From October 1, 2026, Article 18 of the Debt Collection Services Quality Act (Wki) will enter into force. This gives the registration requirement for debt collection service providers a new meaning. From that moment on, not being registered can have direct financial consequences. And the Judiciary will also test for this more emphatically.
What is changing?
The Wki sets requirements for the quality and reliability of extrajudicial debt collection services. Registration of debt collection service providers is an important part of this.
From October 1, Article 18 attaches concrete consequences to this. Is a debt collection service provider not registered, or is the registration suspended? Then a debtor is not obliged to pay the claim to this debt collection service provider.
Furthermore, the extrajudicial collection costs for the work of that party are not due. In addition, from the moment of a written payment request, the statutory interest no longer continues to accrue at the expense of the debtor.
The original debt does not disappear, however. Article 18 primarily has consequences for the way in which and by whom the extrajudicial collection is carried out.
The Judiciary will also test registration
The new rules also have consequences as soon as a case ends up before the court.
In a recent report on Article 18 Wki, the Judiciary announced that from October 1, additional information must be included in summonses and petitions if a debt collection service provider is involved in the claim.
This includes the name and registration number of the relevant debt collection service provider. Were other debt collection service providers involved in the file earlier? Then information about these parties may also be required. And if a registration was temporarily suspended, that must also be stated.
Is this information missing or is it not clear enough to assess the registration? Then the Judiciary will, in principle, assume that it concerns an unregistered debt collection service provider.
More than an administrative obligation
Registration will thus become much more than just a checkmark in a register from October 1.
For creditors, it means that the choice of a collection partner can influence the collection costs, interest, and ultimately also a legal procedure.
For debt collection service providers, it means that not only must their own registration be in order. It must also be clear which parties have been involved during the collection process.
Does a case eventually come before the court? Then that information must also be correctly and fully included in the procedural documents.
The entire chain therefore counts: from the choice of a collection partner to the recording in the file and ultimately the summons.
Knowing who you work with becomes even more important
The thought behind the Wki is clear: to increase the quality of debt collection services and better protect debtors against parties that do not meet the legal requirements.
Article 18 also makes those rules very concrete from October 1.
For organizations that outsource collection activities, this is therefore a good time to look at their own processes and partners. Is it clear who is involved in a file? Do these parties meet the legal requirements? And is that information properly recorded when an extrajudicial process turns into a legal procedure?
Our Legal Team is happy to assist with this. For example, with questions about the consequences of Article 18 Wki, the setup of the collection process, or the information required when a case comes before the court.
In this way, we work together to map out where potential risks lie and what is needed to set up the process correctly from a legal perspective.
Because from October 1, registration is not just something for the register. It can have direct consequences for the file and the procedure.