Last updated on October 25, 2025
No, EU banks are not allowed to deny refugees access to a basic payment account solely due to lack of a permanent address. However, they may require alternative documentation to comply with anti-money laundering (AML) regulations.
Banking Rights Without Borders
In the European Union, access to a bank account is considered a fundamental right. Whether you’re a citizen, a migrant, or a refugee, the ability to manage money, receive payments, and pay bills is essential for participating in society. But what if you don’t have a permanent address? Can banks legally turn you away?
The answer is no—at least not for basic accounts. But the path isn’t always smooth.
The Legal Guarantee: Payment Accounts Directive
The Payment Accounts Directive (PAD) 2014/92/EU ensures that all legally resident individuals in the EU, including refugees and asylum seekers, have the right to open a basic payment account. This account must allow standard financial operations like deposits, withdrawals, and payments. Banks cannot refuse access based solely on a lack of permanent residence or financial status.
This directive was designed to combat financial exclusion and promote social integration. It applies across all EU Member States and is enforced by national authorities designated to monitor compliance.
The AML Challenge
While PAD guarantees access, banks must also comply with the EU Anti-Money Laundering (AML) Directive, currently shaped by Directive (EU) 2018/843 and the newly adopted Regulation (EU) 2024/1620. These laws require banks to verify the identity of all customers and assess the risk of money laundering or terrorist financing.
This means that even if a refugee is legally entitled to a basic account, the bank must still perform customer due diligence. Typically, this involves verifying identity documents and, where possible, proof of address. For refugees without a fixed address, banks may request alternative documentation—such as a certificate of residence from a shelter or a letter from a recognized support organization.
Banks are not allowed to use AML rules as a blanket excuse to deny access. Instead, they must find reasonable ways to meet verification requirements without excluding vulnerable individuals.
Balancing Inclusion and Security
The European Commission acknowledges the tension between financial inclusion and AML compliance. It encourages Member States to provide clear guidance to banks on how to handle cases involving refugees and others with limited documentation. The goal is to ensure that AML obligations do not become barriers to basic financial services.
In practice, some banks may still hesitate or impose additional steps, but these must be justified and proportionate. Refugees who face unjust denial can appeal to national financial authorities or seek assistance from legal aid organizations.
The Bottom Line
EU law protects the right of refugees to open a basic payment account, even without a permanent address. Banks must comply with AML rules, but they are also required to make reasonable accommodations. Access to banking is a right—not a privilege—and the law is clear: exclusion is not an option.
See more on European Union
Sources
Access to bank accounts – European Commission
https://finance.ec.europa.eu/consumer-finance-and-payments/retail-financial-services/access-bank-accounts_en
2024-08-12
Opening a basic bank account within the EU – Your Europe
https://europa.eu/youreurope/citizens/consumers/financial-products-and-services/bank-accounts-eu/index_en.htm
2024-07-30
Directive (EU) 2018/843 – AML Directive
https://eur-lex.europa.eu/eli/dir/2018/843/oj/eng
2018-06-19
Regulation (EU) 2024/1620 – AML Authority
https://eur-lex.europa.eu/eli/reg/2024/1620/oj/eng
2024-06-19