Wet kwaliteit incassodienstverlening (Wki)

What changed on 1 October 2026?

Article 18 was held back until eighteen months after the transitional year for existing collectors had ended (Staatscourant 2024, 5616). Since 1 October 2026 it has three effects, as the Rechtspraak set them out on 10 September 2026:

• a debtor does not have to pay a collector that is unregistered or whose registration is suspended;
• no collection costs are owed for work done by an unregistered collector or by its successor on the claim;
• no interest is owed from the day an unregistered collector sends a written demand for payment.

Courts now check registration. A summons or petition that claims payment to a collector, collection costs or interest must name the collector and any predecessors with their registration numbers, and say whether a registration was suspended in the relevant period. If that information is missing or insufficient, the court starts from the assumption that the collector was unregistered (Rechtspraak).

The debt itself survives. The Ministry of Justice and Security confirmed on 21 September 2026 that the debtor must still pay the original amount (Rijksoverheid). What goes are the collection costs, and the interest from the unregistered collector's written demand onwards.

What does the Wki require?

The rules sit in three layers: the Act, the Besluit kwaliteit incassodienstverlening (Bki, Staatsblad 2024, 44) and the Regeling kwaliteit incassodienstverlening (Rki, Staatscourant 2024, 10329). All three took effect on 1 April 2024.

Registration

Article 4 prohibits collecting or offering to collect without a registration, or with a suspended one. Justis keeps the register and screens applicants. The application has to explain how the collector will meet Articles 11, 12 and 13 (Article 5). Registration costs €2,200 per collector plus €600 per director (Bki Article 7.1). An annual supervision fee of €1,800 for a sole trader or €7,400 for any other collector is due on registration and every year after (Bki Articles 8.1 and 8.2). Fees are not refunded.

People

Staff who deal with debtors or creditors, and the people who lead that work, need a verklaring omtrent het gedrag no older than three months (Article 12(1)). Every director must be in the register (Article 12(2)). Collection staff need training at level 3 of the European Qualifications Framework; team leaders and sole traders need level 4. All of them take a refresher course every year, and the collector holds sessions on social norms at least twice a year (Bki Articles 2.2 and 2.3).

The training rule is the one the government has relaxed in practice. On 28 March 2025 the State Secretary concluded that it did not create a level playing field and hit small firms disproportionately, and announced a temporary, more lenient policy (Kamerstuk 35 733, nr. 18). As at 29 June 2026 that policy still covered staff active before 1 April 2024, it did not cover trainees, and no decision on the diploma requirement had been taken (Kamerstuk 35 733, nr. 19).

Contact with debtors

The collector gives the debtor a written description of the claim as soon as possible: the parties, the legal basis, the payment terms and a breakdown into principal, interest, collection costs and VAT (Bki Article 3.1). Contact by phone, letter, email or in person is prohibited between 20:00 and 07:00, on Sundays and on public holidays (Bki Article 4.2). The Rki adds that written communication is in Dutch at language level B1, that incorrect threats and aggressive language are not allowed, and that debtors are told about payment arrangements, municipal debt help and the 113 suicide prevention line. A person must be reachable by phone, letter and email during office hours.

Files and complaints

Each instruction gets its own file, kept for at least two years after it closes (Bki Article 5.1). The collector has a complaints procedure, confirms receipt of a complaint in writing within two working days (Bki Article 6.1) and is a member of a dispute resolution scheme (Article 13(5)).

Collection costs on instalments

Since 1 October 2024, Article 6:96(8) of the Burgerlijk Wetboek limits stacking costs on instalment payments. Where the lowest fee applies, the first missed instalment in a six-month period costs €40 and each further one €20 (Staatsblad 2024, 44, Article 9.1). The ministry put the result at no more than €140 per six months for instalments under €266.67 (Rijksoverheid). The rule does not apply to commercial transactions.

What happens when a collector breaks the rules?

The Inspectie can order a collector to comply under penalty (Article 15) and can impose an administrative fine (Article 16). Fine ceilings follow the categories in Article 23(4) of the Wetboek van Strafrecht: the first category (€550 from 1 January 2026) for the naming and contact rules in Article 11, the second (€5,500) for the staff rules in Article 12 and for refusing to cooperate with the Inspectie, and the third (€11,000) for the quality rules under Article 13. Article 16(4) applies Article 23(7) Sr, which lets a fine on a legal person reach the next category up when the set category does not allow an appropriate penalty. The Minister must strike a collector from the register for a serious breach of Articles 11 to 13 (Article 17).

Working without a registration carries no administrative fine. Article 16 does not cover Article 4, so the Inspectie orders the firm to register or to stop collecting (Inspectie JenV, 31 March 2026). The Inspectie has asked for a fining power for registration breaches, and on 29 June 2026 the government said it would explore whether one is possible, necessary and desirable (Kamerstuk 35 733, nr. 19).

The Inspectie's fining policy took effect on 3 February 2026 (Staatscourant 2026, 1098). It sets a base amount per breach in four categories, from €258 to €12,875, then adjusts it for seriousness and duration, culpability, other circumstances, the risk of repeat offences and the firm's financial capacity (Inspectie JenV).

What recently changed

Newest first, as at 13 October 2026.

1 October 2026: Article 18 took effect, the last article of the Wki to do so. Debtors owe no collection costs or interest to an unregistered collector, and courts check registration numbers in every claim for costs or interest (Rijksoverheid, Rechtspraak).

22 September 2026: the Justis register showed 277 active entries (Justis).

29 June 2026: the government responded to the invoeringstoets. The review, completed at the end of 2025, found low awareness of the Wki, lagging registration, practical problems with the training requirement and a supervisor short of powers and capacity. The government brought the statutory evaluation forward to 2028 and said it would explore the scope, the training rules, extra sanctions and the position of creditors. It announced no amendment (Kamerstuk 35 733, nr. 19).

31 March 2026: the Inspectie reported that many collectors still break the law. It had carried out more than 50 inspections since 1 April 2024 and issued more than 20 official warnings. Twenty firms had an order under penalty imposed or announced, and three a fine. Since the summer of 2025 it had written to about 50 firms about registration. The four largest buy now, pay later providers were registered, partly after the Inspectie intervened (Inspectie JenV).

3 February 2026: the Inspectie's fining policy took effect (Inspectie JenV).