Dutch challenger bank bunq has refiled its application for a US banking licence with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, the Amsterdam-based neobank confirmed in January 2026. The move revives a pursuit of the American market that bunq had first initiated and subsequently withdrawn approximately two years earlier, and signals the bank's conviction that conditions are now sufficiently favourable for a renewed regulatory engagement with US banking authorities. The refiling makes bunq one of the few European neobanks to mount a second attempt at the demanding US de novo licensing process.
At the time of refiling, bunq counted 17 million users and held €8.7 billion in deposits across its European operations. Those figures represent a considerably stronger financial and operational profile than the bank presented when it first applied, and bunq is positioning the growth in its balance sheet and user base as evidence of the institutional credibility and track record that US regulators expect from banking licence applicants.
CEO COMMITS TO US MARKET AMBITION
Chief Executive Ali Niknam described the United States market as a strategic priority for the challenger bank, framing the refiling as a continuation of a long-term growth objective rather than a reactive decision prompted by any single change in external circumstances. Niknam has consistently highlighted the US as the most significant untapped international growth opportunity for bunq, and the decision to refile reflects a sustained executive and board commitment to entering the market rather than a change of strategic direction.
Obtaining a US banking charter is a demanding regulatory process that requires applicants to demonstrate adequate capitalisation, a credible and financially sound business plan, and governance and compliance frameworks that satisfy the OCC and FDIC's standards for a de novo institution. bunq's withdrawal of its first application in 2024 underlined the complexity of meeting those requirements, and the refiling in 2026 will need to address the concerns or gaps that either the regulators or bunq itself identified during the initial review process.
The mobile-first current account model that bunq operates successfully across multiple European Union member states — built around tiered subscription pricing and features designed for internationally mobile and digital-native users — may require meaningful adaptation for the US market, where consumer banking expectations, competitive dynamics, and the regulatory framework governing deposit-taking differ materially from the EU environment in which bunq has built its franchise.
EUROPEAN BASE PROVIDES FINANCIAL PLATFORM
bunq holds a banking licence issued by De Nederlandsche Bank, the Dutch central bank, and operates in multiple EU member states under the European passport framework. The €8.7 billion deposit base gives the bank a credible claim to financial stability and scale, while the 17 million user figure demonstrates meaningful and growing consumer traction in the highly competitive European digital banking market, where bunq competes against a large number of well-funded neobank and traditional bank rivals.
European neobanks that have previously attempted to enter the US market have found the process more protracted and capital-intensive than initial projections suggested, reflecting the complexity of the dual OCC and FDIC approval process and the strength of entrenched digital banking offerings from both established US banks and US-founded fintech challengers. bunq's prior withdrawal implies that its second application has been prepared with more thorough regulatory engagement and a more detailed understanding of the approval hurdles involved.
The OCC and FDIC have not commented publicly on the refiled application, and the regulatory review process is expected to extend over a considerable period before a formal determination is made. bunq has not publicly disclosed a target timeline for receiving a licensing decision.