Basic payment account in Denmark: who has the right to one?

Consumers with lawful residence in the EU, or in a country with which the EU has a financial agreement, generally have a right to a basic payment account at a Danish credit institution (pengeinstitut), and it requires neither a permanent address, nor MitID (the Danish national digital ID), nor a long bank login. A few grounds for refusal are set out in law. The right is laid down in the Danish act on payment accounts and basic business accounts. Here we go through what the account must include, who the right applies to, and the few concrete grounds on which a bank can lawfully say no.

1. What is a basic payment account?

A basic payment account is an ordinary payment account with a minimum content set by law. The rules are found in the act on payment accounts and basic business accounts, which implements an EU directive on the comparability of fees and access to payment accounts with basic features. The purpose of the act is to ensure that consumers with lawful residence in the EU, or in a country with which the EU has a financial agreement, generally can get access to the most basic banking services, regardless of income, residence status or whether they are otherwise a “difficult” customer to set up in the bank’s systems.

The account is not a special product type with its own name in the bank. It is rather a legal term for a set of minimum rights that every credit institution offering ordinary payment accounts must be able to provide if a customer asks for it and meets the conditions.

The background to the rules is that a payment account has in practice become a precondition for taking part in Danish society and economic life: you need an account to receive salary, public benefits or student grants (SU), to pay rent and bills, and to have a NemKonto (Denmark’s designated account for payments from public authorities), which the public sector can pay into. Without access to an account you risk being left outside the ordinary payment system. That is the situation the rules on the basic payment account are meant to prevent.

2. Who has the right to a basic payment account?

Under the act, credit institutions must offer a basic payment account in Danish kroner to consumers with lawful residence in a country within the EU or in a country with which the EU has an agreement in the financial area, and to consumers who have not been granted a residence permit but who cannot be removed from the country.

Among other things, this means the right generally applies to:

• Danish citizens and others with lawful residence in the EU or a country with which the EU has a financial agreement. Finanstilsynet (the Danish Financial Supervisory Authority) writes that an EU citizen who lives outside these countries, for example in Thailand, has no claim to a basic payment account.
• People with lawful residence in Denmark without a Danish CPR number (the personal ID number) or a permanent home, including people without a fixed address (homeless people).
• People who are seeking asylum under the Geneva Convention, and others with a similar international protection status.
• People without a residence permit who cannot be removed from Denmark.

Finanstilsynet has repeatedly made clear to the banks that the lack of a permanent address, CPR number or MitID is not in itself a lawful reason to refuse a basic payment account, and that homeless and other vulnerable citizens are covered by the right on the same terms as everyone else. The requirement is lawful residence, not a particular housing status or a particular digital ID.

Finanstilsynet has also established that an entry in a register of bad payers, such as RKI (a Danish credit-information register), is not in itself a lawful reason to refuse an application for a basic payment account. Finanstilsynet found in 2023 that this was a type of ground for refusal that several banks were still using contrary to the rules, which led the authority both to issue a stricter notice to the banks and to start an investigation of the practice of selected institutions.

3. What must the account offer?

The act sets out a list of services that a basic payment account must include, and which the consumer must be able to use without limit. The account must allow:

• Opening, using and closing the account.
• Depositing funds into the account.
• Withdrawing cash from the account in a country within the European Union or a country with which the Union has an agreement in the financial area, both on the credit institution's premises and at ATMs, also outside the bank's opening hours.
• Direct debits (for example Betalingsservice), payment transactions with a payment card, including online payments, and credit transactions, including standing orders, in a country within the European Union or a country with which the Union has an agreement in the financial area (section 9(1), nos. 3 and 4).

The institution is, however, only obliged to offer each service to the extent that it already provides it to customers with ordinary payment accounts. If you can manage and initiate payments from your ordinary account via online banking, the same should generally be possible from a basic payment account, provided the bank otherwise offers online banking to its customers.

4. What may a basic payment account cost?

The credit institution must offer the services for the basic payment account free of charge or for a reasonable fee. The act does not set a specific amount in kroner for what is “reasonable”. Instead, when setting the fee, the institution must take into account the level of income in Denmark, the average fees charged by credit institutions in Denmark for similar services, and the institution’s own costs and a reasonable profit from offering the account.

The bank also must not make it a condition of getting a basic payment account that you at the same time buy other services not linked to the account, or buy shares, units or guarantee certificates in the bank, unless that is a general condition for being a customer of the institution at all.

If you ... then ...

5. How to apply for a basic payment account

You approach the credit institution you want as your provider and ask for a basic payment account. The bank will ask for the information it needs to carry out its customer due diligence under the anti-money-laundering act, including identification. Once the bank has received a complete application, it must, as soon as possible and no later than 10 working days after, either open the account or give a written refusal.

Finanstilsynet has clarified that the 10 working days run from the time the bank has received an application with all the necessary information, not from the time the bank actually starts processing it. If information is missing, the bank should contact you quickly to get it, instead of letting the case sit. If you find that a bank takes longer than 10 working days on a complete application, you can draw Finanstilsynet’s attention to it. The authority has previously intervened against specific banks, including issuing an order, when the deadline has not been met.

Any refusal must be given on paper or on another durable medium and must, as a general rule, include a reason, unless the reason can be left out for reasons of national security, public order, or to protect the confidentiality of reports under the anti-money-laundering act. The refusal must also tell you about the possibility of complaining to Det Finansielle Ankenævn and of referring the matter to Finanstilsynet.

If you want to read more about what to look for in a salary account in general, see our guide to salary accounts: what to look for.

If the bank does not answer or says no ... then

1. If more than 10 working days have passed since a complete application, then write to the bank, refer to the deadline, and draw Finanstilsynet’s attention to it (the section above).
2. If you get a refusal without a written reason, then ask for one. A refusal must as a general rule give reasons and tell you about the right to complain.
3. If the reason given is a lack of permanent address, CPR number, MitID or an RKI entry, then compare it with what Finanstilsynet has written (section 2).
4. If the reason is not one of the grounds for refusal in section 11, then complain to the bank’s complaints officer and then to Det Finansielle Ankenævn (section 7).
5. Collect the documents as you go, for example with Bank documents.

6. When can the bank say no?

The right to a basic payment account is strong, but not unconditional. Under section 11, a credit institution must offer the account unless opening it would lead to a breach of the anti-money-laundering act (subsection 1). In addition, the bank can refuse (subsection 3) if:

• You cannot demonstrate a genuine interest in opening a basic payment account.
• You already have a payment account in Denmark that gives you access to the same services, unless you declare that you have been told the account will be closed.
• You have committed criminal offences against the credit institution, and the bank therefore wants to prevent misuse of the right to the account.
• You have behaved offensively or in a way that is a nuisance to the bank's other customers or employees.

The anti-money-laundering reservation in subsection 1 applies, for example, if you cannot or will not provide the information the bank needs for its customer due diligence. Together with the four grounds for refusal in subsection 3, these are the grounds for refusal we have found in section 11, and the bank has no free discretion. Section 11 does not say more precisely what is meant by being unable to “demonstrate a genuine interest” in opening the account, but the exception is intended as a narrow possibility for the bank to reject purely pro forma applications, not as a general right to refuse customers the bank does not want. If you are unsure why the bank thinks you have no genuine interest in the account, you should ask for a more detailed, specific reason.

We go into more depth on these grounds for refusal, the anti-money-laundering rules and what you can do if you are refused, in the article can a bank refuse you an account?

The bank can also terminate a basic payment account that has already been opened, but only on one of the grounds set out in the act (section 13), and as a general rule with at least two months’ notice (termination because of criminal use of the account or incorrect information can take effect immediately), for example if the account has been used for criminal purposes, has had no transactions for more than 24 consecutive months, or if you obtained it by giving incorrect information.

7. Complaints

If you disagree with a refusal or a termination, the first step is to contact the bank’s complaints officer and ask for a written reason, if you have not already received one. If that does not lead to a solution, you can complain to Det Finansielle Ankenævn, which handles disputes between consumers and financial firms. You can also refer the matter to Finanstilsynet, which supervises whether credit institutions comply with the law, but Finanstilsynet does not decide the individual customer’s specific case.

What to ask the bank

• What documentation do I need to show to get a basic payment account if I have no permanent address or MitID?
• What does the account cost in quarterly fees, and is there a fee per withdrawal, transfer or card transaction?
• Can I use the account for Betalingsservice and online payments straight away?
• How long will it take before I get an answer to my application?
• What happens if you say no, and how do I get that in writing?

Can I have a basic payment account and an ordinary account at the same time?

The act allows for you to be refused a basic payment account if you already have a payment account in Denmark that gives access to the same services. If you have been told that your current account will be closed, you can still apply for a basic payment account. If you are unsure about your specific situation, you should ask the bank directly before you apply.

Does the right also apply to businesses?

No, the right to a basic payment account described here applies to consumers. There is a corresponding, but not identical, right to a basic business account for certain traders and associations. Read more in our guide to the basic business account.

Can the bank require me to open an ordinary salary account before I can get a basic payment account?

No. The right to a basic payment account is an independent right, and the bank cannot make it conditional on you choosing another, more expensive product instead. The bank can of course tell you that it also has ordinary salary accounts, if that is relevant to your situation, but it cannot reject an application for a basic payment account solely because it would rather sell you something else.

Can I be refused a basic payment account because I previously had an account at the same bank that was terminated?

It depends on why your earlier account was terminated. If the termination was because you previously committed criminal offences against the credit institution, that may be a lawful reason to also refuse a new basic payment account at the same bank. If the earlier account was simply closed because you did not use it, or because you terminated it yourself, that is not in itself a lawful ground for refusal under the list above.

Read also: security and rights, can a bank refuse you an account?, what does it cost to have a bank account?, NemKonto and switching bank.