The Dutch Data Protection Authority (AP) has published recommendations for debt collection agencies regarding the responsible use of artificial intelligence (AI) and algorithms.

Following an investigation conducted with 29 agencies, the AP observed an increasing use of these technologies, leading to risks of incorrect decisions, discrimination, and unequal treatment. The systems are notably used to estimate the chances of successful debt recovery, based on variables such as credit score, location, or payment history, as well as to "enrich files" by searching for additional information about debtors. The authority emphasizes that agencies sometimes ignore applicable rules, which could practically lead to fully automated and prohibited decision-making.

The AP recalls the necessity of human intervention for any decision with significant consequences and formulates three main recommendations: ensuring this intervention, mapping the personal data processed to verify compliance with privacy legislation, and improving transparency towards debtors about the use of algorithmic systems and their rights. A roundtable with sector organizations is scheduled for December 2, 2026, to discuss the findings of the investigation report and the authority's recommendations.