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Recent regulatory developments in the Netherlands, such as the new Energy Act, explicitly assign responsibility to energy suppliers for the early identification of payment issues. Payment difficulties must be recognised earlier, followed up carefully and, where appropriate, shared with local authorities.
In practice, this often triggers the same reflex: “We need an additional module or system for this.”
That assumption is misleading.
Early identification of payment issues does not require a separate solution. It requires overview, coherence and control within the credit management process. That is exactly where the strength of an integrated approach lies.
What regulation increasingly requires
While the Dutch Energy Act applies nationally, its underlying principle is widely recognisable: organisations are expected to identify payment problems at an early stage and handle them with care. Regulation typically defines what must be achieved, but deliberately leaves open how this should be organised.
In the Dutch context, escalation towards local authorities is only permitted in cases of structural arrears. In practice, this means that at least two invoices remain outstanding, and for at least one invoice, reminders have been sent and contact attempts have been made, including information about available debt support.
A single overdue invoice is therefore not sufficient. What matters is the overall pattern of payment behaviour.
This does not introduce a new principle, but it does raise the bar. Each step must be logical and well substantiated. Organisations with a coherent credit management process experience limited impact. Where processes are fragmented across multiple systems, pressure increases. Not because of regulation itself, but because end-to-end visibility is lacking.
Where things break down in practice
In many organisations, early identification of payment issues is organised separately from the regular follow-up process. Signals are prepared in additional modules or through manual checks, which makes the process unnecessarily complex.
Not because the rules are unclear, but because coherence is missing. It is not always clear how many invoices are outstanding, which communication has already taken place, or whether the timing of escalation can be properly substantiated. As a result, early identification becomes an administrative exercise, while it is intended as a careful and people-centred instrument.
Early identification is not a feature, but a matter of process design
Early identification of payment issues can be organised as a standalone process, but that quickly leads to additional actions, controls and coordination. It becomes far simpler and more scalable when it is embedded in the credit management process.
From invoicing onwards, context is built: payment behaviour, reminders, contact moments and arrangements are connected. When that coherence is in place, the right moment to escalate emerges naturally. Without additional checks or manual exception handling.
How FIQAS and Abillity® support early identification
Within Abillity®, early identification of payment issues is not a separate functionality or add-on module. It is a logical decision point within an integrated credit management process.
Because invoicing, payments, follow-up and customer communication come together in a single environment:
- a signal is triggered immediately when a payment becomes overdue;
- reminders and contact attempts are automatically recorded;
- it is visible whether support information has been provided;
- it can be objectively determined if and when escalation criteria are met.
Not based on isolated signals, but on the complete history. This makes early identification transparent, well substantiated and suitable for accountability towards authorities and regulators.
One process, despite external differences
Public authorities operate with different systems, procedures and interfaces. That is a given. That is exactly why a consistent internal follow-up process is essential to avoid errors, exceptions and manual corrections.
For FIQAS, one principle is key: external variation should never dictate the internal process. Within Abillity®, the credit management process remains coherent. The logic of reminders, contact moments and escalation criteria does not change, regardless of external channels.
Early identification follows the process, not the other way around.
What regulation ultimately reveals about your process
Regulation does not add an extra step. It reveals how your processes are designed. Where the early identification of payment issues is already embedded in the credit management process, little changes. Where it is organised separately, exceptions, manual work and risk increase.
Organisations that choose integration do not need to add anything. They meet regulatory expectations, identify payment issues earlier and act more consistently. Early identification then becomes no longer a reactive obligation, but a logical and people-centred part of the process.
