By: Money Navigator Research Team
Last Reviewed: 16/01/2026
FACT CHECKED
Quick Summary
Banks can ask for documents when they’re reviewing an account for possible restriction or closure. The requests are usually aimed at answering a few core questions:
- Who controls the business?
- What the business does?
- Where money is coming from?
- Whether the account activity matches what the bank understands about the customer
Requests vary by bank and by situation. In many cases, the most practical impact is that account features (especially outgoing payments) may remain limited until the review is completed.
This article is educational and not financial advice.
Why banks ask for documents during a closure or restriction review
Document requests often arise from ongoing monitoring and customer due diligence obligations, as set out in the UK’s anti-money laundering framework and supporting industry guidance. See the legislative framework in the Money Laundering Regulations 2017 and the industry guidance used by many firms (JMLSG).
Regulators have also published work on payment account access and closures (including oversight, governance, and decision-making expectations).
This does not mean a particular customer has done anything wrong. It means the bank is seeking enough evidence to support a defensible decision about whether it will continue the account relationship and on what terms.
The most common categories of documents banks may request
Below are typical categories (examples, not a checklist). The exact wording and scope can differ by bank, and the “must have” items often depend on what the bank is trying to clarify.
Banks may re-check:
identity documents for directors/partners/authorised signatories
proof of address (particularly if records are out of date)
ownership and control information (including who ultimately owns or controls the business)
group structure information where there are multiple entities or complex ownership
This overlaps with onboarding, but it is often triggered because something has changed or because records need to be refreshed. Related onboarding guide: What documents banks check for business bank accounts
What the business does and how it trades
Banks may ask for evidence that demonstrates the trading model, such as:
contracts, statements of work, or engagement letters
invoices issued and invoices received
purchase orders, delivery/fulfilment records, or service completion evidence
website/storefront details and trading names
refund/returns terms used with customers (where relevant to activity)
Source of funds and transaction explanations
Banks may ask for documents that evidence where specific money movements came from, for example:
bank statements showing the origin of a transfer
loan or investment documentation (where funding is being injected)
sale documentation for an asset sale or business sale
explanations and supporting evidence for large, unusual, or high-velocity flows
Tax, payroll, and financial footprint
Where account activity suggests payroll, VATable sales, or significant trading volume, banks may request:
management accounts or filed accounts (where available)
VAT registration evidence and VAT returns (if registered)
payroll summaries / PAYE references / payroll provider outputs (where payroll flows are visible)
(If payroll is impacted by restrictions or closure, see: Can payroll still run if a business account is being closed or restricted? if/when it exists in the sitemap export – it is not in the provided export, so it is not linked here.)
Where restrictions meet card payments and disputes
If card settlement, refunds, disputes, or chargebacks are part of the account profile, a bank may request evidence linked to sales fulfilment and refund handling. For related mechanics in restriction contexts, see: Chargebacks when a business account is frozen
Restriction vs closure: why the same documents can lead to different outcomes
A restriction is often a control state (what the bank will allow the account to do today). Closure is an end of the relationship, often after a notice period unless an exception applies.
For definitions and practical differences, see: Difference between frozen and closed business bank account
For the complaint-handling lens on closures and notice, see: Financial Ombudsman Service guidance on bank account closures
Summary table
| Scenario | Outcome | Practical impact |
|---|---|---|
| Bank requests updated identity/authority documents | Review continues until checks complete | Some features may remain limited during review |
| Bank requests trading evidence (contracts/invoices) | Bank assesses whether activity matches the business profile | Delays if evidence is incomplete or inconsistent |
| Bank requests source-of-funds evidence for specific credits | Bank validates origin and purpose | Some transactions may remain questioned until evidenced |
| Bank requests payroll/tax records | Bank cross-checks scale/regularity of flows | Additional scrutiny of recurring high-value payments |
| Review ends in closure | Account is exited under terms/notice (where applicable) | Remaining balance and payment disruption become the next operational issues |
Why banks may give limited detail about “why” (and focus on documents instead)
In some circumstances, banks limit the explanation they provide, including where disclosures could prejudice investigations or breach legal constraints.
The UK’s money laundering offences framework includes offences around disclosures and prejudicing investigations; this is one reason customers may receive limited narrative and more focus on “please provide X documents”.
This does not mean an adverse conclusion has been reached; it means the bank may not be able (or willing) to share detail beyond the evidence request and the outcome.
What happens if documents are not provided (or can’t be provided)
Common operational outcomes include:
restrictions staying in place while the bank waits for evidence
tighter controls on outgoing payments while review is open
the bank deciding it cannot continue the relationship and moving to closure
If closure happens, the next practical question is often timing and routing of any remaining funds: How long banks return remaining balances after account closure
Where the issue is prolonged back-and-forth and delays, the underlying mechanics can resemble onboarding delay causes (different process, similar friction points): Why business bank account applications get delayed
Scenario-level / process-level / outcome-level
| Scenario-level | Process-level | Outcome-level |
|---|---|---|
| Ownership/control information is unclear or outdated | Bank refreshes KYC/beneficial ownership records | Restrictions can persist until verification is complete |
| Activity appears inconsistent with business profile | Bank requests commercial evidence and explanations | Account may be exited if the mismatch cannot be resolved |
| Large/unusual credits appear | Bank requests source-of-funds documents and narrative | Funds movement may remain constrained pending review |
| High refund/dispute footprint (where relevant) | Bank tests sales/fulfilment/refund evidence | Risk position is reassessed; controls may tighten |
| Customer challenges a closure decision | Complaint process and evidence review follows | Outcome may focus on notice, fairness, and process |
Compare Business Bank Accounts
Different providers can handle reviews differently in practice (how evidence is uploaded, clarity of requests, support channels, and how quickly restrictions lift). A neutral comparison hub is here: Business bank accounts
Frequently Asked Questions
They can overlap, but they are not the same exercise. Opening checks are about onboarding and initial verification, while closure/restriction reviews often focus on explaining specific account activity that has already happened.
That is why a bank may ask for transaction-by-transaction evidence (such as contracts and invoices for a time window) rather than the broader “set-up” documents requested at application stage.
Because the bank may be testing whether account flows match the business model it holds on file. Contracts and invoices can be a practical way to connect incoming payments to real trading activity.
Some business models do not produce classic invoices for every payment (for example, platform sales or subscriptions). In those cases, banks may accept other forms of evidence that show what the payment represents.
“Source of funds” usually means the origin of a particular credit: where the money came from and why it was paid. The bank may want a traceable chain, such as statements from the sending account and a document explaining the purpose.
This is different from broader “source of wealth” concepts, which relate to how money was accumulated over time. Closure/restriction reviews often concentrate on specific transactions and their documentary trail.
It can happen where the business and the individual are closely linked (for example, sole traders, director funding, or where personal accounts appear to be a funding source). Requests often aim to evidence the origin of funds or confirm identity/control.
Where personal data is involved, data protection rules still apply, and banks typically focus on what is necessary for the review purpose rather than requesting unlimited information.
Banks may refresh identity and control records over time, particularly if documents expired, details changed, or the bank’s records are incomplete. Reviews can also occur when the bank is updating its risk assessment.
This is consistent with the wider framework that expects ongoing monitoring and record keeping in higher-risk or changing situations, as reflected in UK AML rules and guidance.
Not all trading relationships are documented as formal contracts. In those cases, banks may accept alternative evidence that demonstrates the commercial reality (for example, email confirmations, platform order records, delivery confirmations, or service logs).
A review can still become prolonged if the bank cannot connect account flows to a clear underlying narrative, even when the business is trading legitimately.
No. Document provision can resolve questions, but it does not guarantee the bank will keep the account. Banks can exit relationships under their terms and risk appetite, subject to applicable rules and complaint routes.
Where a dispute is raised, the complaint focus is often on process, notice (where applicable), and fairness rather than a guaranteed right to keep an account open.
Banks sometimes limit the detail they share, including where disclosures could prejudice investigations or breach legal constraints. In those scenarios, the bank may communicate mainly through evidence requests and outcome notices rather than detailed reasons.
The legal framework around money laundering offences is one reason firms may be cautious about what they disclose in certain contexts.
Data protection rights can allow individuals to request personal data held about them, subject to exemptions and redactions. The ICO sets out resources on subject access requests and how organisations respond.
A data response is not the same as a requirement for a bank to disclose every internal trigger or risk model detail. Some information may be withheld where legally permitted.
The typical route starts with the firm’s internal complaints process. GOV.UK outlines the general approach to complaining about a financial service and escalation routes where applicable.
For closure-specific complaint handling expectations and time limits (from the firm perspective), the Financial Ombudsman Service publishes guidance on how it looks at account closure complaints.
These document requests usually aren’t about building a perfect “paper file”. They are the bank’s way of testing whether it can evidence four fundamentals:
- Who controls the account
- What activity should look like
- Where money is coming from
- whether observed flows fit the stated model
When the bank can’t close those gaps, restriction is the short-term lever; closure is the longer-term lever.
Sources & References