Each summer following the annual/ordinary General Assembly, many Belgian non-profit organisations (“NPOs”) are contacted by their banks to update their KYC (Know Your Customer) and AML (Anti-Money Laundering) documentation. While this is a recurring obligation, the 2025 campaign has brought new challenges and expectations. EY Law has assisted numerous NPOs through this process and observed several key developments. This article outlines the latest trends in KYC/AML documentation requests and provides practical guidance to help NPOs navigate this increasingly complex exercise.

Banks are legally required to maintain up-to-date information on their clients, including NPOs. While these compliance exercises were previously conducted approximatively every two years, we noticed that in general they are now carried out annually. As part of this process, banks request identification documents and proof of residence for the organisation’s ultimate beneficial owners (“UBOs”)—typically the directors and the person entrusted with the daily management of the NPO. Failure to provide the requested documentation in due time may result in the blocking of the organisation’s bank account, which can severely disrupt operations. The burden is even greater for NPOs with accounts in multiple banks, as each institution applies its own procedures and documentation requirements.

This summer, EY Law has identified four notable trends in the KYC/AML documentation requested by Belgian banks:

• Proof of residence: In addition to a valid ID, banks now consistently request a document evidencing the residential address of each UBO. This may include a utility bill, a certificate of residence, or another official document. This requirement applies even when the address is already mentioned on the ID document. It is important to note that the document must be recent—typically no older than three months—and is requested even for Belgian citizens or residents.
• Place of birth: While the place of birth was previously overlooked or satisfied by indicating only the country, banks now systematically request the full place of birth (city and country). This can be a challenging detail, as several countries do not mention the place of birth on ID cards or passports. Be aware that some service providers subject to KYC/AML compliance have even requested a separate document evidencing this information, despite its absence from traditional ID documents.
• Royal Decree: Some banks now request a copy of the Royal Decree granting legal personality for their clients being international non-profit associations and foundations of public utility. These requests have occurred even when the NPO was incorporated decades ago and has been a longstanding client of the bank.
• UBO transparency for legal entities managing NPOs: When the person responsible for the daily management is a legal entity (e.g. a management company), whether Belgian or foreign, banks now require full UBO disclosure for that entity as well. This includes identification of the UBOs, the individual(s) authorised to represent the management company, and supporting documentation (e.g. an excerpt from the local UBO register, organisational charts, ID, and proof of residence for each individual). This requirement should be carefully considered by secretary generals, directors general, and executive directors, as it may involve disclosing personal information—particularly where the management company is jointly owned with partners or family members.

Despite harmonisation efforts at the EU level, each bank applies its own KYC/AML procedures. It is therefore not uncommon for NPOs to receive different requests from different banks within the same month. For example, one bank may ask for a copy of the Royal Decree granting legal personality, while another may request notarised documentation instead.

The lack of standardisation across banks increases the administrative burden on NPOs, often leading to confusion and delays. Being prepared is essential. To help your organisation respond efficiently to KYC/AML requests, we recommend the following:

• Anticipate the summer wave: Prepare a KYC/AML file in advance, including updated IDs and proof of residence for all UBOs. If you know that banks conduct their compliance checks annually, start collecting the required documentation early. Do not forget to update your file whenever there are changes in the board of directors.
• Centralise documentation: Maintain a secure and accessible repository of all KYC/AML documents. This will save time and reduce the risk of missing or outdated information.
• Assign a contact person: Designate someone within the organisation to coordinate responses to banks. We also recommend appointing a back-up contact during the summer period. It is not unusual to receive a request in mid-August with a ten-day deadline to provide all required documentation. Banks will not accept the absence of the designated contact person as a valid excuse.
• Raise awareness amongst directors: Directors – who are typically the UBOs of the NPO – must be made aware of their responsibility to promptly provide the required KYC documentation upon request. This is not only a matter of good governance but also a legal duty. Failure to comply can lead to serious consequences, including the blocking of the organisation’s bank account. Directors should understand that their cooperation is essential to maintain the organisation’s financial operations.
• Seek legal support: When in doubt, consult with legal counsel to ensure compliance and avoid account disruptions. Professional guidance can help you interpret complex requests and respond appropriately.

KYC/AML compliance is a legal obligation that cannot be avoided or ignored. While the process can be burdensome—especially during the summer months—it is manageable with proper planning, clear internal coordination, and timely responsiveness from directors and UBOs.

Changes to AML legislation are expected in 2026 and may impact NPOs. EY Law will closely monitor these developments and keep you informed of any new obligations.

If you have any questions or concerns related to non-profit law or KYC/AML compliance, Antoine DRUETZ, Partner, and his team will gladly assist your organisation.