"Can I open a bank account in another country without living there?" is a frequent question before a move. Many answers to it are lists of banks that were said to be friendly to foreigners at some point. Lists like that age quickly, because a bank's appetite for non-resident customers is a commercial decision that can change with one internal memo.
The more durable answer lies in the rules underneath. Three questions decide whether a bank abroad will open an account for you:
- Where are you legally resident? In some places that gives you a legal right to an account. In most, it gives you nothing.
- Where are you resident for tax purposes? Every bank in the automatic-exchange system has to ask, and your answer travels.
- What is the bank obliged to do, and what is it merely allowed to do? The gap between the two is where most applications fail.
Get those three straight and the question of which bank becomes much easier.
Where you have a right, and where you only have a request
The European Union: a right for EU residents, in any member state
The EU is the one large region where access to a bank account is written into law. The Payment Accounts Directive (Directive 2014/92/EU) requires member states to make sure that consumers legally resident in the Union have the right to open and use a payment account with basic features with credit institutions located in their territory. Article 16(2) extends that right to consumers with no fixed address and to asylum seekers, and then adds the sentence that matters most for people who move: "Such a right shall apply irrespective of the consumer's place of residence."
In plain terms, someone legally resident in Portugal can apply for a basic account at a bank in Germany or the Netherlands, and the bank cannot turn them away simply because they live elsewhere in the EU. Article 15 backs this up with a ban on discrimination "by reason of their nationality or place of residence" when consumers legally resident in the Union apply for an account anywhere within the Union.
The directive also sets procedure. The bank must open the account or refuse the application within 10 business days of receiving a complete application (Article 16(3)). If it refuses, it must tell you the specific reason in writing and free of charge, unless disclosure would breach national security, public policy or anti-money-laundering rules, and it must point you to the complaint procedure and the competent authority (Article 16(7)). A member state may also require applicants from outside its territory to show a "genuine interest" in opening an account there, but it must ensure the right is not made too difficult or burdensome to exercise.
Two limits are easy to miss. First, the right covers a basic account: payments, transfers, a debit card, cash. It is not a right to a savings account, an investment account or credit. Second, the gatekeeper is legal residence in the Union. A person resident in Dubai, Singapore or New York has no right under the directive in any EU country, however strong their ties to Europe.
The United Kingdom: a right only for UK residents
Britain kept the same model after Brexit and narrowed it. Under regulation 23 of the Payment Accounts Regulations 2015, a consumer is eligible for a basic bank account at a designated bank only if they are legally resident in the United Kingdom, and either hold no other UK account with the basic features or are ineligible for the bank's other accounts. The words "United Kingdom" replaced the earlier reference to the European Union with effect from 31 December 2020. The designated banks must offer the account to anyone who meets those criteria.
The consequence is simple: if you live outside the UK, there is no statutory basic account for you. A British bank may still open an account for a non-resident, often through its international or private-banking arm, but that is a product decision, not a right.
The United States: no right, but no residency rule either
American law does not give anyone a right to a bank account, and it does not require residence either. The federal customer identification rule (31 CFR 1020.220) sets out what a bank must collect before it opens an account. For a non-U.S. person, the identification number can be a taxpayer identification number, a passport number and country of issuance, an alien identification card number, or the number of another government-issued photo document evidencing nationality or residence. For the address, the rule asks for a residential or business street address.
So a passport and a foreign street address satisfy the federal minimum. The rule sets a floor, not a ceiling: each bank writes its own program on top of it, based on its own assessment of risk, and it may ask for more. The Brief went through that route in detail in How to Open a U.S. Bank Account as a Non-Resident without SSN, and the equivalent picture for the Emirates in Opening a Personal Bank Account in Dubai and the UAE as a Non-Resident.
Why "allowed" is not the same as "accepted"
Outside the EU and UK basic-account rules, a bank is free to say no, and anti-money-laundering law often pushes it that way. Article 14(4) of the EU's Fourth Anti-Money Laundering Directive requires that where a bank is unable to complete customer due diligence (identifying you, identifying any beneficial owner, understanding the purpose of the relationship), it shall not carry out a transaction through a bank account, establish a business relationship or carry out the transaction. A file the bank cannot complete is a file it must decline.
Non-residents are harder files. Addresses are foreign, income is foreign, documents are in other languages, and the bank's systems may flag the country you live in. One response is to avoid the whole category, which supervisors call de-risking. European supervisors have said plainly that this is not how it should work. When the European Banking Authority issued its guidelines on de-risking in March 2023, it wrote that "de-risking of entire categories of customers, without due consideration of individual customers' risk profiles, can be unwarranted and a sign of ineffective ML/TF risk management", and that before rejecting a customer, "several options need to be considered".
That does not give you a right to be accepted. It does mean that in the EU a blanket "we do not bank non-residents" is a policy supervisors are entitled to question, and that a well-prepared individual file has a better chance than the category you belong to might suggest. The Brief has written about the other end of the relationship, when the bank closes an account you already have, in When Your Bank Fires You, and about how the post-2001 compliance architecture made all of this harder for people abroad in Twenty-Five Years After 9/11.
The question every bank now asks: where do you pay tax?
The second filter is tax. Every bank in the automatic-exchange system must ask, when the account is opened, where you are resident for tax purposes, and must check that your answer is plausible against everything else in your file. In EU law the rule sits in Annex I, Section IV of Council Directive 2014/107/EU: the bank "must obtain a self-certification" and "confirm the reasonableness" of it. If you name an EU member state, the bank must treat the account as reportable, and it is reported to that state's tax office. An account abroad is not invisible at home, and an applicant who cannot name a convincing tax residence at all is a hard file for any bank. The Brief set out what that self-certification triggers, and how much more the reports will say from 2027, in Singapore Offshore Banking From 2027; the evidence that settles where you are resident is covered in The Paper Trail That Saves You. U.S. citizens carry an extra layer, FATCA reporting, explained in the Brief's piece on citizen-based taxation.
Banks and e-money accounts are not the same thing
One alternative for anyone who cannot get a bank account abroad is an account at an electronic money institution: the app-based multi-currency accounts that are opened online. For payments they work well. As a place to hold money, they are legally different from a bank, and the difference matters when you plan where your reserves sit.
A bank deposit in the EU is covered by a deposit guarantee scheme. Article 6 of the Deposit Guarantee Schemes Directive sets the coverage level for the aggregate deposits of each depositor at EUR 100 000 if the deposits become unavailable.
E-money is not a deposit. Article 6(3) of the E-Money Directive says that funds received by an e-money institution "shall not constitute either a deposit or other repayable funds received from the public". Instead, Article 7 requires the institution to safeguard customer funds, for example by keeping them segregated or invested in secure, low-risk assets, and Article 12 prohibits paying interest on e-money. Safeguarding is a real protection, but it is a different mechanism from a deposit guarantee, and it is not a promise of EUR 100,000 from a public scheme.
The practical answer is to use each for what it is built for: an e-money account for day-to-day payments in several currencies, and a regulated bank account for the money you cannot afford to have frozen or delayed.
What changes next in the EU
The EU's anti-money-laundering rules are moving from directives, which each member state transposes in its own way, to a directly applicable regulation. Regulation (EU) 2024/1624 will, under its Article 90, apply from 10 July 2027. From then on, the core due-diligence rules that decide whether a bank can open your account will be the same legal text in every member state rather than 27 national versions. That will not create a right to an account for non-residents, but it should reduce the number of cases where the same file is acceptable in one country and impossible in the next.
A practical order of operations
Taken together, the rules suggest a sequence that works better than applying to banks at random:
- Settle your tax residence first. Obtain a tax residence certificate and a tax identification number in your country of residence before you apply anywhere. Every bank in the reporting system will ask.
- Use the rights you have. If you are legally resident anywhere in the EU, you can apply for a basic account in any member state, with a decision due within 10 business days and a written reason if refused. If you are legally resident in the UK, the designated banks must offer you a basic account if you meet the criteria.
- Where you have no right, make your file ordinary. Passport, proof of your foreign street address, tax residence certificate, and a clear explanation of the source of your funds and why you want an account in that country. The easier the bank's due diligence, the likelier a yes.
- Keep reserves in a guaranteed bank deposit. Use e-money accounts for payments, not as the only home for your savings.
- If you are refused in the EU, ask for the reason in writing. For basic accounts it is your right, and it tells you whether the problem is your file or the bank's policy.
None of this depends on a list of banks that happened to be friendly last year. It depends on where you live, where you pay tax and how complete your paperwork is, and those are things you can control before you apply.
Work with Sebastian
If you want your residence, tax position and banking set up in the right order before a move, and a banking plan that still works after it, book a consultation.
