credit insurer asks for an overview of my debtors

Concentration risk with customers, not your total turnover

A debtor overview for a credit insurer usually does not ask for your entire customer base, but for the distribution of the risk that the insurer itself bears: which customers have a credit limit running, how large is that limit per customer, and how much of your turnover is with a small number of large customers. The insurer wants to see whether a bankruptcy of one customer affects a large part of its cover. That is a different type of question than the creditworthiness of your own business, which usually appears in a separate section of the same questionnaire.

Concretely, you are often asked about the top-10 or top-20 customers with turnover per customer, the granted or requested credit limits, and sometimes the outstanding balance on a reference date. If you do not have that breakdown at hand, an aggregated answer — for example the percentage of turnover from the five largest customers, without names — is usually a workable alternative, provided you indicate that it is an estimate. Customer names are often commercially sensitive for you; in that case, check the confidentiality button before submitting the overview. This overview is separate from questions about your banking relationships or payment behaviour to suppliers — these are about your position as a debtor, not as a supplier with receivables.

Why this does not follow from a single legal source

A debtor overview is not a legal obligation but an acceptance and management tool of the credit insurer itself: it uses it to estimate its own risk of non-payment by your customers and to adjust the policy terms — limits, premium, exclusions — accordingly. This is different from the data laid down in the Trade Register about your own business, and also different from the customer due diligence that banks conduct on the basis of the Directive on the prevention of the use of the financial system for the purposes of money laundering and terrorist financing. There is no article that prescribes what must be in this overview; the structure differs per insurer and per policy.