ Important:
A registration does not automatically mean that fraud has actually been proven. In practice, we regularly see that people are registered based on suspicions or assumptions.
Which registers exist within CIS?
There are several sub-registers within the CIS system, including:
-
Incident register
-
Internal Referral Register (IVR)
-
External Referral Register (EVR)
An EVR registration in particular is radical, because it is visible to all affiliated insurers. The information from sources such as Roy-dataand CISis accessible to all insurers and agents affiliated with them. Based on this information, they can decide to refuse your application for car insurance, even if you apply elsewhere.
How can you check the claim-free years?
Do you want to know how many claim-free years you have built up? Then you can easily check this via Roy-data: the central database in which all claim-free years are recorded. Log in with your DigiD on the Roy-data website, where you will immediately find the current overview. Do you have doubts about the number? Please contact yourprevious insurer. This can tell you exactly what was passed on to Roy-data. Stichting EPS itself cannot adjust this data; changes always go through the insurer. This way you can be sure that you always have up-to-date insight into your accrued claim-free years.What are the consequences of a CIS registration?
The consequences can be far-reaching:
-
Insurances are refused or terminated
-
Premiums are being increased significantly
-
Mortgage applications are stuck
-
Lease or financing applications will be rejected
-
Business insurance is difficult or impossible to take out
Many clients only notice something when they “suddenly” no longer receive insurance — without it becoming clear why.
The “blacklist” of insurers
Although the term 'blacklist' is not official, a CIS registration is compared to it in practice. An entry in the CIS registeris anything but positive: insurers have access to this data and can decide to simply refuse an application or terminate a current insurance policy. Information from theRoy datadatabase – which includes claim-free years and previous claims – also plays a role in this assessment. Because insurers have no obligation to accept, they may reject your application for insurance without further explanation. The acceptance policy also differs per insurer, but the shared information within Stichting CISand Roy datais heavily taken into account everywhere. If you have a CIS registration, insurers will quickly see you as too much of a risk.What can you do if you are rejected?
If an application is refused due to a CIS registration, it is important to know that you can submit a correction request to the insurer that placed the registration. This is possible, for example, if the registration is incorrect, incomplete or disproportionate. The CIS Foundationoffers a form with which you can object and explain your situation. Is it not possible to take out a policy with regular insurers? In exceptional cases you can contact specialized insurers such as De Vereende, who also accept customers with a CIS registration – although the premiums there are often (much) higher and the conditions stricter. Note: it is always advisable to avoid the risk of a CIS registration. A registration has a long lasting effect and affects almost all insurance and financing applications.What alternatives are there if you are refused by regular insurers?
Are you refused by regular (car) insurers due to a CIS registration? Unfortunately you are not alone. A registration can lead to almost all known insurers rejecting your application, regardless of your further insurance history. But this does not mean that you have no options at all. These are the best-known alternatives:- Special insurers for “difficult risks”: Consider De Vereende. This party specializes in insuring people who can no longer take out insurance elsewhere.
- Companies with less strict acceptance requirements: Some smaller insurers or niche parties sometimes do offer a policy, often at a higher premium and with stricter conditions.
- Intermediaries or intermediaries: An experienced insurance advisor or intermediary can sometimes find a suitable (emergency) solution in their network.
How long does a CIS registration remain valid?
That varies per situation, but in practice we often see:
-
3 to 8 years registration
-
Sometimes even longer, without active reassessment
A registration is not automatically deleted when the period has expired. Taking action is therefore often necessary.
Terms per type of registration The duration of a CIS registration depends on the type of incident. Below is an overview of the most common terms:| Registration type | Registration duration |
|---|---|
| Negative claim-free years | 15 months |
| Failure to meet financial obligation | 3 years |
| Damage | 5 years |
| Driving disqualification | 5 years |
| Failure to fulfill contractual obligations | 5 years |
| Insurance fraud | 8 years |
How long does a financial obligation registration remain?
If you have failed to meet a financial obligation — for example because you have not paid a premium or owe an amount to the insurer — this may lead to a registration in the CIS register. But how long does such an entry actually remain visible? In practice, a term of 3 years usually applies to administrations relating to unfulfilled financial obligations. During this period, insurers can view your registration, which may have consequences for taking out new insurance or financial products. After those 3 years, the registration should be deleted, unless there are special circumstances that justify a longer retention period. Note: it is not an automatic process. Therefore, keep a close eye on it and, if necessary, take action to have it removed in a timely manner.When is a CIS registration unlawful?
Registration is not always permitted. This may be unlawful if:
-
There is insufficient evidence of fraud
-
The registration is disproportionate
-
No adversarial hearing took place
-
The weighing of interests is missing or incorrect
-
The registration is taking too long
Insurers are obliged to act carefully. If they do not do so, removal can be enforced.
What can you do with a CIS registration?
Step 1 – Request access
You have the right to inspect your CIS data. This makes it clear:
-
why you are registered;
-
in which register;
-
for what duration.
Step 2 – Legal assessment
Have the registration assessed:
-
is legally sustainable;
-
complies with proportionality and care;
-
may be maintained.
Step 3 – Takedown request or procedure
Is the registration unjustified or too onerous? Then you can:
-
a removal request must be submitted;
-
or legal proceedings will be initiated against the insurer.
Where else can you go if rejection occurs?
If both the insurer and the complaints committee reject your complaint, there are two more options:- You can submit your case to the Financial Services Complaints Institute (Kifid). This institute mediates and makes rulings in disputes between consumers and financial service providers.
- IfKifid does not lead to the desired result, you may consider taking the matter to court. In that case, take into account possible high costs and a longer procedure.
Why legal assistance is crucial
Insurers have files, protocols and legal departments. Without legal knowledge you can quickly find yourself 1-0 behind.
At Arslan We assess lawyers:
-
whether the registration is lawful;
-
which arguments are promising;
-
how quickly removal can be enforced.
Our assistance is free of charge for clients, because in many cases the costs are recovered from the liable party.
CIS registration? Don't wait too long
The longer a registration remains, the greater the damage — financial and personal. Early intervention significantly increases the chance of successful removal.
Need help with a CIS registration?
Are you dealing with a CIS registration or do you suspect that you are registered? Please contact Arslan Lawyers. We carefully review your situation and explain clearly where you stand and what steps you can take.