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Opening a Belgian Bank Account with Annex 15: Basic Banking Service, National Number and AML Evidence
A Belgian Annex 15 is an official immigration or population-registration certificate issued under the Royal Decree on foreigners.
Its effect depends on the legal article and procedure stated on the document.
It can evidence temporary registration or a pending residence-document situation. It is not the same as:
- Belgian electronic identity card;
- passport;
- permanent residence card;
- bank account approval.
A bank can accept Annex 15 as part of the onboarding file, but it must still complete identity, residence, tax-residence and anti-money-laundering checks.
Read the Annex 15
Check:
- full name;
- date of birth;
- nationality;
- address;
- legal reference;
- issue date;
- validity;
- municipality;
- photograph or attached identity evidence;
- national-register or identification number where shown.
Belgium's Immigration Office describes Annex 15 as a certificate connected with registration in the foreigners or population register under the applicable procedure.
The document should be used together with the valid passport or national identity document.
Do not present Annex 15 as a travel document unless the competent authority has confirmed the travel effect for the specific case.
Belgian national number
Municipal registration can result in a Belgian national-register number.
The number is used by:
- public authorities;
- social security;
- tax;
- health funds;
- employers;
- banks.
The bank can ask for it to connect the customer to Belgian records.
A national number is not proof that the holder has unrestricted residence or work rights.
The immigration document controls that status.
If the number has not yet been issued or appears incorrectly, contact the municipality.
Do not generate a number using an online calculator and present it as official.
Ordinary current account
A bank's normal account can include:
- debit card;
- mobile banking;
- savings;
- credit card;
- overdraft;
- investment access.
The bank can apply its commercial acceptance policy, while complying with:
- anti-discrimination law;
- AML law;
- consumer law;
- payment-account rules.
It can request:
- passport;
- Annex 15;
- Belgian address;
- national number;
- employment contract;
- source of funds;
- tax-residence self-certification;
- foreign tax identification number;
- telephone;
- email.
An ordinary-account refusal does not necessarily decide the customer's right to the statutory basic banking service.
Right to a basic payment account
EU law gives a person legally resident in an EU country a right to a basic payment account, subject to national implementation.
The bank cannot refuse merely because the customer does not live in the country where the bank is established.
Belgium's FPS Economy publishes a specific basic banking service for private individuals.
The account is designed to provide essential functions such as:
- receiving payments;
- transfers;
- direct debits;
- cash withdrawal;
- payment card.
It does not guarantee:
- credit;
- overdraft;
- premium card;
- investment products.
Ask the bank specifically for the private-individual basic banking service rather than only applying for a premium package.
Eligibility and residence evidence
The applicant should prove legal EU residence.
Possible Belgian evidence can include:
- valid residence card;
- Annex 15 plus passport;
- Annex 4 or another current official document;
- EU registration evidence;
- other lawful residence documentation.
The bank decides whether the documents permit reliable AML identification.
If Annex 15 expires soon, provide:
- renewal appointment;
- municipality confirmation;
- pending card evidence.
Do not submit an expired certificate without explanation.
AML and tax-residence checks
The basic-account right does not remove AML duties.
The bank can refuse or delay where it cannot:
- identify the customer;
- verify the identity;
- understand legal residence;
- establish source of funds;
- complete sanctions screening;
- obtain tax-residence declarations.
Prepare:
- salary contract;
- first payslip where available;
- foreign bank statements;
- explanation of initial transfer;
- tax number;
- expected account use.
Do not route a third party's unexplained money through the new account.
Existing Belgian account
A bank can refuse the statutory basic account where the applicant already has a usable equivalent account in Belgium under the national conditions.
Disclose existing accounts.
A closed, blocked or unusable account should be documented with:
- closure notice;
- bank letter;
- restriction evidence.
A foreign SEPA account is not automatically a Belgian equivalent account for every national refusal rule, but the bank can ask why a Belgian account is needed.
Explain payroll, rent or local payment requirements.
Payroll while waiting
An employer can often pay salary to another valid SEPA IBAN.
The European Commission describes rejection of an account solely because its IBAN is from another SEPA member state as IBAN discrimination.
Ask payroll to confirm:
- accepted IBAN;
- account-holder name;
- cut-off date;
- whether the first salary can use the foreign account.
Do not delay onboarding silently.
A Belgian bank account can still be useful for:
- local direct debit;
- cash;
- national services;
- credit history.
Application evidence
Submit the basic-account request through a traceable channel.
Keep:
- application;
- document list;
- receipt;
- bank correspondence;
- refusal;
- date.
Ask whether the decision concerns:
- ordinary account;
- AML identification;
- statutory basic account.
The remedy differs.
An oral “the system does not accept Annex 15” is not a complete written refusal.
If refused
Request:
- written decision;
- legal reason;
- missing document;
- complaint route;
- financial ombudsman information.
Possible next steps include:
- supplying updated municipal evidence;
- correcting national-register data;
- applying explicitly for the basic banking service;
- contacting FPS Economy;
- using the Belgian financial ombudsman;
- obtaining legal or consumer assistance.
Do not send repeated ordinary-account applications without addressing the stated reason.
Sources
- Belgian FPS Economy — Basic banking service
- Your Europe — Basic bank accounts in the EU
- Belgian Immigration Office — Official annexes, including Annex 15
- Belgian Immigration Office — Glossary
- European Commission — IBAN discrimination
- Belgian National Register
This article provides general information. The bank and municipality decide whether the exact current documents satisfy their procedures.