Topic Consumer protection BaFin makes opening bank accounts easier for refugees

Date: 09.09.2015

With immediate effect and for a transition period, refugees will be able to open a basic account even if they cannot produce a document satisfying the passport and ID requirements in Germany. BaFin has created transitional provisions to this effect in consultation with the Federal Ministry of Finance. These will apply until an identity verification regulation in accordance with section 4 (4) sentence 2 of the Money Laundering Act (GeldwäschegesetzGwG) comes into force, probably next year. This regulation is expected to permit identity documents beyond the ones mentioned in section 4 (4) no. 1 of the GwG.

Until then, such an account may be opened using documents which:

  • carry the letterhead and the stamp of a German immigration authority,
  • contain the personal details specified in section 4 (3) no. 1 of the GwG (name, place and date of birth, nationality and address),
  • include a photograph and
  • have been signed by an official of the immigration authority.

BaFin will not raise supervisory objections to banks which open accounts for refugees on the basis of documents meeting these criteria. The full content of the transitional provisions may be found in BaFin's letter to the German banking industry association (Deutsche Kreditwirtschaft e.V., only available in German).

Definition: Basic account

A "basic account" means a current account which can be opened without an enquiry to the credit reference agency Schufa and even if the holder has poor credit worthiness, and which ensures access to cashless payments. It is an account in credit without an overdraft facility and permits the key functions, i.e. payments in and out (including in cash), direct debits, standing orders, transfers and the execution of payments using a payment card or similar payment instrument.


The European Payment Accounts Directive, which is currently being implemented in Germany with the Payment Accounts Act (Zahlungskontengesetz) gives every consumer legally residing in the European Union – including people of no fixed abode and asylum seekers as well as people without a residence permit who cannot be deported for legal or practical reasons – the right to a basic account. The planned identity verification regulation will also classify various documents which do not satisfy Germany's passport and ID requirements as equivalent to such documents for the purposes of identification pursuant to the GwG. People without identification documents or replacements for these will therefore also be able to open a bank account.

Given the sudden rise in the numbers of refugees who should be integrated into society and the labour market as quickly as possible, transitional provisions are necessary to enable them to have comprehensive access to an account now.

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