Neobank fraud or dispute: your recourse in Belgium

Yes, a neobank must refund a debit you did not authorise, and the law gives you thirteen months to report it. The remedy itself depends on the institution. Revolut has a Belgian branch and falls under Ombudsfin, the Belgian financial services ombudsman. For N26 and bunq, the answer is not as clearly established.

Must a neobank refund a debit you did not authorise?

Yes, and the rule does not come from the neobank's contract. It comes from Directive (EU) 2015/2366, known as PSD2, which applies to every European bank and payment institution.

For an unauthorised debit, the provider refunds at once, and by the end of the next business day at the latest after you report it (article 73). It may hold off only if it has grounds to suspect fraud on your part and has told the national authority. Article 72 then requires it to prove that the transaction was authenticated. A record of the transaction in its own systems does not prove, on its own, that you acted fraudulently or with gross negligence.

In Belgium these rules sit in Book VII of the Code de droit économique, the Belgian Code of Economic Law. Article VII.38 obliges you to report the loss, theft or unauthorised use of the instrument without delay. Article VII.41, paragraph 1, sets the ceiling: thirteen months from the debit. Article VII.44 governs how much of the loss you can be made to bear, with gross negligence as the exception. PSD2 caps that share at €50 for a lost or stolen card, unless you acted fraudulently or with gross negligence (article 74).

The figure to keep: thirteen months is a maximum, not a comfortable deadline. Revolut's terms for its Belgian branch, in force since 31 March 2026, repeat the thirteen-month limit.

In the files I handled, a refusal rarely turned on the substance. It turned on a date: the cardholder had no record of the first report. I worked at a traditional card issuer, never at a neobank, so I have no neobank file to tell you about. But the applicable law is the same, and the date is what sank the most disputes.

Which mediator can you turn to: Ombudsfin or a foreign body?

For Revolut, Ombudsfin. For the others, you have to read the institution's complaints policy, and I do not claim to know the answer for each one.

Revolut serves its Belgian customers through the Brussels branch of Revolut Bank UAB. Its Belgian complaints policy, consulted on 29 September 2026, sets out the route: a complaint through the app, an online form or email, with a reply in 15 business days and 35 business days at most in exceptional cases. If the answer is unsatisfactory, it names Ombudsfin, the financial services mediation service.

For N26 and bunq, I could not establish on 29 September 2026 which body a Belgian customer can turn to. The N26 complaints page I consulted is written for France and refers to a separate document for mediators. I do not assert it, and you should not assert it in a letter either.

One rule holds in every case: an institution's complaints policy has to name the competent mediation body. And Ombudsfin is the Belgian member of the European Commission's FIN-NET network, created for cross-border financial disputes.

Will Ombudsfin accept your file?

Yes if six conditions are met, and the first is the one most often skipped: the prior written complaint.

According to Ombudsfin's admissibility page, consulted on 29 September 2026, the file is admissible if:

• you first sent the complaint to the institution and did not get a satisfactory answer within a reasonable time, in principle one month;
• less than a year has passed since that complaint;
• the dispute is not, and has not been, the subject of court proceedings;
• it is not a case of over-indebtedness for which no fault can be shown on the institution's part;
• you act as a private individual, with a clear and documented request;
• the institution is a member of Ombudsfin.

The procedure is free and written. Ombudsfin issues an opinion that does not bind the institution, in 90 days in principle. In 2024 the average handling time was 56.1 calendar days.

The item that most often goes missing from a file is a dated copy of the first complaint. Without it, the mediator cannot check that the preliminary step took place.

Thirteen months, eight weeks, no delay: the deadlines by situation

The right move depends on what happened, not on which neobank you use.

For the full procedure after a loss or theft, the article on a lost or stolen card gives the order of steps.

Why does fraud cost more on a debit card?

Because the money has already left your account by the time you notice. You are not disputing a line, you are waiting for a refund.

On a deferred-debit credit card, the fraudulent line appears on the statement before the withdrawal from your current account. You therefore have a window to write to the issuer before the money goes. On a debit card it is your own funds, straight away, and next day's rent does not stop because a refund is in progress.

Inaction has a price on the credit card too. If you leave €180 on a carried balance without disputing it, it runs at the APR of the contract. Rates checked with the issuers on 3 September 2026: the Beobank Visa Classic costs a €5 annual fee for an APR of 14.49%, about €26 of interest over twelve months if the €180 stays owing. The Argenta Mastercard Green costs €24 a year for an APR of 9.50%, about €17.

I do not compare neobank debit cards on that ground: they open no credit, so they have no APR to display. The ranking of Belgian credit cards and the comparison tool carry the figures card by card. For the difference between the two families, see the article on debit card or credit card.

Does a disputed merchant payment follow the same path?

No. A merchant who does not deliver is not an unauthorised transaction: you paid, and it is the service that went wrong. That case falls under the chargeback, a contractual mechanism of the Visa and Mastercard networks.

At Revolut, the help page on the dispute process gives a first review within 8 days as a rule, then 30 days for the merchant's reply on Visa and 45 days on Mastercard. Up to 85% of disputes are resolved within five weeks, and complex cases can take up to twelve weeks. The admissible reasons are detailed in the article on chargebacks in Belgium.

A debit of an unexpected amount, such as a deposit that becomes a charge, falls under a different deadline: eight weeks, provided by article 76 of PSD2. The article on a card hold for a car rental covers its use.

What if you approved the transfer yourself?

In principle there is no refund as of right, and this is the hardest part of the subject.

A transaction you approved in the app, even under pressure from a fake adviser who convinced you your account was under threat, remains an authorised transaction under PSD2. Articles 73 and 74 do not work the same way. The future EU payment services regulation, on which a political agreement was reached in November 2025, provides for a full refund in cases of impersonation of the bank, provided you file a police report and inform the provider. It was not applicable when this was written: the announced transition period is about 21 months after adoption.

Right now, you can complain in writing describing the manipulation, file a police report, report the scam on Safeonweb and keep every message. An institution may make a goodwill gesture, but it is never a right. If the answer remains unsatisfactory, Ombudsfin can be approached, but its opinion does not bind the institution.

In the files I handled, cardholders trapped by a fake call from their bank almost all apologised. There is no shame in it: these scripts are written to fool careful people.

Sources, consulted on 29 September 2026. Refund, proof of authentication, liability cap and refund of a payee-initiated payment: articles 71 to 76 of Directive (EU) 2015/2366. Belgian transposition: articles VII.38, VII.41 and VII.44 of the Code de droit économique, Book VII. Admissibility and course of a complaint: Ombudsfin, 2024 handling figures, and Test-Achats of 16 February 2026. Ombudsmen in Belgium: FIN-NET network. Consumer credit framework: FPS Economy. Future payment services regulation: Taylor Wessing note, December 2025. Belgian complaints policy, terms in force since 31 March 2026 and card dispute help page: Revolut. Annual fees and APRs checked on 3 September 2026 on the public pricing pages of Beobank and Argenta. No link in this article is paid for.