Dutch Privacy Regulator Warns Debt Collectors Over AI Decisions

Autoriteit Persoonsgegevens, the Dutch data protection authority, said in an announcement that a sample of 29 debt collection agencies found growing use of algorithms and AI. The regulator warned that these systems can produce incorrect decisions, discrimination and unequal treatment.

Agencies use AI to estimate the likelihood of collecting a debt based on factors such as a person's credit score, location and payment history. Staff may use these estimates to decide which debtors to contact first. Some agencies also use automated systems to add contact details, bank information, company records and social media activity to case files.

The authority said agencies may not leave important decisions about debtors entirely to computers. Its survey found that agencies do not always know the rules, and it considers it a real possibility that fully automated decision making, which is prohibited, already happens without agencies realizing it. It recommended human involvement in decisions with major consequences, records of the personal data being processed, and clear explanations to debtors about how algorithms are used and what rights they have.

The regulator will hold a roundtable with debt collection organizations on December 2, 2026, to discuss its findings and recommendations. The Dutch debt collection industry association NVI said it had not been informed in advance and would study the report, NL Times reports, citing the newspaper AD.