🇪🇺 EU CRD VI: Article 21c — New Rules for Non-EU Banks
A major regulatory change is coming for third-country banks and certain large investment firms providing banking services to EU clients.
Under Article 21c of CRD VI, from 11 January 2027, in-scope non-EU institutions will generally need to establish an authorised branch in the relevant EU Member State to provide core banking services such as:
• 💰 Deposit-taking
• 💳 Lending
• 🤝 Guarantees and commitments
There are exemptions, including certain reverse-solicitation, intra-group and interbank activities, as well as specific MiFID investment services.
⚠️ Why it matters: non-EU banks currently serving EU clients cross-border may need to reconsider their structure, licensing and market-entry strategy.
📅 The new regime applies from 11 January 2027, with grandfathering for certain contracts entered into before 11 July 2026.
For firms affected by Article 21c, now is the time to assess whether an EU branch, EU-authorised entity, or an applicable exemption is the right solution.
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