Are you unable to open an ordinary payment account? As a consumer, you may, subject to conditions, be entitled to a basic payment account. The bank may refuse that application only on the statutory grounds and must, among other things, be able to comply with the Wwft (the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act). An internal registration or an entry in the External Reference Register (EVR) is not in itself a separate statutory ground for refusal. The facts behind the registration may, however, be relevant.
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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.
If your application is rejected, therefore ask which type of account was assessed and on which specific ground the bank is refusing. A statutory basic payment account (basisbetaalrekening) and a basic bank account under a covenant (basisbankrekening) are different schemes. If they are confused, your application may be handled incorrectly.
Why this distinction matters
Without an account of your own, it becomes difficult to receive wages or benefits, pay fixed costs and manage your finances independently. At the same time, banks have obligations to prevent misuse of the payment system. The right to a basic payment account brings these interests together, but it is subject to conditions and exceptions.
A rejection for an ordinary banking package does not mean that the bank may automatically also refuse a statutory basic payment account. A regular package may include services to which you are not entitled, such as credit or a credit card. If necessary, submit an express application for a basic payment account and ask for a decision on that application.
If the bank has already terminated an account, two actions may run in parallel: challenging the termination and applying for a new means of payment. The success of one action does not automatically decide the other. A fraud registration also remains a separate matter.
Three types of account side by side
| Account | Key feature |
|---|---|
| Ordinary payment account | Regular product subject to the bank’s acceptance policy and terms and conditions |
| Statutory basic payment account | Consumer account with statutory access and specific grounds for refusal |
| Basic bank account under the covenant | Safety net under additional arrangements, sometimes with the involvement of a support organisation |
Use the correct term in your correspondence. Ask the bank to use that term in its reply as well. A letter that merely states that you do not meet the policy may not make it sufficiently clear whether the statutory application has been assessed separately.
These schemes are aimed at personal banking. A business owner cannot simply use the consumer right to a basic payment account to enforce access to business payments. A different assessment applies to that, explained under access to a business account.
Who can apply for a basic payment account?
Article 4:71f of the Financial Supervision Act (Wft) is aimed at consumers who are lawfully resident in the European Union. Nationality or place of residence may not simply determine access. The scheme also takes into account certain persons without a fixed address, asylum seekers and persons who cannot be deported for legal or practical reasons.
The bank may ask about your identity and about a genuine interest in having an account in the Netherlands. Think of living, working or studying in the Netherlands. Which documents are appropriate depends on your circumstances. The lack of a standard document does not mean that you fall outside every scheme without further assessment.
Ask which alternative documents can be used if your situation differs from the usual application process. A postal address, a statement from a support worker or another document may be relevant, depending on the information requested. A statutory entitlement does not remove the necessary identity check and customer due diligence.
Which services come with the account?
The basic payment account is intended for customary payment transactions, within the statutory description and the bank’s range of services. It does not give a general right to a loan, an overdraft or a credit card. Ask which payment functions are available and which charges apply before assuming that the entire package you want will be offered.
The law requires the services to be offered free of charge or for a reasonable fee. That does not mean that every basic payment account is free. In principle, the bank may also not make opening the account conditional on the purchase of various other products. There is a specific exception for participation in the bank’s equity if that applies to all account holders.
A basic payment account may not be offered exclusively via the internet. That may be relevant if you have difficulty with digital services or if the online process does not properly accommodate your situation. Ask for a suitable way to apply and document it if you are repeatedly referred back to an unusable digital form.
When must the bank refuse because of the Wwft?
Article 4:71g of the Wft provides that the bank may not open a basic payment account if doing so would prevent it from complying with the Wwft requirements. The statutory right to a payment account therefore does not cancel those obligations. You must answer relevant questions about your identity, background and intended use.
Do, however, ask which information is missing or which obstacle the bank sees. Perhaps an old address has not been updated, a source document is missing or it is unclear what you want to use the account for. Give a specific explanation and ask whether this allows the investigation to be completed. Simply pointing to your right to an account does not answer the due diligence questions.
A refusal on Wwft grounds does not automatically mean that criminal offences have been proven. It may result from the inability to establish the necessary information. Conversely, the bank must have a genuinely relevant obstacle. Read more about a careful response to Wwft questions from your bank.
What other grounds for refusal exist?
The law also lists specific situations in which the bank may refuse. These include an insufficient genuine interest in an account in the Netherlands, an already usable payment account with another Dutch bank or a pending application for a basic payment account. The law contains an exception where you have been informed that the existing account will be closed.
Certain final convictions from less than eight years ago may also constitute a ground. This concerns the offences designated in the law, not every contact with the police or every suspicion. There are also rules on a basic payment account previously terminated on a specific statutory ground and on refusing to provide a requested declaration about other accounts.
Have the bank state exactly which ground it is applying. “You are on a list” or “you once had a conflict” is not the same as demonstrating that a statutory ground for refusal has been met. The precise facts, date and scheme determine whether reliance on that ground can succeed.
An EVR or IVR (Internal Reference Register) registration does not automatically mean exclusion
An EVR entry has important practical consequences, but it is not listed as an independent ground for refusal in Article 4:71g of the Wft. The bank must assess whether the underlying facts amount to a statutory ground. An internal registration is not automatically sufficient either. So ask for an assessment against the law and not only against internal acceptance policy.
In Kifid 2024-1108 (Kifid being the Dutch Financial Services Complaints Tribunal), a bank was required to open a basic payment account and an associated management account. No statutory ground for refusal had been established, while the bank relied, among other things, on earlier events and covenant rules. The ruling illustrates why the statutory entitlement must be assessed first.
This does not mean that a registration is irrelevant or that every application must be granted. The facts may, for example, cause a problem for customer due diligence. In addition, have it assessed separately whether the fraud registration itself is correct and proportionate.
How do you submit a complete application?
State expressly that you are applying for a basic payment account for personal banking. Provide your contact details, identity information and your genuine interest in a Dutch account. State which accounts you still have and whether they are being closed. Enclose a termination letter if one is available.
Ask the bank to confirm in writing which documents are still needed. Keep a copy of all forms and enclosures. If you do not have a regular residential address or need help with communication, explain this straight away. Ask which procedure suits your situation and who within the bank will assess the application.
Under Article 4:71f of the Wft, the bank must open the account no later than ten working days after receiving a complete application, unless a ground for refusal applies. It is therefore important to record when the application was complete. A sending date of your own choosing is not automatically the starting point if essential information is still missing.
An example for your application
“I request a basic payment account for my personal banking under Article 4:71f of the Wft. My interest in a Dutch account is [explanation]. My current account will be terminated on [date], as shown by the enclosed letter. I enclose the requested identification and other documents. Could you confirm whether my application is complete and, if not, which specific information is missing? In the event of a rejection, I would like to receive the applicable statutory ground for refusal and the underlying reasoning.”
Adapt this example if you do not have an existing account or if an application is still pending. Do not sign a declaration that wrongly states that you have no account anywhere else. A complete and accurate statement prevents new problems regarding the reliability of the application.
If you have urgent payment problems, also ask for practical information about the processing time. Enclose evidence of wages, benefits or fixed costs that you cannot receive or pay. That substantiation does not replace the eligibility conditions, but it does make clear why a prompt assessment is needed.
What if the bank keeps referring you to an ordinary application?
Explain in writing that your earlier regular application was rejected and that you are now making a separate statutory application. Ask for the file to be passed on to the department that assesses basic payment accounts. Keep the replies, so that it is clear whether the bank has dealt with your request on its merits.
If the digital form keeps rejecting you automatically, ask for another way to apply. Pass on the error message or rejection, without repeatedly creating new accounts with differing details. Repeated applications with different information may complicate the assessment and do not produce a clear file.
If no useful response is received, submit a formal complaint. Refer to the specific application and the missing assessment. Do not merely ask for a goodwill gesture when you believe that a statutory entitlement exists. A request for goodwill and reliance on the law may raise different questions.
The basic bank account as a safety net
If a statutory basic payment account cannot be opened because of a ground for refusal, look into the basic bank account under the covenant. This scheme has its own conditions and an application route that often involves the bank you last banked with. In certain cases, the involvement of a recognised support organisation is required.
For adults in the Netherlands, the current website of the covenant describes, among other things, the importance of a known postal address and the role of support services. Use the questionnaire to determine the appropriate route. The scheme is no guarantee that every investigation or every risk will be set aside.
Do not confuse the support worker with the account holder. Have it recorded who manages the account, which powers apply and how living allowance becomes available. For the current application procedure, see Basisbankrekening. A covenant application requires its own assessment and may not, without explanation, be used as a substitute for the statutory test.
Protective administration and support
In the case of protective administration (beschermingsbewind), the administrator (bewindvoerder) may need a management account and a living allowance account to carry out their duties. Provide the court order and the information on powers that are required for this. Explain who can dispose of which part of the money and how the account will be used.
The presence of an administrator does not remove every question arising from the bank’s due diligence. It may, however, be relevant to the practical set-up and control of the use of the account. Ask the bank to take that information into account instead of referring exclusively to an old event.
If you do not have an administrator but do have support from a debt assistance service, discuss what role that organisation can play in an application. Informal help from family is not always the same as support under the covenant. Have the required form of support confirmed explicitly.
Complaining to the bank and next steps
Your complaint starts with the type of account, the application date and the ground for rejection. Then explain why, in your view, the ground does not apply or which information removes the obstacle. Ask for a specific decision on opening the account. A complaint about unfriendly communication alone does not decide the entitlement.
For a consumer dispute that can be dealt with, Kifid may then come into the picture. Check the provider’s membership, the internal complaints procedure and the time limits in the rules. Kifid cannot deal with every problem involving every provider. A complaint also does not automatically suspend the closure of another account.
In the case of acute exclusion from essential payment services, an urgent legal assessment may be necessary. In certain circumstances, the court may be asked for a provisional measure. Discuss your evidential position, the costs and the chosen route before starting parallel proceedings that may affect each other.
Fictitious example of two separate decisions
An account holder receives a letter stating that his regular payment account will be closed in a few weeks. He has an internal registration, and another bank rejects an ordinary package. He concludes that he has nowhere left to turn. That is premature: it must first be examined whether he can apply for a statutory basic payment account.
In that application, he reports the existing account and encloses the termination letter. He asks which statutory ground for refusal the bank considers applicable and provides the missing identity information. At the same time, he has the internal registration assessed separately. Whether both requests succeed depends on the facts; a new account does not automatically make the registration unlawful.
This example shows why the practical objective must be clear. A bank account is needed for access to living money. For future financial products, correction or removal of the registration may also be important. A file may therefore contain several interrelated requests.
Have a rejection recorded clearly
In telephone contact, always ask for written confirmation of the decision on your application. Note the date, the department and what is said to be missing. Make it clear that your request concerns a statutory basic payment account. This prevents a rejection of an ordinary payment package from later being treated as though the separate application had also already been assessed on its merits. Keep the complete application and the acknowledgement of receipt together with the decision.
Also read about Kifid or the court and termination of an account.
Frequently asked questions
Am I entitled to a basic payment account with an EVR registration?
An EVR registration is not in itself a separate statutory ground for refusal. The bank must, however, be able to comply with the Wwft and may apply the grounds set out in the law. The facts behind the registration therefore remain important.
Is a basic payment account free of charge?
Not necessarily. The services must be offered free of charge or for a reasonable fee. Ask about charges and functions in advance. The right to the account does not automatically include an overdraft, credit or a credit card.
Do I have to go to my last bank?
That condition may form part of the covenant scheme for a basic bank account. It is not necessarily the same condition for the statutory basic payment account. Have it established which scheme your bank is assessing.
Can I apply while my current account is still open?
Disclose the existing account in full. If you have been informed that it will be closed, the law provides a relevant exception to the ground for refusal based on another account. Enclose the termination letter.
Is a police report against me sufficient grounds for refusal?
A police report is not the same as a final conviction. Other facts may, however, be relevant to customer due diligence. The bank must link its rejection to the correct statutory ground.
Can Arslan Advocaten assess my rejection?
Yes. Send the application, the rejection, any termination letter and information about other accounts. Arslan Advocaten can assess which entitlement and procedure are appropriate. Also discuss costs and any options for subsidised legal aid.
Sources and legal basis
- Financial Supervision Act (Wft), Articles 4:71f and 4:71g.
- Kifid 2024-1108, including the relevant statutory provisions.
- Dutch central government on a refused payment account.
- Current information from the Basic Bank Account Covenant (Convenant Basisbankrekening).
- Kifid rules.
Sources checked on 16 September 2026. The practical example is fictitious.
