UK law does not require proof of address — and nine banks must open you a basic account
Checked against the rules themselves rather than the banks' websites: nine designated banks must open a basic account within 10 business days, the grounds for refusal are a closed list, and neither a poor credit file nor a missing address is on it. What to bring instead of a utility bill, where £120,000 of protection applies and where none does, and what changed on 28 April 2026.
"They won't open an account without proof of address." It is the most expensive thing a newcomer to Britain gets told, and it is wrong. There is no requirement in UK law for a bank to see proof of address before opening a personal account.
We checked this against the rules themselves rather than against what banks put on their websites: the Payment Accounts Regulations 2015, the Money Laundering Regulations 2017, and the JMLSG guidance that the Financial Conduct Authority approves. Here is what a bank must do, what it merely prefers to do, and what to do when you are turned down.
Your ad could be hereAdvertise hereA basic bank account is a legal entitlement, not a favour
Britain has a specific product for this: a payment account with basic features. It is free, comes with a debit card, receives wages and pays bills. It has no overdraft and no credit.
Regulation 22 of the Payment Accounts Regulations 2015 puts it plainly: a designated credit institution must offer a basic account to any consumer who meets the criteria. Not "may consider" — must.
Who qualifies: a consumer legally resident in the UK who either holds no UK payment account with basic features, or is ineligible for every non-basic account the bank offers.
And here is the part that matters most for people who have recently arrived. The regulations state expressly that consumers legally resident in the UK include consumers with no fixed address, asylum seekers within the meaning of section 94 of the Immigration and Asylum Act 1999, and people who have not been granted a residence permit but whose expulsion is impossible for legal or practical reasons.
There is a deadline too: the bank must open the account or refuse it "without undue delay, and no later than 10 business days from receipt of the completed application."
The duty falls on nine banks designated by the Treasury, not on all of them. Per the most recent Treasury report these are: Barclays UK, The Co-operative Bank, HSBC UK, Lloyds Banking Group (including Halifax and Bank of Scotland), Nationwide, NatWest Group (including RBS and Ulster Bank), Santander UK, TSB and Virgin Money.
Monzo, Starling, Revolut, Chase and Zempler are not designated and have no duty to offer a basic account. That is not a criticism of them — it simply means you have no right to demand one there.
The grounds for refusing a basic account are a closed list
Regulation 25 leaves the bank very little room.
It must refuse where opening the account would be unlawful — contrary to the Fraud Act 2006, to the Money Laundering Regulations 2017, to section 40(2) of the Immigration Act 2014 (the prohibition on opening current accounts for disqualified persons), or to a restriction imposed by the FCA.
It may refuse in exactly one other situation: where the consumer's conduct towards staff amounts to an offence under the Public Order Act 1986, the Protection from Harassment Act 1997 or their Scottish and Northern Irish equivalents.
That is the whole list. A poor credit file, a bankruptcy, no credit history at all, no UK address history — none of these is a lawful ground to refuse a basic account. If you were refused for one of them, the refusal does not match the regulations.
Since 28 April 2026 there is more. Where a basic account application is refused, the reason must now be "sufficiently detailed and specific to enable the consumer to understand why the application has been refused" — unless giving it would itself be unlawful. The bank must also tell you how to complain to it and that you may complain to the Financial Ombudsman Service.
Proof of address: the law does not ask for it
Regulation 28 of the Money Laundering Regulations 2017 requires a firm to identify the customer and verify their identity "on the basis of documents or information in either case obtained from a reliable source which is independent" of that person. It names no documents. For an individual customer it does not mention address at all.
The JMLSG guidance — the industry guidance the FCA approves — goes further, and speaks about newcomers specifically:
"The standard verification is verification of name and a choice between verifying address or date of birth. Providing the standard evidence of address can be a particular difficulty for many new arrivals to the UK, and firms should have regard to this fact in deciding whether, in particular cases, to insist on address verification."
A passport, which carries a name and a date of birth, therefore satisfies the standard on its own.
The same guidance forbids hiding behind the law:
"Where an applicant produces non-standard or incomplete documentation, staff should not cite the ML Regulations as an excuse for not opening an account without giving proper consideration to the evidence available."
And the FCA's own Handbook requires firms to have "appropriate measures to ensure that procedures for identification of new customers do not unreasonably deny access to its services to potential customers who cannot reasonably be expected to produce detailed evidence of identity."
So why does the branch still ask for a utility bill? The guidance answers that too: for people who have recently entered the UK, firms "may well require additional documentary evidence — not for AML/CTF purposes, but to offset fraud and credit risks." That is a commercial choice by the bank, not a requirement of law. Which means it is negotiable.
What counts instead of a utility bill
The guidance carries a list of evidence for people who cannot meet the standard check. It is written with basic accounts in mind:
- Economic migrants: a national passport; for EEA and Swiss nationals, a national identity card.
- Refugees: an Immigration Status Document, or an IND travel document.
- Asylum seekers: the Home Office Application Registration Card (ARC).
- Benefit claimants: an entitlement letter from DWP, HMRC or the local authority.
- People in care homes, sheltered accommodation or a refuge: a letter from the manager or warden.
- Homeless people: "a letter from the warden of a homeless shelter, or from an employer if the customer is in work, will normally be sufficient evidence."
- International students: a passport plus a letter of acceptance from the institution.
The guidance adds that a non-resident who is physically present in the UK "should normally be able to provide standard identification documentation to open a Basic Bank Account", and that even non-residents not physically in the UK "are entitled to open a Basic Bank Account, with its limited facilities."
What the banks themselves publish
HSBC's basic account leaflet accepts, as identity: a current passport, a full UK or overseas driving licence, a national identity card, an original benefits notification, or a letter from a hostel manager, social worker, armed services officer, minister of religion or GP. For address — specifically for foreign nationals — it accepts a letter from a UK employer, or from a university, college or language school.
NatWest asks non-UK and non-EU nationals for a passport supported by a valid eVisa share code. Without photo ID it accepts Universal Credit or Jobcentre Plus letters, HMRC correspondence and the Home Office Application Registration Card. But it states plainly that a non-resident of the UK cannot open an account with NatWest.
Santander accepts, for basic account applicants, a state pension notification, HMRC correspondence or a paper driving licence. For students, a college letter less than 12 months old. Mobile phone and TV bills are not accepted as proof of address anywhere.
Nationwide accepts tenancy agreements from housing associations and councils, housing benefit letters and letters from social workers, and says: "We are here to help if you have difficulties getting any of the documents listed on this page." One caveat: without three years of address history you cannot apply online, but you can phone or visit a branch.
Lloyds accepts a non-UK passport through its mobile app, and accepts international addresses.
The practical conclusion: go into a branch and speak to a person. The online form is an algorithm that trips over a missing address history. Branch staff work from the list of exceptions above.
Digital banks: where your money is protected and where it is not
This distinction is widely misunderstood and it is worth all of your savings.
Since 1 December 2025 the Financial Services Compensation Scheme covers deposits up to £120,000 per person per bank, raised from £85,000. Temporary high balances are covered to £1.4 million for six months. Firms had until 31 May 2026 to update their materials, so any page still quoting £85,000 is out of date.
But the cover applies only to actual banks:
- Monzo, Starling, Chase UK and Zempler are fully licensed banks. FSCS applies, up to £120,000.
- Wise is not a bank. It says so itself: it is an authorised electronic money institution, and "the e-money and payment services provided to you by Wise Payments Ltd are not subject to the Financial Services Compensation Scheme." Customer money is safeguarded in a segregated account, which is not the same thing.
- Revolut needs a careful sentence. Since March 2026 Revolut Bank UK Ltd is a fully licensed UK bank, authorised without restrictions, with FSCS cover to £120,000. But the migration of existing customers is staged and unfinished. New customers are set up as bank customers automatically; some existing accounts remain e-money accounts for now. Check the entity name in the app: Revolut Bank UK Ltd means FSCS cover, Revolut Ltd means not yet.
The difference shows up at the moment of failure. FSCS returns protected deposits "usually automatically and within seven days." If an e-money institution fails, in the FSCS's own words, "your money could be tied up for a while during the insolvency process."
Refused. What now
For a standard account a bank need not give a reason — and sometimes legally cannot. Where a suspicious activity report has been made, section 333A of the Proceeds of Crime Act 2002 makes disclosure an offence carrying up to two years. That is why staff sometimes genuinely cannot explain.
What to do:
- Ask for a basic account by name, at one of the nine designated banks: "I would like to apply for a payment account with basic features."
- If refused, ask for the refusal in writing with the reason. For a basic account this is the bank's duty.
- Complain to the bank. It has 8 weeks to respond — only 15 days for complaints about payment services, fraud and e-money.
- Then go to the Financial Ombudsman Service, within 6 months of the bank's final response. The service is free; you need no solicitor and no claims company.
You may be right to think a refusal was unreasonable. The FCA's own review of firms found the reasons given included "non-specific financial crime concerns", generalised suspicion of whole categories of customer, and — in its words — "alternative forms of ID not being accepted."
Closing an account without warning is no longer allowed
From 28 April 2026, for framework contracts entered into on or after that date, notice of terminating a payment account must be given at least 90 days in advance and must explain the reasons in terms "sufficiently detailed and specific to enable the payment service user to understand why the framework contract is being terminated", with information about how to complain. Older contracts keep the previous two months' notice.
The exceptions are real: no notice is required where customer due diligence cannot be applied, where closure is required under the Immigration Act 2014, where the provider has reasonable grounds to suspect the account is connected with serious crime, or where a regulator requires it.
For basic accounts the grounds for closure are themselves a closed list: illegal use, no transaction for more than 24 consecutive months, incorrect information at application, loss of legal residence in the UK, holding another qualifying account, or abusive conduct towards staff.
Note that 24-month rule. An account opened "just in case" and left untouched for two years can be closed lawfully.
A checklist for a new arrival
- Bring your passport and, if your status is UK-issued, an eVisa share code — it lasts 90 days, so generate it on the day you go to the bank.
- Go into a branch of one of the nine designated banks and ask for a basic account, not a standard current account.
- No utility bill? Bring what the official list allows: an employer's letter, a college letter, a benefits letter, a council tenancy agreement.
- If a member of staff says the law requires proof of address, that is not correct. Ask for a manager and refer to the JMLSG guidance on basic bank accounts.
- If refused, get it in writing and follow the chain: bank, then ombudsman.
- Once open, use the account. One transaction a year protects it from closure for dormancy.
- Payment Accounts Regulations 2015, reg. 22
- Payment Accounts Regulations 2015, reg. 23
- Payment Accounts Regulations 2015, reg. 25
- Payment Accounts Regulations 2015, reg. 26
- Basic bank accounts: July 2023 to June 2024 — HM Treasury
- Money Laundering Regulations 2017, reg. 28
- JMLSG Guidance Part I (June 2023, updated August 2025)
- JMLSG Guidance Part II, Sector 1 — retail banking
- FCA Handbook SYSC 6.3
- HSBC — basic bank account identification
- NatWest — what you need to open a current account
- Santander — customer identification documents
- Nationwide — proving your identity
- PRA confirms FSCS deposit limit increase to £120,000
- FSCS — banks and building societies
- FSCS — e-money and FSCS protection
- Revolut — UK banking licence status
- Wise — how customer funds are safeguarded
- Financial Ombudsman Service — how to complain
- FCA — access to payment accounts and closures
- Payment Services and Payment Accounts (Contract Termination) Regulations 2025


