CRD VI is now final: what is expected for non-EU banks?

In December 2023, the European Commission published the near-final text of its new Banking Package. This package will definitely have a huge impact on many non-EU banks, significantly restricting their ability to provide “core banking” services into the EU, as well as introducing a new harmonised regime for the regulation of third-country branches (TCBs) via targeted amendments to CRD VI. The Directive will force non-EU banks to rethink their overall European footprint. Foremostly, simply to comply with the new rules, firms must decide the future of any existing, now non-compliant cross-border services. Given the number of relevant considerations, firms should begin identifying a best way forward now, to ensure they are not only compliant but “right-sized” for the November 2026 deadline.

In this alert, you will read more about the regulatory background, key takeaways, impact on firms, and conclusions.