ING Luxembourg Closes Accounts Opened for Spaniards in 2013

ING Luxembourg peine accounts for Spaniards in 2013 and is now closing them

ING Luxembourg no longer wants a large portion of its Spanish clients. What might have sounded like idle speculation in 2013 now has a long documentary trail: the Luxembourg subsidiary of the Dutch bank included residents in Spain among the countries admitted for opening its accounts online, removed them from that list barely a year later, and since the end of 2023, has been closing existing accounts via registered mail. It wasn't a slammed door, but a slow withdrawal. And in the middle, thousands of savers who moved money to Luxembourg in case the country took a turn that never came.

The detail matters because the declared reason was never the Spanish saver. It was the stagnant balance, the account without a direct debit, and the client who generates no commissions.

Free card, multi-currency, and a Flash form

The 2013 lure was hard to ignore. The Orange account was managed entirely online, with no maintenance fees, no statement fees, and a free card, plus an associated savings account. The list of available currencies was an entire navigation chart: euro, pound, Norwegian, Swedish, and Danish krone, dollar, Canadian dollar, Singapore dollar, Hong Kong dollar, Australian and New Zealand dollar, Swiss franc, South African rand, and yen. Additionally, it allowed the purchase of fixed-income bonds, something impossible at ING Spain.

There was one detail that grated from day one. The registration form was built entirely in Flash. A technical profile warned that this architecture compromised accessibility and likely transferred checks to the browser instead of the server. Its verdict was blunt: unprofessional. The bank didn't change it then.

The Model 720 and LU 11082217

With the account peine came the second hurdle: declaring it. Here, the case tracking split in two. One current of thought maintained that the opening had to be communicated to the Banco de España (Bank of Spain) with the corresponding form; another recalled that the real obligation with the Tax Agency arrived with Model 720, which is activated for amounts over 50,000 euros in deposits, securities, or real estate, counted separately without adding them together. And a third warning: accounts below 20,000 euros were outside the initial decree.

The practical problem was obtaining the entity's tax identification number. Several Spanish banks did not want to provide it. ING's response took time, but it came: LU 11082217. Years later, the DD1 form disappeared and was replaced by the Foreign Transactions Survey, which is only submitted for amounts over one million euros or when the Banco de España expressly requests it.

Minimums of 2,000 euros and 13 euros per quarter

In May 2014, the scenario changed. Spain stopped appearing on the list of countries that could be marked as residence. The bank added a filter: maintain 2,000 euros in the savings account or 1,000 euros in direct debits, or pay 13 euros per quarter in fees. By 2016, the requirement shifted to average minimum annual amounts.

Those who didn't pay noticed it later. The current account started costing 16 euros per year, the VPAY card was replaced by a debit Visa, and maintenance fee notices appeared at 1.75 euros per month. The bank itself closed current accounts due to lack of use before closing savings accounts.

Registered letters: the 2023 and 2024 closures

The final phase arrived by postal mail. Account holders with over a decade of seniority received a registered letter announcing the closure of their accounts: effective November 13th in some cases, effective January 8th, 2024 in others, always invoking article B.9 of the general conditions, which empowers the bank to terminate the contract at will. Nationale Nederlanden did the same with all its clients' savings accounts on the same day.

Affected individuals describe the same pattern: frozen balance, cancelled outgoing transfers, and a KYC review requested through channels no one had read in time. Repatriation required a signed letter with a Spanish destination account. Some recall receiving, in the midst of the process, a handwritten orange sheet with rounded lettering and a perfume scent asking for another form. The Iberian financial madmax many had prepared for ended up resolved in two weeks of administrative management.

Merger with BNP Paribas, planned for summer 2025

The official explanation has been trickling in. A subsequent letter informed of a business strategy change and the integration with BNP Paribas for summer 2025, offering a new account with the French entity. The most widespread interpretation among those trinc the matter is that ING Luxembourg is abandoning personal banking and shedding clients who only maintain a dormant balance. This had already peine in France and Belgium before.

What alternatives remain for having an account in Luxembourg?

Few, and with worse conditions. Other Luxembourgish entities now refer to an in-person appointment and practically only admit residents from neighboring countries. Advanzia maintains its card business, with deposits around 0.3% annually. Those seeking profitability have looked towards Portugal: a three-month deposit at 1.1% APR, maximum 50,000 euros, Portuguese guarantee fund, and a minimum of 500 euros to avoid commissions, with the drawback of a 28% withholding tax that can be reduced to 15% by presenting the tax residency certificate.

A closure that is not yet over

With Luxembourgish retail banking retreating and mergers on the table, it is foreseeable that the culling will continue, albeit in waves and with criteria the bank does not publish. It is also possible that the transfer to BNP Paribas will keep some accounts alive and leave the episode as a simple logo change. What should not be considered closed is the tax issue: information to the Banco de España changed forms and thresholds, and many people are still operating under the rules from ten years ago.

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Notice: this article summarizes experiences and regulations commented on by its protagonists. It does not constitute tax or financial advice.