Early detection

Education Implementation Service

DUO reports to the City of Amsterdam on debtors who are (beginning to) fall behind with their repayments to DUO. The City of Amsterdam uses this information as part of the ‘Amsterdam early warning approach’, which enables the city to help citizens at risk of falling into poverty as early as possible, so that any (early) arrears do not increase.

Last change on 23rd of June 2026, at 11:44 (CET) | Publication Standard 1.0

• Publication category: Impactful algorithms
• Impact assessment: DPIA, IAMA
• Status: In use

General information

Theme

Education and Science

Begin date

2024-03

Contact information

[e-mail]

Link to publication website

https://duo.nl/particulier/betalingsachterstand/wat-te-doen-bij-betalingsachterstand.jsp

Responsible use

Goal and impact

The government wants to reduce the number of people experiencing payment difficulties. The minister has therefore asked DUO to carry out an ‘Early Warning’ pilot scheme in collaboration with the City of Amsterdam. By offering early help to people with payment arrears, the City of Amsterdam can prevent financial problems from escalating. To this end, DUO passes on alerts to the City of Amsterdam regarding debtors with payment arrears.

DUO uses an algorithm based on criteria from the temporary ‘Signal for Payment Arrears’ scheme (hereinafter: the Scheme) to determine who is eligible for early warning. In addition, a debtor must be resident in the municipality of Amsterdam. This enables the municipality of Amsterdam to offer targeted assistance to these debtors. Debtors receive a notification letter from DUO in advance informing them that a signal is being sent to the municipality of Amsterdam. By that point, they will already have received one or more payment reminders from DUO. Debtors have the right to indicate at any time that they do not wish to participate in the early warning scheme (they may then exercise an opt-out). In that case, the process is halted before the alert is sent.

Considerations

Early intervention focuses on vulnerable debtors who are often difficult to reach and struggle to find the support that is available. Through early intervention, the City of Amsterdam can offer targeted support and thus prevent debts from mounting further. A large proportion of debtors in arrears with DUO are not currently receiving debt counselling. At the same time, the City of Amsterdam has observed that debtors receiving debt counselling are almost always in arrears with DUO. The City of Amsterdam can offer these debtors support tailored to their personal circumstances, rather than focusing solely on their arrears with DUO. Debtors who do not fall within the scope of this pilot scheme, or who do not wish to take part in it, will have to deal with a bailiff.

Human intervention

If DUO has additional details such as a telephone number or email address, the Municipality of Amsterdam will contact the debtor via these channels, provided the debtor has indicated that they have no objection to this.

The early warning process is largely automated, but random checks are carried out on the letters. If DUO finds any discrepancies, a member of staff will carry out a further check. Finally, DUO ensures that the alerts remain up to date. When someone is no longer in arrears, or moves to another municipality, DUO withdraws the alert.

Risk management

DUO complies with the requirements of data protection legislation and information security. Data is exchanged with the Municipality of Amsterdam via a secure system link. Furthermore, the risk of DUO retaining data for too long is limited.

If a debtor indicates within two months of receiving the notification letter that they do not wish to participate, DUO will not send a notification to the City of Amsterdam. If a debtor decides to opt out after DUO has sent the notification to the City of Amsterdam, DUO will withdraw the notification. The City of Amsterdam will then retain the data for no longer than 6 months. For participants in the early warning scheme, the City of Amsterdam will retain the data for a maximum of 5 years and will not use it for any other purpose. This is also set out in the Regulations.

Finally, DUO monitors the use of the algorithm. The pilot will be followed by an evaluation. Depending on the outcome, the pilot may be extended to other local authorities.

Legal basis

DUO passes on data to the Municipal Executive of the City of Amsterdam. DUO does this in order to carry out the task set out in Article 3(1)(b) of the Municipal Debt Assistance Act.

Article 2.3 of the Regulations sets out what constitutes a ‘signal’ and which personal data DUO is required to pass on to the municipality of Amsterdam in such cases.

Links to legal bases

• Municipal Debt Assistance Act: https://wetten.overheid.nl/BWBR0031331/2026-01-01
• Temporary scheme for alerting to payment arrears: https://wetten.overheid.nl/BWBR0045801/2025-06-01

Elaboration on impact assessments

In the IAMA, the various fundamental rights have been weighed up against one another, including any potential positive and negative effects. This assessment shows that the use of the algorithm is balanced and that its deployment is justified.

Impact assessment

• Data Protection Impact Assessment (DPIA)
• Human Rights and Algorithms Impact Assessment (IAMA)

Operations

Data

The algorithm uses the following details of the debtor, as described in Article 2.3 of the Regulations:

1. Name and address (or contact) details (name, address, place of residence and, where available, telephone number and email address)
2. Date of birth
3. The amount of the outstanding debt.

Technical design

The algorithm is a rule-based algorithm that selects debtors eligible for early warning. A rule-based algorithm means that it operates according to fixed rules that have been established in advance. The algorithm follows these rules step by step and does not learn independently.

External provider

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