The Future for Third-country Banks in the EU, 27.11.2025
Members and non-members event
date & time
27/11/2025 4:00-5:00 pm EET
The EC has introduced a new regulatory regime for third-country banks and in particular their branches (TCBs) operating in the 27EU, under the EU Capital Requirements Directive VI, which is applicable from 2027.
Article 21c of the Capital Requirements Directive VI will regulate how non-EU financial firms can provide core banking services within the EU. Essentially, it requires these firms to establish an EU branch in a member state where they are providing "core banking services" like deposit-taking and lending, if they don't already have a subsidiary there.
A degree of flexibility is provided via exemptions and carve outs. Notably, the requirement to establish a third country branch in the relevant Member State does not apply where the inter-bank or the intra-group transactions are involved. Nor is the establishment of a third country branch required in the case of reverse solicitation.
The new regime will considerably restrict foreign banks from providing banking services on a remote basis, unless they have an EU presence, or can argue that they are eligible for the above exemptions.
This is expected to be a major transformation of the EU banking landscape.
Key Topics:
Overview of the new CRD VI third-country branch regime
Implications for non-EU financial institutions
Interaction with MiFID, AIFMD, and UCITS frameworks
Insights from the EBA's July 2025 report
Practical guidance on reverse solicitation and exemption
As speaker Dr. David Doyle, EU Financial Services Regulatory Expert (Paris & Brussels) and experienced EU policy advisor working with the European Commission, Parliament, Council, ESMA, ECB, and IOSCO.