This article offers an overview in English of the online Guide to opening a bank account in Belgium published (in French) by Myria. The guide details the procedures for opening a standard bank account as well as a basic bank account.

Neobank Revolut recently attracted attention from the media in Belgium by announcing its intention to introduce a Belgian IBAN for its users, addressing the situation of IBAN discrimination in Belgium. While European legislation, specifically Regulation (EU) No 260/2012, seeks to resolve this issue by standardising credit transfers and direct debits in euros, solving the issue of discrimination in banking remains a challenge in practice.

A 2023 study by Myria highlights that immigrants to Belgium who do not have a Belgian IBAN are faced with significant banking-related challenges that can impede their integration process in the country. These difficulties range from problems with securing a rental deposit to inability to receive a salary, as some employers refuse to pay salaries into non-Belgian accounts and some utilities companies refuse to take direct debits from non-Belgian accounts. 

In addition, opening a bank account in Belgium in general can be incredibly difficult for newcomers, as they are required to navigate often long and complex administrative procedures. In recent years, Myria and Unia have received numerous reports of foreigners encountering difficulties when opening a bank account, often due to their residence status or nationality. 

Overview of the the guide

1. Opening a standard bank account

While banks can generally choose their clients, and have the right to refuse service, they must comply with anti-discrimination laws. In order to apply anti-money laundering (AML) and counter-terrorism financing regulations, banks are allowed to verify the identity of potential clients and request additional documents when necessary.

Standard identification requirements include provision of personal details such as name, surname, date of birth, and address, alongside an official identification document. The document provided can be a national passport or an identity card with a photograph, or a foreigner registration certificate such as an electronic residence card (A, B, C, D, E, E+, F, or F+). If a residence document does not provide such proof of identity, other valid documents issued by Belgian authorities may be accepted. These may include:

• registration certificates issued by the relevant commune as provisional residency authorisation (such as Annex 4, the “orange card”);
• an asylum application recorded by the Foreigners’ Office (Annex 26 or 26 quinquies for multiple applications);
• proof of asylum request at border control (Annex 25 or 25 quinquies for multiple applications);
• a provisional residency certificate (Annex 15, pending the residency document);
• special residency documents (Annex 35 in case of appeal to the Council for Alien Law Litigation).

In the event of refusal

If a bank refuses to open an account, the applicant may request a written explanation from the bank. Should no response be provided, the client can take the issue to the bank's central customer service for a formal complaint. If the refusal persists, the individual may lodge a complaint with the Ombudsfin service, or report potential discrimination to Unia. 

2. Opening a basic bank account

If access to a standard bank account is denied, one may request the opening of a basic bank account, which provides essential services without the possibility of overdraft, deferred payments, or cheque services. Banks are not obliged to offer this option spontaneously; it must be requested explicitly, and the account will be opened within ten days if eligibility criteria are met.

Who can open a basic bank account?

According to Article VII.57 (2) of the Belgian Economic Law Code, any individual legally residing in a European Union Member State is entitled to a basic bank account. This includes:

• asylum seekers;
• homeless individuals;
• recognised refugees;
• persons granted subsidiary protection;
• individuals without a residence permit who cannot be expelled due to legal or practical reasons.

Applicants must provide appropriate identity and/or residence documents including name, surname, date of birth and, when possible, an address. In practice, banks may require an address, as European regulations mandate that banks know a payee's address for all money transfers. 

Banking conditions

To qualify for a basic bank account, the applicant must not hold other current accounts in Belgium, even with a different bank (savings accounts are allowed), and the total amount held across all accounts must not exceed €6 000. Furthermore, the applicant must not have used a basic bank account within the past 24 months.

If access is denied

In cases where access to a basic bank account is denied, it is essential to verify whether the bank's conditions have been met. One should explicitly request the account, referencing the legislation on basic banking services, either in person or in writing. If refused orally, Myria advises to attempt recording the conversation or follow up by email or phone. The refusal must be confirmed in writing within 10 days, unless national security is involved.

Further actions include contacting the bank’s central customer service via online complaint forms or email and, if necessary, lodging a complaint with Ombudsfin, the financial services mediation service, or the Economic Inspection Department of the Federal Public Services. If the refusal is based on discrimination, a complaint can also be filed with UNIA.

Closure of a bank account

A bank may terminate an account under certain circumstances, such as:

• conviction for fraud, breach of trust, fraudulent bankruptcy, forgery, or violation of anti-terrorism or anti-money laundering regulations;
• no payment operations conducted for more than 24 consecutive months;
• provision of inaccurate information to obtain a basic bank account;
• the individual is no longer legally residing in an EU Member State;
• suspected transactions related to money laundering or terrorist financing;
• expiration of a residence permit with limited duration.

In the event of account blocking, it is advisable to contact the bank’s head office via its customer service department. If no response if provided, Ombudsfin can be contacted for mediation. It is recommended to wait for final approval from the head office before making any initial transactions.