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Online bank failure in Belgium: who pays you back, and when

If an online bank or neobank fails: the 7 working day payout rule, which fund pays a Belgian resident, real Belgian precedents and what to prepare now.

ByMaxime10 min read

If your online bank fails, a deposit guarantee scheme must repay you up to 100,000 euros within 7 working days. That scheme is not necessarily Belgian, the deadline has only existed since 2024, and it does not apply at all to electronic money institutions. I went back over the failures that hit depositors in Belgium to see how things actually played out.

Seven working days, and an account elsewhere

The rule fits in one line of Directive 2014/49/EU: when a licensed bank can no longer return its customers' money, the deposit guarantee scheme repays each depositor up to 100,000 euros, within a deadline cut to 7 working days since 2024. In 2023 it was still 10 working days.

Seven working days is not a week. A failure declared on a Friday means repayment by the Tuesday of the second week at the latest, eleven calendar days later, and more if a public holiday falls in between.

The second point is practical, and almost nobody thinks of it. The scheme pays you into an account. When Optima Bank failed, the Belgian Guarantee Fund, run by the FPS Finance (the federal finance ministry), asked depositors for an account number "valid at another bank", to be entered in MyMinfin, the ministry's online portal, under "Mon patrimoine".

Can an online bank go bankrupt?

Yes. No more and no less than a bank with branches: the legal status is the same, and the lack of a counter changes nothing about the risk.

I gathered six failures that mean something to a customer in Belgium today. Three involve banks, three involve firms that are not banks, and the mix is deliberate: the two stories do not end the same way.

DateInstitutionStatusEventCustomers' access to their money
October 2008Kaupthing Bank Luxembourg, Belgian branchBankCollapse of the Icelandic parent, accounts frozenAbout nine months: accounts released on 16 July 2009
November 2011Snoras, LithuaniaBankNationalisation, then bankruptcyCompensation by the Lithuanian scheme, funded by a state loan
June 2016Optima Bank, BelgiumBankDefault declared on 9 June 2016Belgian Guarantee Fund, claims via MyMinfin until 9 June 2017
August 2019Ipagoo, United KingdomElectronic money institutionAdministration on 1 August 2019Safeguarded funds returned by the administrators, no deposit guarantee
June 2020Wirecard Card Solutions, United KingdomElectronic money institutionActivity suspended by the regulator after Wirecard's insolvencyRestrictions lifted on 29 June 2020, after a few days of blocked cards
April 2024Synapse, United StatesTechnical intermediary, not a bankBankruptcy filing on 22 April 2024About 158.6 million dollars still owed to end users in July 2024, with an estimated shortfall of 65 to 95 million

Sources: VRT NWS (16 July 2009), Bank of Lithuania (25 November 2011), FPS Finance (2016), FCA (2 August 2019), FinTech Futures (30 June 2020), TechCrunch (22 August 2024). Table compiled on 12 October 2026.

Payment card on a dark desk next to a smartphone showing a banking app
Licensed bank or electronic money institution: a failure does not end the same way.

Kaupthing, 2008: nine months for 20,000 Belgian customers

The most instructive story for a reader in Belgium is not about a neobank, but it has all the mechanics of one.

Kaupthing Bank Luxembourg had a branch in Belgium that collected savings from Belgian individuals. In October 2008, the Icelandic parent collapsed. Around 20,000 Belgian customers saw between 500 and 550 million euros frozen overnight, according to VRT, the Flemish public broadcaster. Their deposits fell under the Luxembourg guarantee, since the bank was licensed in Luxembourg, and the Belgian branch changed nothing about that.

It took a restructuring approved by the Luxembourg regulator, a letter from the Belgian Prime Minister of the time to customers in December 2008 and a takeover of the accounts by Crédit Agricole Belgique and Keytrade Bank before the money was released, on 16 July 2009. Nine months without access to one's savings.

Two features of that case are found as they are in the neobanks active in Belgium: a licence issued in another country, and a Belgian presence that does not move the guarantee. The deadline, on the other hand, has changed. In 2008, the 1994 directive then in force still gave guarantee schemes three months, extendable. Today the directive requires 7 working days, and no neobank has yet had to put that rule to the test in a large failure.

Revolut, N26 or bunq going bust: which scheme pays a Belgian customer?

The scheme of the country that issued the licence, not the Belgian one. That follows directly from the European passport.

NeobankLicensed entityGuarantee schemeCeiling
RevolutRevolut Bank UAB, LithuaniaLithuanian public body for deposit and investment insurance, Vilnius100,000 euros
N26N26, GermanyEntschädigungseinrichtung deutscher Banken (German banks' compensation scheme)100,000 euros
bunqbunq B.V., NetherlandsDutch scheme run by De Nederlandsche Bank100,000 euros
WiseWise Europe SA, BelgiumNone: electronic money institutionNo guaranteed ceiling

Revolut information sheet and N26 help page consulted on 12 October 2026; bunq and Wise statuses checked on 23 August 2026 in their legal notices.

One nuance deserves a closer look. Article 14 of the directive provides that customers of a branch are paid by the host country's scheme, on behalf of the home scheme, which advances the money and reimburses the costs. Revolut has a branch in Belgium. On paper, a customer attached to that branch could therefore receive the repayment through the Belgian Guarantee Fund, with Lithuanian money.

I reread Revolut's information sheet for Belgian customers on 12 October 2026 to check. It mentions only the Lithuanian scheme, with its Vilnius address and phone number, and says nothing about a Belgian relay. Revolut also distinguishes, in its complaints policy, between customers of its Belgian branch and customers of Revolut Bank UAB. I cannot tell you which category your account belongs to, and the sheet does not say either: it is a question to put in writing to customer support, keeping the answer.

For N26, the help page consulted the same day refers only to the German scheme, with no Belgian relay at all.

A Belgian IBAN changes none of this. Since 2025, Revolut has been giving IBANs starting with BE to its new Belgian customers, and many conclude that their money is now "in Belgium". The account number prefix shows where the account is held, not which scheme guarantees it. A BE IBAN at Revolut is still a deposit with Revolut Bank UAB, covered from Vilnius.

Trade Republic illustrates the next case, a neobank that opens a branch. Registered with the FSMA, the Belgian financial markets authority, as the Belgian branch of a German credit institution since 7 July 2026, it falls under the German guarantee for the deposits it holds itself. Its help page nevertheless states that customer money is placed in trust accounts at several partner banks, each covered up to 100,000 euros per customer. The part invested in money market funds is not a deposit at all. One app can therefore cover three different protection regimes, and that is the first thing I check when a reader asks me whether their savings are "safe" there.

The Lithuanian scheme has paid out once before, with state help

A guarantee scheme never holds the money it covers, and that is normal.

The directive requires it to hold at least 0.8% of covered deposits. The Lithuanian scheme reported in July 2025 that it stood at about 0.96%, less than one euro in reserve for every hundred euros guaranteed. The rest relies on backup funding: extraordinary contributions from banks, borrowing and, as a last resort, the state.

Lithuania has been through it. When Snoras failed in November 2011, the Bank of Lithuania put compensation at about 4.1 billion litas, roughly 1.19 billion euros, with almost 90% of depositors repaid in full. The scheme did not have that sum: the government lent it 3.3 billion litas, about 956 million euros, according to The Baltic Times of 6 December 2011. Depositors were paid.

The timeline deserves a close look, because it shows what a mass payout looks like. The insured event is dated 24 November 2011. The first payments went through SEB, a commercial bank appointed as paying agent for the Vilnius region, with other banks sharing the other cities. On the first day, 1.665 billion litas were paid out, about 40% of the planned total. Lithuanian law at the time gave the scheme 30 working days, and most customers immediately placed their compensation in another bank in the country.

My view, and it is a view: this precedent is rather reassuring about the will to pay, and it also shows that the 7 day deadline assumes a state ready to advance the money very quickly. Revolut claimed more than a million retail customers in Belgium alone in March 2026, according to Forbes Belgium. Snoras had a little over 400,000 individual depositors: the Lithuanian scheme has never had to compensate a customer base the size of Revolut's.

Electronic money institution: no scheme, an administrator

Wise and Vivid are not banks, and their official pages say so plainly. Their protection is called safeguarding: customer money is kept apart from the company's, in segregated accounts or in money market funds. In a bankruptcy, it does not become part of the estate shared among creditors.

Ipagoo shows what that means. The UK regulator announced on 2 August 2019 that the firm had gone into administration, stating that the UK compensation scheme does not cover electronic money: the administrators first had to assess the safeguarded funds, then return them "as quickly as possible". No deadline in figures.

Wirecard Card Solutions was the opposite case, a happy one. The regulator suspended its activity at the end of June 2020, the day after the German parent's insolvency, then lifted the restrictions on 29 June. A few days of blocked cards at Curve, Anna or Pockit, and Revolut switched to other systems. Synapse, in the United States, is the dark case: safeguarding assumes perfect bookkeeping, and when the bookkeeping is missing, so is the money.

At Wise, the European entity is Wise Europe SA, licensed by the National Bank of Belgium as an electronic money institution. Vivid, for its part, says it safeguards most funds in a money market fund managed by BNP Paribas Asset Management. In both cases, the failure scenario is not a bank's. No guarantee scheme steps in, no 7 day clock runs, and restitution depends on the quality of the institution's records. For a balance covering everyday spending, that risk is small; for savings of several tens of thousands of euros, it weighs more than the fee difference between two apps.

What can you do today to be repaid quickly?

Nothing complicated, and it all has to be prepared beforehand. The habits I apply to my own accounts:

  • keep an account at another institution, into which a scheme could pay your repayment, with enough to last a month of spending;
  • note the exact name of the legal entity in the terms and conditions, not the app's name;
  • know whether your neobank is a licensed bank or an electronic money institution, which changes the whole scenario;
  • stay under 100,000 euros per institution, counting together every account and vault you hold with it;
  • export a balance statement every quarter, so you can prove what you held if the app stops responding;
  • check that you can log into MyMinfin with itsme, the Belgian digital ID app, or your eID card, since that is where a claim to the Belgian Guarantee Fund goes.

The ceiling is calculated per depositor and per institution. A single person holding 130,000 euros at Revolut has 30,000 euros uncovered. A couple with a joint account of 150,000 euros at the same bank is in principle fully covered, each co-holder counting for 75,000 euros. Sums placed in money market funds or shares fall under another regime, which we explain in our article on e-money institutions versus banks.

Person checking their account balance in a banking app

In short

An online bank can fail like any other bank, and your money there is protected in the same way: up to 100,000 euros by the scheme of its licensing country, within 7 working days since 2024, into an account you will have opened elsewhere. Belgian customers of Kaupthing waited nine months in 2008 because that rule did not exist yet. Electronic money institutions sit outside this framework: no scheme, an administrator, and a deadline nobody can promise. Each neobank's status is set out in our article on neobank deposit protection, and our comparator lines them up side by side.

This article gives general information on deposit protection; it is neither legal advice nor investment advice.

Sources: Directive 2014/49/EU on deposit guarantee schemes, articles 8 and 14; Guarantee Fund for Financial Services (FPS Finance), notice on Optima Bank, 2016; Test-Achats, "Banque en faillite : quand récupérer vos avoirs protégés"; Revolut Bank UAB deposit insurance information sheet (fr-BE) and N26 help page on deposit protection, consulted on 12 October 2026; VRT NWS, 16 July 2009; CSSF, restructuring of Kaupthing Bank Luxembourg, July 2009; Bank of Lithuania, 25 November 2011; The Baltic Times, 6 December 2011; Indėlių ir investicijų draudimas, 25 July 2025; FCA, 2 August 2019; FinTech Futures, 30 June 2020; TechCrunch, 22 August 2024; Forbes Belgium, 18 March 2026.

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Frequently asked questions

If it is a licensed bank (Revolut, N26, bunq), the guarantee scheme of its licensing country repays you up to 100,000 euros within 7 working days. If it is an electronic money institution (Wise, Vivid), safeguarded funds are returned by the insolvency administrator, with no guaranteed ceiling and no legal deadline.

Like any bank, yes. Revolut Bank UAB is licensed in Lithuania: its deposits are covered by the Lithuanian public deposit insurance body, up to 100,000 euros per depositor and within 7 working days according to Revolut's information sheet consulted on 12 October 2026.

Not with its own money. The directive provides that the host country scheme pays the customers of a branch on behalf of the home scheme, which advances the sums. For a neobank with no branch in Belgium, the foreign scheme pays directly.

It is strongly advisable. In 2016, Optima Bank depositors had to provide an account number held at another bank to receive their repayment. Without such an account, the money waits while you sort it out.

Maxime suit le secteur des néobanques et de la fintech belge depuis près de dix ans. Ancien conseiller en agence devenu analyste indépendant, il ouvre et teste lui-même les comptes qu’il compare, décortique les grilles tarifaires ligne par ligne et traque les frais cachés derrière les offres « gratuites ». Son objectif : aider les Belges à payer moins et choisir une banque qui colle vraiment à leur usage, sans jargon ni argument commercial.

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