A bank may terminate a payment account or customer relationship subject to certain conditions. To do so, it must have a valid ground and follow the applicable rules. If customer due diligence under the Wwft (the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act) has not been sufficiently completed, termination may even be mandatory. Even so, a reference to the Wwft does not automatically make the termination correct. Check the stated reason, your earlier answers, the terms and conditions and the consequences of the end date.
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Written by Onur Arslan, attorney at Arslan Advocaten. Registered in the specialisation register of the Netherlands Bar for employment law and personal injury. Last updated: 17 September 2026.
This article mainly concerns private payment accounts. With a business account, the company’s activities and continuity play a greater role; there is a separate explanation about business bank accounts for that situation. The termination of a credit facility or mortgage must also be assessed separately. Ending your payment account does not automatically make every loan immediately due and payable.
What exactly is the bank terminating?
Start with the scope of the letter. Is one account being closed, is only an additional service being withdrawn, or is the entire customer relationship coming to an end? A bank may list payment accounts, savings products, credit cards and other services separately. Write down the products and their end dates. Ask for clarification if the letter only refers to the banking relationship in general terms.
Also check whether this is a proposed decision or a final termination. A warning may still give you the opportunity to provide missing information. A final termination requires not only a substantive response but also a plan for your day-to-day payments. Do not confuse a period for responding with a guarantee that the account will remain fully usable during that time.
If your account has already been blocked, two issues are running at the same time. You can no longer make payments even before the end date. You should therefore ask both for your ability to make payments to be restored and for the termination to be reconsidered, where there are grounds for doing so. See also the step-by-step plan for a blocked bank account.
What reasons can a bank rely on?
A bank may rely on contractual termination rights, a breach of contract, security risks or statutory obligations. Many banks use the General Banking Conditions (Algemene Bankvoorwaarden), which include a duty of care and rules on termination, among other things. Product-specific terms and conditions may also apply. Check which versions actually apply to your agreement.
In a Wwft-based termination, the bank may argue that it cannot establish the source of funds or cannot complete its customer due diligence for another reason. A different situation arises where the bank does have sufficient information but is unwilling to accept a particular risk. The legal reasoning must match the actual reason and the measure the bank has chosen.
Misuse of the account, threats against staff or conduct in breach of the terms and conditions may also lead to a dispute about termination. There is no general outcome that applies to all customers. A specific allegation must be tested against specific facts, and the consequences for both parties must be taken into account in the assessment.
A Wwft investigation is not a criminal conviction
For a termination on the ground of incomplete customer due diligence, it does not first have to be proven that you have laundered money. On the contrary, the bank must be able to assess, both in advance and during the relationship, whether it can lawfully provide its services. Article 5 of the Wwft may prohibit continuation of the relationship if the required due diligence cannot be carried out.
On the other hand, the bank must be able to substantiate what information is missing and why it is relevant. A mere reference to a risk profile does not replace any further explanation. Ask which questions remained unanswered, which documents were reviewed and which inconsistencies the bank still sees. Make your own answers verifiable by adding supporting documents.
Avoid a discussion that revolves solely around the argument that you have no criminal record. That may be relevant to certain allegations, but it does not answer a question about the source of a payment. Our explanation of Wwft customer due diligence describes how to link your explanation and supporting evidence to each individual transaction.
What notice period applies to a payment account?
Under a framework contract for payment services concluded for an indefinite period, a payment service provider may, if this has been agreed, in principle terminate the contract by giving at least two months’ notice. Article 7:515 of the Dutch Civil Code (BW) contains the rules on this. That is not a universal period for every banking product and every ground for termination.
In the event of a serious breach, a specific contractual ground or a statutory impediment, a different assessment may be required. Any reliance on immediate termination must meet the applicable requirements. So do not only ask how much time you are being given, but also why, according to the bank, it is entitled to depart from an ordinary notice period.
Make a note of when the termination reached you and through which channel. Keep the letter, email or notification on a durable medium. A notice placed somewhere in an app may give rise to disputes about whether it reached you and whether you took note of it. If the period is short, have it assessed immediately whether the notification, the ground and the end date are legally consistent with one another.
What does the bank’s duty of care mean?
In providing its services, the bank must take your legitimate interests into account. The precise content of that duty depends on the product and the situation. In the case of a termination, relevant factors include how dependent you are on the account, the seriousness of the reason, your cooperation and the availability of alternative means of making payments.
The civil law assessment may also concern the question of whether the exercise of a termination right is unacceptable according to standards of reasonableness and fairness. That is an assessment of all the circumstances. The mere fact that termination is inconvenient or costly does not make it invalid. Conversely, a contractual clause does not give the bank unlimited freedom.
The duty of care cannot simply override a statutory obligation to terminate. It is therefore important to distinguish between an actual prohibition on continuing the relationship and a policy choice made by the bank. A good defence addresses the correct ground, so that the parties do not talk at cross purposes.
Gather evidence of the consequences
Show what you use the account for. Think of receiving your salary or pension, and paying rent, health insurance premiums, maintenance and direct debits. State whether you have other accounts, what they can be used for and why they may not be a workable alternative. Keep this information up to date if your situation changes.
If another bank has rejected an application, keep the rejection and the reason given. A general statement that nobody will accept you is less convincing than documented applications. Also mention any application that is still pending. That may be relevant to a request for extra time to switch banks or for certain functions to be retained temporarily.
If you rely on medical or social circumstances, limit yourself to what is needed to understand the consequences. A complete medical file is not automatically relevant. A concise explanation of the impact on your ability to make payments or manage your own affairs may be more useful. Share sensitive documents through a suitable channel.
Reviewing the file on the termination
Draw up a timeline starting from the first request for information. Note when the bank responded, what answers you gave and which documents were requested. Place the termination letter alongside that timeline. If the bank claims that you never responded while you have an upload confirmation, that is a concrete starting point for a reassessment.
Next, check whether your documents actually answer the questions. A bank statement may show a transfer without explaining the original source. An employment contract may support your income without explaining cash deposits. Do not leave any gaps unaddressed; instead, provide an additional explanation or ask how you can demonstrate that information in another way.
Distinguish between errors in the decision and information missing on your side. Both can be dealt with in a single response. You do not have to admit a disputed allegation in order to provide a document. A consistent, factual response offers more to work with than a letter containing only general objections to bank policy.
A targeted response to the termination letter
An initial response may consist of four parts: what you dispute, which documents support that, what the consequences are and what solution you are asking for. Refer to the end date and ask explicitly whether the bank is willing to suspend implementation until your additional information has been assessed. After all, an objection does not automatically suspend the termination.
An example you can adapt: “I request that you reconsider the termination of [date]. Your letter states that [reason]. On [date] I provided [answer and documents] on this point. Please find enclosed [additional information]. The termination affects [specific payments]. I request that the account be continued and, for as long as the assessment is ongoing, written confirmation that the account will remain available. If you are not prepared to do so, I would like to receive your reasons and an assessment of the proposed temporary solution.”
Only use facts that you can explain. Where necessary, ask for an acknowledgement of receipt and keep the complete message you sent. If you have made arrangements by telephone, confirm them in writing yourself. Note whether the bank accepts or corrects that confirmation.
When is confidentiality not a complete answer?
In customer due diligence and transaction monitoring, statutory restrictions may apply to the sharing of information. You are not automatically entitled to all internal alerts, reports or details of how monitoring systems work. So ask for the information you need to understand the decision, without demanding that the bank disclose information it is prohibited from sharing.
In a ruling concerning bunq, Kifid, the Dutch Financial Services Complaints Tribunal, held that the bank had insufficiently substantiated an immediate termination. At the same time, the bank did not have to grant full access to its customer investigation. The reason for termination and access to investigation information are therefore separate questions. See the explanation of Kifid ruling 2025-0043.
This example does not mean that every brief letter will lead to the account being restored. It does show, however, why a file-specific question about the ground for termination is worthwhile. Ask which facts the bank relies on to exercise its right and what explanation it can provide within its statutory obligations.
Your payments during the dispute
While you challenge the termination, also work on a practical alternative. Make a list of incoming payments, direct debits, debit cards and linked services. Ask the bank how any remaining balance will be paid out and what details are needed for that. A decision to terminate does not mean that the bank may keep the money without a valid ground.
Download statements, annual overviews and correspondence in good time. After closure, it may be more difficult to obtain documents. Indicate which data you still need for tax matters, legal proceedings or your records. Ask whether your online access will remain available for a limited time after the end date and on what conditions.
Do not use someone else’s account to evade an investigation, an attachment or contractual restrictions. If you cannot open an ordinary payment account, assess the separate route to a basic payment account. A successful application does not automatically remove any fraud registration.
When do Kifid or the courts come into play?
After your internal complaint, Kifid may be suitable for an eligible consumer dispute with an affiliated bank. Check the time limit under Kifid’s rules and make a deliberate choice between binding and non-binding advice. A binding decision cannot, as a rule, later be submitted to the court again on its merits.
If the end date is approaching and you are at risk of losing essential payment facilities, have the option of interim relief proceedings (kort geding) examined. Those proceedings focus on a provisional solution. Think of continuation of the account for a certain period or restoration of an account, insofar as that is legally possible. The court will also take the bank’s statutory obligations and risks into account.
Before starting parallel procedures, discuss whether they may affect one another. The Kifid procedure has its own rules on concurrent proceedings and jurisdiction. A complaint to a supervisory authority is a different route and does not automatically result in an order requiring the bank to keep your account open.
What happens to internal and external registrations?
Ask whether the termination is accompanied by an entry in a register. A termination due to incomplete due diligence may result in a different registration from an established fraud incident. The scope, retention period and conditions differ. A standard sentence about internal processing does not always provide sufficient clarity on this.
Ask for a separate decision or overview of information and, where appropriate, make a separate request for access, rectification or erasure. The bank must assess its processing against the relevant privacy rules. For an internal Wwft list, you will find more information under CAAML registrations.
What should a written extension contain?
During an objection, the bank may offer to postpone the end date temporarily. Check whether it is only keeping the account open for longer or also lifting the usage restrictions. An account that exists on paper but does not allow any payments may not solve the immediate problem. You should therefore ask separately about outgoing payments, receipt of your salary, direct debits and the ability to transfer the remaining balance.
Record the date until which the arrangement applies and what happens afterwards. Also confirm which documents you still need to provide and when the bank will respond to them. An extension is not automatically a promise that the termination will be withdrawn. Conversely, agreeing to extra time does not have to mean that you waive your objection. Read the wording before you agree, especially if the bank refers to a definitive solution or a final settlement.
A fictitious example: a customer is given three extra weeks to open another account. His mortgage payment falls within that period, but the direct debit function remains blocked. In that case, a new end date alone offers insufficient protection. He must also ask whether this specific payment can be made and, if not, which payment route is still available. Whether the bank must grant such a request depends on the reason for the restriction.
If the termination is withdrawn, check whether the bank has also updated its internal systems. Ask about the status of your debit cards and access to statements. If a registration has also been made, discuss it separately. Winning an objection against the termination does not mean that every other measure disappears without further assessment.
Frequently asked questions
May the bank terminate my account if I have no payment arrears?
Yes, payment arrears are not the only possible ground. Customer due diligence, security risks and contractual arrangements may also play a role. The bank must, however, be able to substantiate the ground and the terms it relies on.
Does a two-month notice period always apply?
No. For the ordinary termination of a payment framework contract concluded for an indefinite period, a minimum of two months applies in principle if the right to terminate has been agreed. An immediate termination or a different product requires a separate assessment.
Does an objection stop the closure of my account
Not automatically. Ask in writing whether the bank will suspend implementation. If you do not receive that confirmation and the matter is urgent, have it assessed in good time whether interim relief is needed.
Can new information reverse the termination?
New information may be a reason for a reassessment, but it does not automatically restore the agreement. Explain which doubts the documents remove and ask for an explicit decision on continuation and the existing end date.
May the bank refuse because I can bank elsewhere?
An alternative may be taken into account, but it does not in itself answer the question of whether the termination is legally valid. Conversely, the lack of an alternative is not an automatic exception to a statutory obligation to terminate.
What does help with a bank termination cost
That depends on the urgency, the size of the file and the procedure required. Discuss the work and costs in advance. For private individuals, subsidised legal aid may be explored; whether it is granted depends on the statutory conditions.
Have the end date and the file assessed together
In a dispute with your bank, Arslan Advocaten can assess the termination, the information you have provided and the payment facilities you need. State the announced closure date straight away. This makes it possible to determine which action is worthwhile within the time available.
Sources and legal basis
- Wwft, in particular Articles 3 and 5.
- Dutch Civil Code, Book 7, including Article 515.
- Kifid on the substantiation of an immediate bank termination.
- Dutch central government on alternatives after an account is refused.
- Kifid rules and regulations.
Sources checked on 16 September 2026. The example text is not a fixed procedural template.
