Banks do not refuse holding companies; they refuse files they cannot follow. Since June 2026 a Luxembourg S.à r.l. can be incorporated before its account, as a Dutch B.V. always could, so the bank is no longer a blocker for the company, only for the money. Prepare the structure chart, source of wealth and purpose of the account before you apply; owners from high-risk countries face enhanced checks, and Russian owners a EUR 100,000 deposit cap.
The account, not the company, is the slow part
Incorporating a holding in Luxembourg or the Netherlands takes days to a couple of weeks. Opening its bank account can take weeks or months, and some applications never succeed. European banks carry the full weight of anti-money-laundering law: they must understand who owns the company, where the money comes from and what the account will be used for, and a holding company owned from abroad raises every one of those questions at once.
The good news for 2026: regulators on both sides are pushing back against blanket refusals, and Luxembourg removed the old chicken-and-egg problem of needing a bank before the notary.
New since June 2026
An S.à r.l. can now be incorporated before its bank account and pay in its EUR 12,000 capital within 12 months.
Incorporate first
A B.V. needs no bank at incorporation; the account follows the KvK registration.
Same questions
Owners, source of wealth, structure, purpose of the account.
Luxembourg: the blocking certificate is optional now
Until June 2026 a Luxembourg S.à r.l. paid in cash could not be incorporated without a bank's blocking certificate showing the EUR 12,000 on a blocked account. That meant passing the bank's KYC for a company that did not exist yet.
- The new route. Since 2 June 2026 the articles may defer payment of the EUR 12,000 minimum capital for up to 12 months. The company is incorporated first, and the account is opened in parallel.
- What cannot be deferred. Capital above EUR 12,000, share premium and contributions in kind. Unpaid amounts are disclosed with the accounts.
- KYC is unchanged. The reform moves the bank out of the critical path to incorporation; it does not make the bank faster.
- Regulator pressure. The CSSF said in June 2026 that a higher risk alone does not justify refusing a client. The banking association keeps a directory of more than 120 institutions open to new business clients.
The Netherlands: easy to incorporate, careful to bank
A Dutch B.V. is registered without a bank and with capital from EUR 0.01. The account comes after, and Dutch banks are known for thorough onboarding of non-resident-owned companies: expect questions about the link with the Netherlands, the countries the company deals with and the owners' background.
- Documents. Articles, shareholder register, KvK extract and UBO confirmation, IDs of the directors and owners, and the list of countries you do business with.
- A right to an account is coming. The Dutch parliament passed a law in May 2026 giving businesses registered in the KvK from EU member states a right to a basic payment account. Banks can still refuse on concrete AML grounds; the start date is not yet set.
- Local presence helps. A resident director and a real address make the link with the Netherlands that banks look for.
Banks do not refuse holdings. They refuse files they cannot understand. A one-page chart and a paragraph on the source of wealth open more doors than any introduction.
How bankable is your holding?
Tick what you already have. The result shows the route and the pacing items.
How bankable is your holding?
Three questions and a document list. You see the likely route, the pace and what to fix before you apply.
When the owners live outside the EU
| Owner profile | What changes |
|---|---|
| EU, EEA, Swiss, UK or US residents | Standard due diligence; the fastest case |
| Residents of other countries | Standard or enhanced due diligence depending on the country and the source of wealth |
| Countries on the EU high-risk list | Enhanced due diligence is mandatory; since 29 January 2026 the list includes Russia and the British Virgin Islands |
| Russian nationals without EU residence | Enhanced due diligence plus the sanctions cap: banks may not accept deposits above EUR 100,000 from them; EU residence permits lift the cap |
From July 2027 a single EU anti-money-laundering rulebook applies directly in every member state. Expect the same questions everywhere, not easier ones.
Payment institutions as a bridge
Electronic money institutions and neobanks such as Revolut Business, bunq or Wise onboard faster and accept holding companies, usually asking for proof of what each subsidiary does. They work well for paying costs and receiving dividends while a bank application runs. Their limits: no credit, restrictions for some nationalities and sanctioned-country links, and some counterparties, notaries and tax offices still prefer a bank.
Luxembourg dropped the blocking certificate requirement in June 2026.
Chart, source of wealth, purpose of the account.
High-risk countries mean enhanced checks; Russian owners face a deposit cap.
A payment institution covers the first months.