A business bank account closed, restricted or scheduled for closure can leave payroll, suppliers and customer refunds without a payment route. The first decision is which services remain available and how the company can meet its obligations lawfully.
This review covers a UK technology or fintech company with international revenue and reliance on one UK operating account. It produces a contract and notice assessment, an information-response checklist and a payment continuity plan. Brazilian or Kenyan connections are assessed through the people, entities and transactions involved.
Start the continuity work when the notice arrives. A complaint does not itself extend the closure date or release restricted money.
Establish what has happened to the account
The provider's legal entity, account holder and product determine the starting point. A familiar app name or UK account number does not establish a bank deposit. A payment institution or electronic money issuer may supply the account.
The review separates five situations:
- Closure ends the account relationship on the stated terms and date.
- A restriction blocks particular functions, payments or access, potentially while the relationship continues.
- A statutory freeze or court order can prohibit dealing with money independently of contractual notice.
- An ownership or signing-authority dispute requires evidence of entitlement and authority before instructions can safely proceed.
- A merchant-acquirer reserve concerns settlement under a separate acquiring agreement. It may survive the operating account's closure.
A payment-instrument block and refusal of a payment order have distinct statutory conditions. Neither should be treated automatically as termination of the whole account. Court-ordered freezing requires assessment of the order and any permitted exclusions. (Payment Services Regulations 2017, regs. 71 and 82; Proceeds of Crime Act 2002, ss. 303Z1–303Z5.)
Acquiring reserves and replacement processor selection belong with Choosing a Payment Processor. If a fintech's programme exit affects customer accounts or balances, the scope also changes. The banking-as-a-service exit analysis addresses that separate provider-and-customer relationship.
Check which notice rules apply
UK account closure rules do not give every business 90 days. The review establishes the payment contract's commencement, duration, applicable terms and customer classification.
For an indefinite framework contract made before 28 April 2026, the ordinary statutory rule permits provider termination, where the contract allows it, with at least two months' notice. For one made on or after that date, the ordinary rule requires at least 90 days, sufficiently detailed and specific reasons, and complaint information. The notice must meet the statutory communication requirements. (Payment Services Regulations 2017, regs. 51A–51B and 55; S.I. 2025/688, regs. 1(2) and 3(4).)
These rules sit within Part 6 of the Regulations. A business outside the consumer, micro-enterprise and qualifying-charity categories may agree to disapply some or all of that Part. Being a company does not itself remove the protection. Group relationships and the relevant financial and staffing figures can affect micro-enterprise status. (Payment Services Regulations 2017, regs. 2 and 40(7); Recommendation 2003/361/EC, Annex, arts. 1–6.)
The newer regime has specific exceptions. Inability to complete required customer due diligence, specified crime concerns and certain official requirements can disapply its notice requirement. Specified threatening or abusive conduct, or qualifying incorrect application information, can remove the 90-day period while preserving a notice obligation. Conflicting legal duties also matter. The exact ground must be checked against the relevant provision. (Payment Services Regulations 2017, regs. 51B(4), 51C–51D.)
A revised terms document does not necessarily establish a new contract date. Fixed-term arrangements, credit-related exceptions and contractual termination rights require their own analysis. The resulting timeline supports transition planning; deciding whether a defect supports a claim requires the separate service check below.
What the engagement produces
Account, contract and notice assessment
The assessment identifies the contracting entities, product, governing law, operative terms and notice mechanism. It records the provider's stated closure date, any restrictions already active and the conditions affecting available services.
The working file preserves the original agreement, later variations, notices and delivery evidence. It distinguishes the contractual timetable from payment cut-offs and any legal restriction. Missing facts remain identified rather than converted into assumed rights.
Evidence and information-response checklist
The checklist maps each outstanding request to its purpose, deadline, supporting record and responsible person. Relevant documents can include ownership information, invoices, customer contracts, source-of-funds evidence and an explanation of unusual transactions.
UK due diligence includes identifying the customer and beneficial owners, understanding the relationship and monitoring transactions. If the required checks cannot be completed, the provider may be required to end the relationship. (Money Laundering Regulations 2017, regs. 28 and 31.)
Responses should be accurate, consistent and limited to the requested issue. The file should explain genuine discrepancies and retain evidence of submission. A request for clarification cannot assume that the provider may disclose every reason; statutory restrictions on disclosure can apply. (Proceeds of Crime Act 2002, s. 333A.)
Payment, balance and record continuity plan
The plan assigns an owner and next action to each unsettled item:
- Payroll and supplier payments: confirm funding, approval rights, submission cut-offs and execution status before sending replacement instructions.
- Direct debits and recurring payments: identify mandates requiring amendment, cancellation or recreation, and obtain the relevant confirmations.
- Incoming transfers and customer refunds: agree how rejected, returned or late payments will be identified and reconciled.
- Balances: distinguish available money, restricted sums, disputed deductions and acquiring reserves; request the applicable release or repayment process.
- Records: export statements, payment confirmations, mandates, correspondence and reconciliation files while access remains available, then confirm later access arrangements.
A closure notice does not make every displayed balance immediately transferable. E-money redemption follows its own rules, alongside applicable legal restrictions. Company accounting obligations continue after account access ends. (Electronic Money Regulations 2011, regs. 39–44; Companies Act 2006, ss. 386 and 388.)
The replacement provider must accept the actual company, activity and transaction pattern. The plan identifies the receiving legal entity, account title, currencies and payment functions. It preserves ownership and source-of-funds disclosures and verifies changed payment instructions before use. It does not use personal or undisclosed third-party accounts to conceal the business or bypass restrictions.
Cross-border route and escalation map
Founder nationality alone does not identify the applicable cross-border rules. Establish residence, the holder of each account, the payer, the recipient and the purpose of each movement.
For a Brazilian connection, distinguish customer revenue, shareholder funding and payments involving Brazilian residents or the Brazilian foreign-exchange market. The selected route must fit the applicable authorised-provider and transaction rules. Brazilian foreign-asset reporting turns on the resident holder and reportable assets; a UK account change is not, by itself, the reporting test. (Lei 14.286/2021, arts. 1, 3–4, 8 and 10; Resolução BCB 277/2022, art. 13; Resolução BCB 279/2022, arts. 1 and 7–8.)
For a Kenyan connection, identify whether the proposed route adds local collections, foreign-exchange business or remittance services. Obtain a current Kenyan regulatory assessment before introducing those features. A UK replacement account does not establish permission to provide them.
Where the company handles other people's money, the activity and safeguarding arrangements need a separate assessment. Payment and E-Money Licensing addresses that licensing decision.
The escalation map identifies unresolved restrictions, deadlines and the specialist role required. It separates operational questions from claims advice, regulated representation, insolvency or court work.
Define the service before work begins
The engagement covers contract diagnosis and lawful continuity planning within an agreed scope. It excludes seeking compensation, account reinstatement or other redress, conducting a complaint, negotiating a claim and litigation unless a separate lawful basis is established.
Claims-management regulation can cover advice, investigation and referrals, even when the business sends the complaint itself. The permission or applicable exclusion must therefore be checked before undertaking those activities. Court representation and reserved legal work require their own entitlement assessment. (Financial Services and Markets Act 2000, ss. 19 and 419A; Regulated Activities Order 2001, arts. 89G, 89I and 89N; Legal Services Act 2007, ss. 12–14 and sch. 2.)
The review does not promise a replacement account, a bank introduction, release of funds or a favourable complaint outcome.
Documents needed to scope the review
Provide the account agreement and variations, closure or restriction notices, recent statements and outstanding information requests. Include the company and ownership structure, relevant financial figures, regulatory status and countries involved.
Add a schedule of payroll, suppliers, refunds, direct debits, incoming receipts and disputed balances. Identify any court order, existing complaint, ownership dispute or proposed replacement route at intake.
Questions before commissioning the review
Can work start after the account has already closed?
Yes. The focus becomes outstanding payments, remaining balances, records and an accepted replacement route. Urgent restrictions or court deadlines may require a specialist mandate first.
Can a business use the Financial Ombudsman Service?
Some can. Eligibility includes qualifying micro-enterprises and small businesses, with financial, staffing, group and timing tests. The relationship with the provider and the complaint must also fall within jurisdiction. A company's size label alone does not establish eligibility. The eligibility exclusions, including those concerning a regulated business's own permitted activities, also need checking. (FCA Handbook, DISP 2.7.3R(2) and (6), 2.7.4G, 2.7.6R and 2.7.9R; Glossary, ‘micro-enterprise’ and ‘small business’.)
How long does the provider have to answer a complaint?
Payment-services and e-money complaints within the relevant rules ordinarily require a final response within 15 business days after the day of receipt. Exceptional circumstances beyond the provider's control can extend that to 35 business days after the day of receipt, with a holding response due within the first 15 business days. Other complaints ordinarily use the eight-week process; a closure dispute must be classified by its issues. Referral deadlines, including the usual six-month period from the date the provider sends a qualifying final response, must be checked separately. (FCA Handbook, DISP 1.6.2R, 1.6.2AR–1.6.2BR and 2.8.2R–2.8.3G; Glossary, ‘PSD complaint’ and ‘EMD complaint’.)
Does a complaint preserve the existing payment route?
A complaint should run alongside continuity planning. Closure, restriction and payment dates remain operational constraints unless the provider or a competent authority changes the position.
Does having a payments licence secure another bank account?
No automatic acceptance follows. Qualifying payment service providers and applicants have specific bank-access protections, including objective, non-discriminatory and proportionate access criteria. Whether they apply depends on the statutory category and facts. An ordinary technology company cannot claim them merely by describing itself as fintech. (Payment Services Regulations 2017, reg. 105.)