Closing accounts

A Swan account might need to be closed for several reasons. You, your account holders and account legal representatives, Swan, and third parties can all request an account be closed.

You only pay for accounts with the status Opened. As soon as an account enters the closure process, the status changes to Closing and you're no longer charged for the account.

Account statuses

Refer to the account statuses section for an overview of what happens when an account is Closing or Closed.

When the closure process begins

When an account enters the Closing status, the following resources are canceled instantly:

• All cards associated with the account.
• All standing orders.
• All virtual IBANs.

Additionally, incoming SEPA Credit Transfers are automatically returned, payment mandates for incoming SEPA Direct Debits are canceled, and any attempted incoming SEPA Direct Debit is rejected. Your users must cancel all outgoing SEPA Direct Debits themselves, as Swan has no control over those payment mandates.

Account closure processes

The account closure process depends on who closes the account. Swan assigns a specific closure reason code to each closed account so you can understand why the closure occurred.

Partner (you)

You can request to close accounts for your users if specific conditions are met:

1. Your end user hasn't made payments to you for two consecutive months.
2. Your end user's account is recognized as a duplicate.
3. Your end user is no longer using your product.
4. Your end user doesn't respond to your communication.

The method you'll use to request to close the account depends on the account's payment level, which is either Limited or Unlimited. Find the payment level by going to your Dashboard > Data > Accounts, then clicking the account you're requesting to close.

Follow the guide relevant to your situation:

• Request to close a limited account
• Request to close an unlimited account

When you request account closure, the reason code is RequestedByPartner.

Legal representative

An account's legal representative can request to close an account. You need to support them in this process by either sending them a non-expiring closure link or closing the account with the API.

Follow the guide relevant to your situation:

• Send a link to the legal representative to close the account
• Use the API to close an account by legal representative request

Only Swan can act on Suspended accounts. Legal representatives can't close accounts with the status Suspended.

When the legal representative requests account closure, the reason code is RequestedByHolder.

Account holder

An account holder or legal representative can request to close an account by contacting Swan Support directly. Send your users the Swan Support Center article explaining the process to initiate account closure.

When they contact Swan Support to request account closure, the reason code is RequestedByHolder.

Swan

Swan reserves the right to close accounts, and might decide to close an account for the following reasons:

1. The account holder's identity document looks fake, stolen, or altered; the device used to complete an identification is altered; or the applicant seems to have performed their identification against their will.
2. Suspicion of other fraudulent activity or activities that aren't compliant with Swan's policies.
3. The onboarding, identification, or Know Your Customer (KYC) process wasn't completed.
4. The Partner (you) is no longer working with Swan.

When closing accounts, Swan is required by law to provide a two-month notice period. More specifically, Swan waits 60 days after notifying the account holder to change the account status to Closing. This provides the account holder with enough time to open an account at another financial institution before losing access to their Swan account.

Swan can close accounts immediately if the closure is due to fraud or a third-party request. The reason code depends on the situation. Refer to the closure reason codes for a complete list.

Third party

Swan can receive requests from third parties to close accounts. For example, liquidators can request account closure if the account holder's company is being liquidated. Notaries can also request account closure following the account holder's death.

Before accepting requests from third parties, Swan performs the following actions:

1. Swan confirms the request is legitimate. If the request is fraudulent, Swan doesn't comply.
2. Swan checks the account balance.
   • Zero balance: No action required.
   • Positive balance: Swan requests bank details from the third party, then transfers the funds.
   • Negative balance: Swan requests the third party transfer funds so the balance reaches zero.

When the account balance reaches zero, Swan changes the account status to Closed immediately for legitimate third-party requests. The reason code depends on the situation (for example, DeathClosure for a deceased account holder). Refer to the closure reason codes for a complete list.

Closure reason codes

Swan provides specific closure reason codes to help you understand why an account was closed. You can view the closure reason code for a closed account by going to Dashboard > Data > Accounts and selecting the account, or by querying the account status with the API.

Closure reasons fall into different categories depending on who initiated the closure and the circumstances.

Timeline for closure reason codes

Before 2 April 2026, Swan used a limited set of four closure reason codes: ComplianceReason, PartnerReason, Inactivity, and CapitalDepositReason. Starting 2 April 2026, these codes are replaced with more granular codes that provide better transparency about why an account was closed.

Existing accounts closed before 2 April 2026 keep their original reason codes. Refer to the deprecated reason codes for the full mapping.

General closure reasons

Reason code	Explanation
RequestedByHolder	Closure requested by the end user.
RequestedByPartner	Closure requested by the Partner for any reason.
RemediationPlan	Closure following a Partner remediation plan.
PartnerChurn	Closure following a Partner churn.
DeathClosure	Account holder is deceased.
DormantAccount	Prolonged inactivity according to local regulatory definitions or internal policy.
Other	Reason not covered by the current list.

KYC, reKYC, and capital deposit closure reasons

Reason code	Explanation
KYCIssue	Documents missing, incorrect, or no reply.
ForbiddenActivity	Prohibited business sectors.
DuplicateOnboarding	A second account was created by mistake.
DeniedCountryResidency	High-risk UBO or resident.
RefusedIbanCountry	The account holder was assigned the wrong IBAN country, or the IBAN country isn't allowed.
CompanyRegistrationCountryNotSupported	The company registration country isn't supported by Swan.
BusinessInactiveOrNotRegistered	The company is inactive or not registered.
UnsupportedLegalForm	The legal form can't be onboarded by Swan.
TCViolation	Terms & Conditions violation.
ReKYCNoReply	The account holder failed to reply to a reKYC request.
CapitalDepositCompleted	Standard closure of a temporary capital deposit account after the company is registered.
CapitalDepositCanceled	The capital deposit was canceled.
CapitalDepositRefusedByNotary	The notary refused the capital deposit case.

Compliance and regulatory closure reasons

Reason code	Explanation
ComplianceReason	Closure for compliance reasons.
RegulatoryRequirement	Closure required by regulation.

note

These are high-level categories for closures. In some cases, Swan uses these codes when we cannot share the specific closure reason with partners, such as in cases of fraud or risk. We cannot provide further details on compliance or regulatory closures.

Deprecated reason codes

The following reason codes are deprecated starting 2 April 2026. They will still appear on accounts closed before this date, but will no longer be assigned to new closures.

Deprecated code	Used for	Replaced by
PartnerReason	Closure requested by the account holder or legal representative.	RequestedByHolder
Inactivity	Prolonged account inactivity.	DormantAccount
CapitalDepositReason	All capital deposit closures (cancellation, completion, or notary refusal).	Any code in KYC, reKYC, and capital deposit closure reasons.

ComplianceReason is not deprecated and remains in use.

Email communications

Swan notifies your end users about account closure by email according to your communication preferences: you (partner) only, you and the end user, or end user only. Refer to the tab for your communication preferences.

🔒 You (partner) only

communication preferences

Swan is dedicated to respecting your communication preferences. However, notifying end users about account closure is a legal requirement and can't be removed from the user flow.

Please consider the following timelines in your implementation. Other than immediate closure, you're notified first and can therefore notify your users about their account before the closure date.

Timeline	Overview
Immediate closure 2 emails	Immediately: Notification of account closure sent to the end user, with you in copy. Immediately: Separate notification of account closure sent to you.
Closure within 60 days 3 emails	Immediately: Notification of the account closure date sent to you only. On closure date: Notification of account closure sent to you. On closure date: Separate notification of account closure sent to the end user, with you in copy.
Closure in 60 days or more 4 emails	Immediately: Notification of the account closure date sent to you only. A month before closure date: Reminder of account closure sent to you only. On closure date: Notification of account closure sent to you. On closure date: Separate notification of account closure sent to the end user, with you in copy.

👥 You & the end user

Timeline	Overview
Immediate closure 1 email	Immediately: Notification of account closure sent to the end user, with you in copy.
Closure within 60 days 2 emails	Immediately: Notification of the account closure date sent to the end user, with you in copy. On closure date: Notification of account closure sent to the end user, with you in copy.
Closure in 60 days or more 3 emails	Immediately: Notification of the account closure date sent to the end user, with you in copy. A month before closure date: Reminder of the account closure date sent to the end user, with you in copy. On closure date: Notification of account closure sent to the end user, with you in copy.

👤 End user only

Timeline	Overview
Immediate closure 1 email	Immediately: Notification of account closure sent to the end user.
Closure within 60 days 2 emails	Immediately: Notification of the account closure date sent to the end user. On closure date: Notification of account closure sent to the end user.
Closure in 60 days or more 3 emails	Immediately: Notification of the account closure date sent to the end user. A month before closure date: Reminder of the account closure date sent to the end user. On closure date: Notification of account closure sent to the end user.

Guides

• Send a link to the legal representative to close the account
• Use the API to close an account by legal representative request
• Close a limited account
• Close an unlimited account
• Query account closure information