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SettleADebt C_NL PASS-02 — Netherlands Wck text reconciliation

Partial current-text verification — not country acceptanceResearch baseline: 22 October 2026, America/Los_Angeles Actual primary-source verification: 26 October 2026, Pacific Daylight Time; 27 October 2026, UTC and Netherlands local time Jurisdiction: European Netherlands, subject to the territorial and cross-border holds preserved from PASS-01.

1. Findings — G1 and G2

This pass establishes four material changes missing or incompletely reconciled in the PASS-01 historical-to-current comparison:

These changes are established by the actual amendment and commencement instruments, not by assuming that a current-looking website accurately reproduces the law. 1991 amendment · 2007 amendment · 2008 professional amendment · 2011 amendment. zoek.officielebekendmakingen.nl+3

G1.1 — Operative definition of krediettransactie: bounded reconstruction

The original 1990 article 1(a) covered an agreement or linked agreements involving:

1. A money advance by or for a kredietgever to a kredietnemer, followed by one or more borrower payments.
2. Provision of the use of movable property or a service designated by AMvB, followed by borrower payments.
3. A money advance linked to provision of movable property or a designated service, involving the creditor, borrower and potentially a third-party supplier, followed by borrower payments.

The original text added a common condition requiring at least one payment after three months. That condition was removed by Staatsblad 2011, 246, article II(A)(1). The amendment's article VI expressly excludes credit agreements concluded before the amendment's commencement. Its article VII makes commencement depend on the Staatsblad issue date; the issue date was 24 May 2011, producing 25 May 2011 as the effective date. An older agreement must therefore be examined against the transition, not automatically analyzed under the broadened post-amendment definition. C_NL-P02-C001–C003. zoek.officielebekendmakingen.nl+2

Separately, Staatsblad 1991, 630, article I(A) removed lichamelijke from the movable-property branches, effective 1 January 1992 under article VII. It would be inaccurate to reproduce the 1990 phrase as the fully operative later definition. C_NL-P02-C002. zoek.officielebekendmakingen.nl+1

The original 1991 Besluit aanwijzing diensten Wet op het consumentenkrediet designated passenger transport or accommodation supplied under a travel agreement for the service limb of article 1(a)(2°)–(3°). This is a service-definition instrument, not an article 48(1)(d) authorization for paid debt negotiators. Its presently consolidated amendment/repeal history remains to be certified. C_NL-P02-C004. zoek.officielebekendmakingen.nl

G1.2 — Article 47: prohibition and schuldbemiddeling

The enacted article 47(1) states: Schuldbemiddeling is verboden.

Article 47(2), as read in the original enacted text, concerns services supplied in the course of a business or profession, other than by entering into a credit transaction, aimed at arranging an existing debt burden of a natural person deriving wholly or partly from one or more qualifying credit transactions.

Therefore the gateway still requires identifying:

• the activity actually performed;
• whether it is professional or commercial;
• whether it aims to obtain a debt arrangement;
• a natural-person debt burden;
• at least one qualifying credit-derived component; and
• the applicable version of the linked credit definition.

The selected amendments examined in this pass do not establish an express change to article 47's own wording. But an official complete consolidation as of 26 October 2026 could not be opened, and all intervening amendments were not exhaustively certified. Accordingly, the reconstructed wording is strongly supported but not certified as the complete 2026 consolidation. C_NL-P02-C005 and C015. zoek.officielebekendmakingen.nl+1

G1.3 — Article 48(1): exceptions, with corrected professional and municipal wording

The evidence supports the following reconstruction:

The professional amendment in Staatsblad 2013, 414, article III took effect 1 April 2014 through Staatsblad 2014, 85. The municipal-contractor substitution in Staatsblad 2018, 424, article XXVIA took effect 1 January 2019 under Staatsblad 2018, 425, article II(1). Those dates are independently confirmed here. C_NL-P02-C008–C009. Overheid.nl > Officiële bekendmakingen+3

G1.4 — Article 48(2)–(3): certificate power versus actual requirement

Correction to P01-C002: The original 1990 version of article 48(2) is incomplete for later periods.

Staatsblad 2007, 192, article ID inserted authority for an AMvB to require a certificaat for mediation under article 48(1). Staatsblad 2007, 222 commenced that amendment on 1 January 2008.

The distinction matters:

• Enacted statutory authority: verified.
• An implementing AMvB currently imposing a certificate requirement: not established.
• A universally required certificate for every article 48(1) actor: not established.
• A universal paid-debt-mediator licence: not established.

The retained fee-rule delegation and article 48(3)'s rule concerning contractual departures must also be read with any actual operative implementing rules. Nothing read here automatically cancels the underlying creditor debt or invalidates a judgment. C_NL-P02-C006–C007. Overheid.nl > Officiële bekendmakingen+2

G1.5 — 2017 retained definitions and repealed chapters

Staatsblad 2016, 360, article V, effective 1 January 2017 by Staatsblad 2016, 438, removed Wck chapters I, IV and X except the opening of article 1 and its paragraphs (a) and (n).

Article 1(n)'s original definition identifies a gemeentelijke kredietbank as a credit-lending institution established by one or more municipalities. Its exact later consolidated wording has not been independently recovered.

Crucially, historical Wck articles 2–4 must not be imported as current exceptions to article 47 or article 48 merely because they appear in the 1990 source. C_NL-P02-C010. Overheid.nl > Officiële bekendmakingen+2

Currentness limitation

The official consolidated wetten.overheid.nl endpoint did not return a readable body in this research session. The official alternative was to open the enacted Staatsblad amendments and their separate commencement instruments. That establishes the particular amendments above; it does not establish that every intervening change has been captured.

There is independent recent corroboration that articles 47–48 remained the subject of operative supervision: a ministerial regulation published in Staatscourant 2025, 40669, effective 1 January 2026, appoints designated Finance Ministry officials to supervise compliance with those articles. This regulation does not authenticate every word of the underlying Wck or determine which AMvBs are in force. C_NL-P02-C014–C015. Overheid.nl > Officiële bekendmakingen

2. G2 — Original-to-later-text and commencement crosswalk

The matrix distinguishes enactment from commencement. “Reconstructed” never means that the complete 2026 consolidated text was fetched.

G2 conclusion: The supplied P01 2013 and 2018 changes withstand this targeted review, but their dates must be made explicit. The previously omitted 1991, 2007, 2008 and 2011 amendments materially strengthen the definition/exception reconstruction. None of the named future proposals below is incorporated into this matrix as current law. C_NL-P02-C001–C010.

3. G3 — Article 48(1)(d) designation boundary

3.1 The only enacted designation examined in this pass was temporary

Staatsblad 1998, 454, the Tijdelijk vrijstellingsbesluit schuldbemiddelaars, actually used article 48(1)(d). Its article 2 designated qualifying registered natural/legal persons subject to conditions; article 3 dealt with remuneration; and article 4 expressly terminated the instrument two years after commencement.

The Staatsblad was issued 23 July 1998, so commencement was 24 July 1998; the decree expired under its own two-year sunset provision. Its historical registration arrangement and remuneration limits cannot establish a 2026 permission, fee cap or registration scheme. C_NL-P02-C011. Overheid.nl > Officiële bekendmakingen

3.2 The later Vrijstellingsbesluit materials examined were drafts

C_NL-P02-C012. internetconsultatie.nl+2

3.3 Actual 2026 proposals are not operative replacements

The government’s Wetsvoorstel schuldregelen was listed at the preparation/consultation stage. Its public 2026 draft proposes replacement legislation and, in draft article 29, repeal of the Wck and the separate Besluit aanwijzing diensten. Draft article 30 contemplates later commencement by royal decree. These are proposals, not operative repeals. Wetgevingskalender+1

A separate Implementatiewet herziene richtlijn consumentenkrediet, bill 36.924, was approved by the Tweede Kamer on 6 October 2026 but was still before the Eerste Kamer in the official status page accessed for this pass. A chamber-approved bill is not a commenced amendment merely because it has passed the lower house. C_NL-P02-C013. Eerste Kamer der Staten-Generaal

3.4 Bounded conclusion on present designation

Unresolved: current article 48(1)(d) implementing instrumentOfficial searches covered the Wck's article 48 designation terminology, enacted Staatsblad instruments, the expired 1998 decree, later consultation drafts and the 2026 legislative proposals. No presently effective article 48(1)(d) category designation was positively established from an opened, commenced official body.

That is not a finding that no designation exists. Nor can the separate statutory certificaat power be translated into a current compulsory certificate without reading an operative implementing AMvB.

The exact remaining retrieval is an official 2026-date implementing-regulations index for BWBR0004815 article 48(1)(d) and (2), followed by every linked AMvB's current body, amendments, commencement, expiry and transition. Until then, both the present designation and any implemented certificate condition remain held. C_NL-P02-C016.

4. PASS-02 source register

ID namespace: C_NL-P02-Sxxx. These IDs do not overwrite the supplied P01 S001–S006.

Access convention: All listed bodies were accessed in this pass on 26 October 2026 PDT / 27 October 2026 UTC (27 October Netherlands local time), except S022, where access was attempted but failed. These are web retrievals, not physical inspections of pre-2009 paper originals. “HTML N/A” means no PDF page index was used, not that an uninspected PDF was read. A published instrument's issue date is not automatically its effective date.

4.1 Enacted Wck and linked instruments

4.2 Designation, proposals, corroboration and failed access

Evidence classification: 15 enacted/original historical statute or decree rows (S001–S015); 8 other successfully read official proposal, policy, regulator or parliamentary rows (S016–S021, S023–S024); 1 failed consolidation row (S022). S015 is historically enacted but expired. This classification counts source records, not independent confirmation of present-day validity.

5. Atomic claim register

Every claim below is narrowly scoped. “Enacted” describes the specified legislative act; it does not certify an unread 2026 consolidation. Claim IDs are distinct from the P01 C001–C048.

Claim counts: 16 new atomic claims, C_NL-P02-C001 through C_NL-P02-C016. Their assertions are restricted to the specified actors, agreement periods, provisions and evidence limits. No claim has been designated A097/A098-accepted.

6. G4 — Exact targeted disposition of supplied P01 claims

The supplied original claim texts are retained. This table specifies the proposed overlay; it does not silently replace other P01 claims.

Old-to-new source identity preservation

No renumbering or overwriting of the other 42 P01 claims is authorized. Their findings, qualifications and review status remain as previously recorded.

7. Granular G1–G4 coverage register

Status definitions

• answered: The specifically identified amendment, enactment, commencement, expiration or historical proposition was verified. This does not imply full 2026 consolidation certification.
• partial: A material proposition is supported, but a source-version, linked-rule or interpretive predicate remains.
• unresolved: Evidence does not support the requested determination.
• excluded_with_reason: Outside the expressly narrowed PASS-02 remit.

G1 — Current-definition and exception reconstruction

G2 — Amendment and commencement

G3 — Current designation gateway

G4 — Bounded disposition and excluded application questions

Separately targeted original coverage rows

The task packet supplies the following eight A-row identifiers, but not their verbatim P01 coverage-row bodies. Unlike the six original claim rows, there is no supplied statement to compare word-for-word. I therefore cannot truthfully assert an exact old-to-new text replacement for any particular A-row. Each remains open for a read-only comparison with its saved original row, using the subject-specific claims established above.

This prevents an unsupported assumption that, for example, A07 necessarily represents one particular Wck exception.

The conditional checks in this table are retrieval questions, not assertions about those original row contents. Until the verbatim bodies are reconciled, these eight rows must not be marked substantively accepted.

8. Read-only research log and limitations

Not performed: full official legislative citator, complete amendment graph, every linked AMvB history, every professional qualification rule, real-world contract analysis, Dutch territorial-nexus opinion, municipal-policy audit, private information access, filings, applications, payments, complaints or contacts.

Historical Staatsblad electronic copies issued before July 2009 are service facsimiles; the originally authoritative paper publications were not physically inspected. No PDF page index is claimed for an HTML-only read.

9. Researcher self-check and publication holds

PASS-02 visible register counts

Source rows

24

23 opened bodies; 1 failed consolidationNew atomic claims

16

C001–C016G1–G4 coverage rows

33

K001–K033Targeted original A-row holds

8

Plus 6 claim and 6 source mappings### Material questions still open

1. Full current version: What does the official Wck amendment/consolidation record actually show for every change affecting articles 1(a), 1(n), 47 and 48 up to the research date?
2. Service-designation survival: Has the 1991 Besluit aanwijzing diensten been changed or repealed by an operative later instrument?
3. Present 48(1)(d) route: Is there a later enacted, currently commenced and unexpired AMvB designating paid private mediators, notwithstanding the expired 1998 decree and nonoperative later drafts?
4. Certificate activation: Has any operative AMvB exercised the 2007 article 48(2) power, and for exactly which covered actors or activities?
5. Legacy debt: How does the 2011 express credit-agreement transition interact with a later debt-mediation service concerning an agreement executed before 25 May 2011?
6. Original coverage reconciliation: What do the saved A01/A02/A03/A07/A08/A10/A18/A35 rows actually say, and which of the newly established amendments changes their wording?

Evidence-grounded publication opportunities

After the outstanding primary-source checks, SettleADebt could usefully publish:

• A dated, version-controlled article explaining why the Wck's 1990 credit definition is not sufficient for evaluating later mediation activity.
• An annotated article 48 actor/exception comparison showing municipal contractors, appointed professionals, gratuitous service and designated private actors as separate branches.
• A historical-versus-operative decree warning: the expired 1998 Tijdelijk vrijstellingsbesluit, the 2013–14 drafts and a 2026 proposal are three different legal statuses.
• A compact source-document decision checklist: agreement execution date, type of credit transaction, debt history, service purpose, compensation description, claimed statutory capacity, municipal instruction or appointment, and claimed implementing-decree authority. No actual person or provider verification would be implied.
• A change-monitoring field set that stores enactment, publication, commencement, repeal, transition, evidence-access and review dates separately.

Publication and operational holds

Do not publish as a certified 2026 legal gatewayThe following claims must remain withheld unless individually supported by the outstanding official text and implementing-instrument checks:

• “All private paid debt mediation in the Netherlands requires licence X.”
• “All article 48(1) actors must hold certificate Y.”
• “A current article 48(1)(d) exemption definitely exists” or “definitely does not exist.”
• “A historical 1998 or proposed 2014 fee formula governs in 2026.”
• “A free initial consultation necessarily places a paid service outside article 47.”
• “A foreign provider, ordinary business registration, municipal referral or professional employee automatically qualifies.”
• “A provider's violation cancels the debt, releases security, voids a judgment or guarantees a private refund.”

Preserved boundaries: P01's unaffected findings and remaining 42 claims are not reopened. The original 128 coverage rows are not accepted or overwritten. Municipal/provincial and Kingdom-territory coverage, foreign/remote nexus, creditor obligations, compensation interpretation, contractual/funds rules, professional-staff delegation, consumer remedies and judicial precedents remain outside this pass.

Researcher-only conclusion: This pass has independently verified material amendments and their commencements, including changes the 1990-based P01 reconstruction could miss. It has not certified the full current Wck consolidation or a presently operative article 48(1)(d) designation. The eight original A-row texts were not furnished for literal reconciliation, so their exact replacements remain held.

Coordinator review must separately reopen consequential enactments, verify complete later amendments and implementing rules, and compare the saved P01 coverage cells. This is not independent review, Dutch-country completion or A097/A098 acceptance.

END C_NL PASS-02