Recently a new collegue joined our group and faced a bureaucratic paradox: Without a German bank account he could not get his salary. And without his salary he could not apply for apartments. But without a registered residence he could not open a German bank account. Complete deadlock.
When the problem came up, I vaguely remembered a 2013 debate on banking for homeless people in the Berlin state assembly. So I knew there had to be a way to get an account without a registered residence. And as it turns out, a lot has changed since that debate: As of 2016 all consumer banks in Germany have to provide a “Basiskonto”, literally a basic account, to any person legally in Germany. This includes all EU citizens, and many other legal residents (especially refugees and homeless people). Crucially, the application for a Basiskonto only requires a postal address, not proof of a registered residence.
So how do you apply for a Basiskonto? If you don’t mind paying a small monthly fee it is very simple: You fill in the standardised application form, walk into your favourite consumer bank and hand it to them. They will ask you for some ID (to prove you are legally in Germany) but they cannot ask you for proof of registration. If they do, politely inform them they are breaking the law and that you will complain to BaFin, their regulatory authority.
Some online banks offer a Basiskonto for free but the application process may be a little more complicated. Online banks often rely on the PostIdent process to verify your ID and postal offices are probably not familiar with the intricacies of banking regulation. I looked at the procedures of two popular online banks, comdirect and DKB. Please note, I did not test them because I already have a bank account and therefore ineligible.
DKB offers a free Basiskonto after a PostIdent check. Unfortunately, their instructions suggest that they require a proof of registered residence (“aktuelle Meldeanschrift”) which might be a typo but could also be a blatant violation of their duty to provide accessible banking. To anyone who quickly needs a bank account DKB is out.
Comdirect on the other hand seem quite accessible. They also ofer a free Basiskonto after a PostIdent check. Their forms do not mention any proof of registration. Instead their forms contain the option to file two addresses: One registration address and one postal address. It seems almost hand-made for EU citizens who are still registered in their home country and now staying at a temporary residence in Germany.
Whatever option you choose, there are two institutions who can help you if a bank is denying you access to basic financial services: Firstly, BaFin can compel the bank to open an account for you, if you are eligible. In case you are wondering, BaFin have compelled banks in more than 100 cases already. Secondly, Verbraucherzentrale (Consumer center) can advise you and might, in extreme cases, litigate on your behalf. They are currently collecting reports on compliance with the new law.