The short version. Two different laws are talking, and people mix them up. Banking law decides whether the bank has to open the account. Tax law decides whether the bank has to collect your Social Insurance Number.
Under section 627.17 of the Bank Act, a member bank must open a retail deposit account for a person who presents two documents from a reliable source, one showing name and address and the other name and date of birth. A SIN is not on that list, and the grounds for refusal in section 627.18 do not include the absence of one. Under paragraph 237(1.1)(b) of the Income Tax Act, you must give your number, on request, to a person who has to file an information return needing it, which is why the moment an account starts paying interest the question arrives. The practical result: you can usually get banked now and sort the number out on the tax side.
What changed on this page, 7 August 2026. The previous version listed eight named banks with a one line claim about each one's SIN policy, plus a cash bonus figure. We removed all of it. None of those bank-by-bank claims could be verified from the institution's own current page, several of the program names had drifted, and the bonus figure conflicted with our own records. What replaced it is the rule that applies to every federally regulated bank in the country, quoted from the statute, which is both more useful and checkable by you. Where a per-bank fact matters, ask the bank to point at its own published policy.
The two laws, kept apart
Almost every confusing conversation at a branch counter comes from collapsing these two things into one.
| Question | Which law answers it | The answer |
|---|---|---|
| Must the bank open an account for me | Bank Act, sections 627.17 and 627.18 | Yes, if you present the required identification and none of the six refusal circumstances applies. No SIN is required by that section, and no minimum deposit or balance may be required |
| Must I give the bank my SIN | Income Tax Act, sections 237 and 162 | Yes, on request, where the bank has to file an information return that needs it. That is what an interest bearing account produces. A $100 penalty applies per failure, with a 15 day escape hatch |
| Can I open a TFSA or an RRSP without one | Income Tax Act, subsection 146.2(5) and the registration rules | No. Registration runs through the number itself |
What a bank may actually ask you for
Subsection 627.17(1) is specific. A member bank must open a retail deposit account, at a point of service or branch in Canada where it opens accounts through people, on the in person request of a natural person who presents one of the following.
- Two documents from a reliable source, one indicating name and address and the other name and date of birth. The categories named in the subsection are identification issued by the Government of Canada or the government of a province, recent notices of tax assessment issued by the federal, provincial or a municipal government, recent statements of benefits from the federal or a provincial government, recent Canadian public utility bills, recent bank account or credit card statements, foreign passports, and any prescribed document.
- Or one document from a reliable source indicating name and date of birth, where identity is also confirmed by a customer in good standing with the bank, or by a natural person of good standing in the community where the branch is located. This vouching route is real, it is written into the statute, and branch staff very rarely mention it.
Three further points sit in the same section and are worth knowing before you walk in.
- If the bank asks, you have to consent to it verifying your documents and checking whether the refusal circumstances apply.
- If the bank has reasonable grounds to suspect you are misrepresenting your identity, it may require one piece of federal or provincial photo identification bearing your photograph and signature.
- Subsection 627.17(4): the bank shall not require you to make an initial minimum deposit or maintain a minimum balance. Opening the account itself costs nothing.
A foreign passport is expressly in the list. That is the sentence that matters most to a newcomer who has landed with a passport and an immigration document and no Canadian paperwork yet.
The only circumstances where the duty to open does not apply
Section 627.18 is a closed list. Subsections 627.17(1) to (3) do not apply where:
- the bank has reasonable grounds to believe the account will be used for illegal or fraudulent purposes;
- you have a history of illegal or fraudulent activity in relation to providers of financial services and the most recent instance was less than seven years before the request;
- the bank has reasonable grounds to believe you knowingly made a material misrepresentation in the information provided for the purpose of opening the account;
- the bank has reasonable grounds to believe refusal is necessary to protect its customers or employees from physical harm, harassment or other abuse;
- the request is made at a branch or point of service where the only retail deposit accounts offered are ones linked to an account at another financial institution; or
- a prescribed circumstance applies.
Subsection 627.18(2) then adds something people fight about for years without knowing it is written down: the fact that you are or have been bankrupt does not, by itself and without evidence of fraud or other illegal activity connected to the bankruptcy, amount to reasonable grounds to believe the account will be used illegally.
Notice what is absent from that list. No SIN. No Canadian credit history. No minimum income. No proof of employment. No length of time in the country. If a refusal is based on one of those things, the refusal is not resting on section 627.18, and that is worth saying out loud, politely, in the branch.
Why the bank asks for your SIN anyway, and what happens if you say no
The bank is not being difficult. It is standing between you and the Canada Revenue Agency, and the Income Tax Act puts obligations on both of you.
On you. Paragraph 237(1.1)(b) says every person shall provide their designated number to another person at that person's request where the other person is required to make an information return requiring it. Subsection 237(1.2) defines the designated number of an individual other than a trust as their Social Insurance Number. Paragraph 237(1)(b) separately says that if you do not have one, you must apply for it within 15 days after being asked.
On the bank. Subsection 237(2) requires a person who has to make an information return needing your number to make a reasonable effort to obtain it, and prohibits them from knowingly using or communicating it other than as required or authorized, without your written consent. So the repeated asking is a legal duty, and so is the confidentiality.
The penalty, and the way out of it. Subsection 162(6) sets a penalty of $100 for each failure to provide the number on request, unless two things are both true: an application for the number was made within 15 days after the request was received, and the number was provided to the person who requested it within 15 days after you received it. There is a matching relief on your own return in paragraph 162(5)(b), which says the $100 penalty for failing to provide information on a prescribed form does not apply to a missing SIN on a return of income where you had applied for the number and had not received it when the return was filed.
Read together, the design is obvious: the law is not trying to punish someone who is waiting for a number. It is trying to stop someone refusing to have one. If you are between arriving and receiving, applying is what protects you.
The 9 series SIN, and the expiry date most people miss
If you are in Canada on a work or study permit, your number will not look like a permanent resident's. The Social Insurance Number Regulations set out exactly why, and they contain a trap worth knowing about.
| Rule | What it says | Where |
|---|---|---|
| Numbers starting with 9 | A number assigned to a person who is neither a Canadian citizen nor a permanent resident, following a direction from the Minister of Citizenship and Immigration under section 90 of the Immigration and Refugee Protection Act, must begin with 9 | SIN Regulations, s. 8 |
| Validity if you applied from outside Canada | Expires five years after the day the number was assigned | s. 9(1) |
| Validity if you applied while in Canada | Expires on the earlier of the day the period authorized for your stay ends, as determined under subsection 183(4) of the Immigration and Refugee Protection Regulations, and the day two years after the number was assigned | s. 9(2) |
| Extending it | You may apply at any time after assignment to extend the period of validity, or obtain a new equivalent period | s. 10 |
| When you become a citizen or permanent resident | You must notify the Commission of the change and of the previously assigned number. It then voids the old number and assigns a new one | s. 13 |
| Old cards with no expiry date | Any SIN card issued without an expiry date to a person who was not a citizen or permanent resident expired on 3 April 2004 | s. 11 |
| Who signs the application | A person aged 12 or older signs their own. For a person under 12, a parent or another person legally authorized to act for them signs | s. 3(1) |
The trap is section 9(2). A temporary resident who applied for their number in Canada can have it expire when their permit does, even though the digits themselves never change. An expired number causes trouble at tax time and with employers rather than at the bank counter, which is exactly why people discover it late. If your status has been extended, extend the number too under section 10.
Section 4 is worth a sentence as well: where a person who is required by law to have a number refuses to apply, the Commission may register them and assign one anyway if it has information establishing identity and status. Refusing is not a strategy.
An account you can open from a phone while the paperwork catches up
Branch appointments and document checks take time that a new arrival often does not have. KOHO is a Canadian prepaid Mastercard account with a free plan that opens online, gives you an account number for direct deposit and sends instant transaction notifications. Be clear about what it is: it is not a chartered bank, deposit protection works differently than at a bank, the better cash back and interest sit on the paid plans, and its own identity requirements are set by the provider, not by section 627.17. Read the current terms on their own page before signing up, and open the bank account too, because you have a statutory right to one.
See how the account worksWhat you can and cannot do while you wait for a number
| Works without a SIN | Needs the number |
|---|---|
| A chequing or basic deposit account under section 627.17, with no minimum deposit or balance | Any account paying interest, because it produces an information return |
| Deposits, withdrawals, debit purchases, bill payments and Interac e-Transfer transactions | A TFSA. Subsection 146.2(5) registers the arrangement under your Social Insurance Number, and subsection 146.2(1) also requires you to be at least 18 |
| Receiving pay by direct deposit into the account | An RRSP, an FHSA, an RESP and other registered plans, for the same registration reason |
| Holding a prepaid or app based account, subject to that provider's own rules | Being paid as an employee. Employment requires a SIN, which is why applying is the first errand after arrival |
We deliberately do not publish a bank by bank table of who will and will not open an account without a number. Those policies are not published consistently, they change, and a wrong line on a website sends someone across a city for nothing. The statutory rule above applies to every federally regulated bank, and it is the one to quote.
If a bank refuses you anyway
1. Ask which paragraph of section 627.18 applies
The list is closed. If the answer is "you have no SIN" or "you have no credit history", neither of those is in it. Ask politely and in those words. A branch that cannot name a ground is usually applying an internal preference rather than the law.
2. Ask for the vouching route
Subparagraph 627.17(1)(a)(ii) allows a single document plus confirmation of identity by a customer in good standing with that bank, or a person of good standing in the community. If you are one document short, this is the provision to name.
3. Escalate inside the bank, then outside it
Every federally regulated bank runs a complaint process with statutory time limits, and there is an external complaints body after it. We set out how that works, and how long the bank actually has, in our guide to how a bank complaint works in Canada. Our guide to a bank refusing to open your account covers the refusal scenario in more detail.
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Frequently asked questions
Section 627.17 speaks of a natural person and does not condition the duty on immigration status, and section 627.18 does not list status among the refusal circumstances. In practice the friction is identification and address rather than status: the section requires two documents from a reliable source, one showing name and address, and a visitor often cannot produce the address half. A foreign passport is expressly named as acceptable for the name and date of birth document. Banks also apply their own anti money laundering procedures on top of the section, and those are not published. Expect the address requirement to be the real obstacle, and ask about the vouching route.
The absence of a Social Insurance Number is not one of the circumstances in section 627.18 that switches off the duty to open an account in section 627.17, and a SIN is not among the documents section 627.17 lets the bank require. A bank that declines on that basis alone is not standing on either section. What the bank can legitimately do is tell you that a specific product, such as an interest bearing savings account or a registered plan, requires the number for tax reporting reasons, which is a different statement about a different product.
We are not publishing a processing time or a fee on this page. Both are operational facts set by Service Canada rather than by the Regulations, and the government pages that state them did not respond to us on 7 August 2026, so any number we printed would be a repeat of somebody else's article rather than a verified figure. Check canada.ca directly. What we can tell you from the Regulations is what the application must contain, in section 2: supporting documents allowing identification of the person and their status, plus information including full name, name at birth if different, date of birth, place of birth and parents' full names at birth.
No, because a deposit account is not credit and does not create a credit file. A Canadian credit file starts when a credit product reports to a bureau. The connection people are actually feeling is that newcomers usually arrive without a SIN and without a credit file at the same time, so the two get blamed on each other. They are separate problems with separate fixes, and the account can be opened while the credit file is still empty.
Yes. Section 9(2) of the Social Insurance Number Regulations ties the validity of a 9 series number assigned in Canada to the earlier of the end of your authorized stay and two years from assignment, so extending the permit does not automatically extend the number. Section 10 lets you apply at any time to extend the period of validity or obtain a new equivalent one. Employers and the tax system are where an expired number causes problems, not usually the bank counter.
The duty in paragraph 237(1.1)(b) is to give the number to a person who is required to make an information return that needs it. An employer is in that category, because employment income is reported. A landlord asking for identity screening generally is not. Nothing in the Income Tax Act obliges you to hand your number to a business simply because it asks. Subsection 237(2) also bars a person who does have a legitimate need from using or communicating it beyond what the Act requires or authorizes, without your written consent.
Related guides from Bremo
- When a bank refuses to open your account, and what to do about it
- How a bank complaint actually works in Canada, and the 56 day rule
- Opening a bank account under 18 in Canada
- Choosing a first bank account as a newcomer to Canada
- What Canadian bank accounts actually cost per month
- US dollar and foreign currency accounts in Canada
- Canadian bank bonus tracker, with the date each offer was last verified
Disclosure: some links on this page are referral links and Bremo may earn a commission if you open an account, at no cost to you. It does not change what is written above. Sources, all read on 7 August 2026 on the Justice Laws website: Bank Act, S.C. 1991, c. 46, subsections 627.17(1) to (4) for the identification a member bank may require, the vouching route and the prohibition on a minimum deposit or balance, and section 627.18 for the closed list of circumstances in which the opening duty does not apply, including subsection 627.18(2) on bankruptcy; Income Tax Act, R.S.C. 1985, c. 1 (5th Supp.), paragraph 237(1)(b), subsections 237(1.1), 237(1.2) and 237(2), paragraph 162(5)(b), subsection 162(6), and subsections 146.2(1) and 146.2(5); Social Insurance Number Regulations, SOR/2013-82, sections 2, 3, 4, 7, 8, 9, 10, 11 and 13. What we deliberately did not publish: a bank by bank table of who opens accounts without a SIN, because no institution's current page confirmed it for us today, and any SIN processing time or fee, because the Service Canada pages that state them did not respond to our requests on 7 August 2026. This is educational general information about Canadian law, not tax, legal or immigration advice. Verify anything that matters against the statute or the institution's own page before you act on it.