CRD VI directive: non-EU bank accounts for EU residents from 2027

In brief

• From 11 January 2027 a non-EU bank may offer deposits, loans and guarantees to EU residents only through a branch authorised in an EU country.
• Contracts concluded before 11 July 2026 are not affected. An account opened later has no such protection.
• If a client approaches a non-EU bank on their own initiative, no branch is needed. But the bank may not market other products to that client.
• Investment services, brokerage accounts and asset management are excluded from the restriction.
• Accounts at banks in EU countries are not affected. Tax information exchange on accounts works as before.

What the EU decided

The core rule is this: EU countries must require a company from a third country to set up a branch and obtain authorisation before providing banking services in the EU. Three core services are covered: taking deposits and other repayable funds, lending, and guarantees. In banking terms a third country is any country outside the EU. Switzerland, the UK, the UAE, Singapore, the US and Turkey are all in the same position.

The directive was adopted on 31 May 2024 and entered into force on 9 July 2024. EU countries had until 10 January 2026 to transpose it into national law, and the branch rules apply from 11 January 2027. Existing contracts have a separate date: 11 July 2026. Anything signed before it remains in force.

Before the directive each country decided for itself. In some, a non-EU bank could serve local residents across the border almost without restriction; in others a licence was already required. Now the requirement is common to all 27 countries, and the exemptions are listed in the directive itself.

What this means for you. The restriction targets banks, not clients. Holding an account outside the EU is not prohibited. What changes is the basis on which a non-EU bank may serve you and offer new products.

What an authorised branch means

A third-country branch is not a separate bank but a unit of the head bank, authorised by the regulator of one EU country. Unlike an EU bank, it cannot use that authorisation to serve clients across the Union.

The directive divides such branches into two classes. Class 1 covers large branches with assets of EUR 5 billion or more, branches that take retail deposits equal to 5% or more of their liabilities or exceeding EUR 50 million, and branches of banks from countries whose supervision the EU has not recognised as equivalent. All other branches are class 2.

The class determines how much of its own capital the branch must hold in the EU country. Class 1 holds at least 2.5% of average liabilities and no less than EUR 10 million, class 2 at least 0.5% and no less than EUR 5 million. Add local management, reporting and supervision, and it is clear why not every bank outside the EU will open a branch. How banks assess clients in this situation is part of our bank compliance support.

What this means for you. If your bank announces a branch, ask where it will be authorised and whether it will serve you. Without a branch, what remains is reverse solicitation or a move to an EU bank.

Who is affected

The rule covers clients located in the EU. For an individual this means, above all, the place of residence, not citizenship. An Indian, Brazilian or South African citizen with a Greek residence permit becomes an EU client for a non-EU bank. A German citizen living in Dubai may fall outside the rule: the bank looks at where the client lives and where they approach it from.

In practice three groups have the most questions. The first is families who obtained EU residence through an investment programme and moved, but kept their main account in Switzerland or the UAE. The second is entrepreneurs with businesses outside the EU who live in Europe and receive dividends into an account in the country of the business. The third is people who plan to open a non-EU account while already having a European address.

A word on tax residence. A residence permit does not by itself change tax residence; that is assessed separately. But the bank relies on the address you gave when opening the account and in your tax information exchange form. If you have told the bank you moved to the EU, it will treat you as an EU client.

What this means for you. If you live in the EU and keep money at a non-EU bank, these rules apply to you. Citizenship does not matter; your country of residence does.

When no branch is needed

The directive keeps four exemptions. Which of them fits your case determines what the bank can offer you after January 2027.

1. Client initiative. If an EU resident approaches a non-EU bank on their own exclusive initiative, the bank may provide the service without a branch. The condition is strict: if the bank, its subsidiary, agent or any intermediary sought out the client, the exemption does not apply.
2. The client is a bank. Services to EU credit institutions are not restricted. For individuals this exemption is irrelevant.
3. Same group. A non-EU bank may serve companies of its own group in the EU.
4. Investment services. Brokerage, portfolio management, investment advice and the deposits and loans linked to them are excluded.

The client initiative exemption has a second limit. Even if you approached the bank first, that does not entitle the bank to market other kinds of products to you. The bank may provide the service you asked for and closely related ones. It may not promote a new loan, guarantee or a different type of deposit to you without a branch.

In its report of 23 July 2025 the European Banking Authority examined whether to widen the exemptions and did not propose changing Article 21c. The regulator noted that EU countries have no common definition of core banking services, so the details will be settled by national regulators.

What this means for you. The client initiative exemption is not a formality. You and the bank may have to prove that you made the first contact, so keep the correspondence about opening the account.

What happens to your account

The answer depends on three things: when the contract was concluded, what the product is and who took the initiative. Below are the main situations.

The most important row is the first. If your account in Switzerland or the UAE was opened before 11 July 2026, the contract is protected. The bank is not required to close it because of the directive. But the bank may review its own policy: some banks may decide to reduce the number of EU clients rather than open a branch. That is the bank's decision, not a legal requirement.

New products within an old contract are harder. If you hold a current account and want to open a term deposit or take a loan secured on your portfolio, the bank may treat this as a new contract. The new rules then apply to it. Exactly how will be decided by the regulator of your country of residence and by the bank itself. It is best to get the bank's position in writing before planning the transaction.

What this means for you. Old accounts are protected; new products are not always. Before a large transaction at a non-EU bank after January 2027, ask the bank on what basis it is carrying it out.

Deposit guarantee: what is protected at an EU bank

A deposit at a bank in an EU country is protected by a common guarantee system: up to EUR 100,000 per depositor per bank. The amount covers all of the client's accounts at that bank together, not each account separately. For a joint account the share of each holder is counted, usually in equal parts.

Above EUR 100,000 there is temporary cover: proceeds from selling a private home, insurance, compensation and payments linked to certain life events are protected for three to twelve months after they are credited, on terms set by each EU country.

Repayment has also become faster: if a bank fails, the guarantee system must pay out within seven working days, down step by step from 20.

An account at a bank outside the EU is not covered by this system; it has its own protection in the bank's country. For a third-country branch that takes deposits in the EU, the host country checks that depositors are protected at least as well as under the EU system, and if not, it can require the branch to join the local scheme.

What this means for you. A large sum from selling a business or property is best spread across several EU banks: the EUR 100,000 limit applies to each bank.

If the bank moves your account to its EU subsidiary

Banks with EU subsidiaries are likely to offer EU clients a move there. For the client this is a new contract: a different IBAN, fees, supervisor and deposit guarantee system.

The EU bank runs its client checks again, even within the same group. It will ask for identity and address documents, tax residence and proof of the source of funds. If the file at the old bank was assembled years ago, the documents will need updating. A bank file prepared in advance helps.

After the move the account is protected by the guarantee system of the new bank's country. Below is how much is covered in typical situations.

Before the move, check whether the terms of deposits and loans are kept, what happens to securities and how tax reporting changes; the EU bank reports the account to your country of tax residence as before. If the account holds money of a company or a family structure, check who will be recorded as the owner; ownership structuring helps here.

What this means for you. A move to the group's EU bank solves the directive question, but it is a new review. Start collecting documents before the bank sends its offer.

Switzerland, the UAE, the UK: where the question is sharper

Switzerland. For private banks, EU clients are a large part of the business. Banks that already have subsidiary banks in the EU may move some clients there. The account is then opened at the group's European bank and is outside the restriction. Smaller banks with no EU presence have a narrower choice: open a branch or work only on client initiative.

The UAE. Accounts in Dubai are often held for both personal spending and business. If you live in the EU and opened the UAE account yourself, the client initiative exemption usually applies. But the bank may ask for confirmation and limit new products. The terms for personal accounts in the UAE are covered in the article on a personal UAE bank account for non-residents.

The UK. Since leaving the EU, British banks are third-country banks for the EU. Those with subsidiary banks in the EU serve European clients through them. If your account is in London and you live in France or Spain, ask which group company will serve you after January 2027.

Other non-EU countries, from Singapore to Turkey, follow the same logic. The less presence a bank has in the EU, the more likely it is to limit services to EU residents.

What this means for you. The directive does not close accounts, but it changes the bank's calculation. A bank may decide that EU clients are not worth opening a branch for and reduce them itself.

What to do now

1. List your non-EU accounts: bank, country, contract date, type of product. Mark what was opened before 11 July 2026.
2. Find the onboarding documents: the contract, your first letter or application to the bank. This is evidence of your initiative.
3. Update your address and tax residence with the bank if you have moved. Hiding a move is not an option: it breaches the bank's terms and the tax information exchange rules.
4. Open a main account at a bank in the EU country where you live. It will cover everyday payments, while the non-EU account remains for savings and business.
5. Prepare proof of the source of funds in advance. An EU bank will check it at the first large transfer.
6. Before a new deposit, loan or guarantee at a non-EU bank after January 2027, ask the bank for its position in writing.

How to open an account at a European bank after obtaining residence we covered using the examples of Cyprus and Hungary. How banks check clients with a second citizenship is explained in the piece on second passports and banks. Paperwork on your money is easier with source of funds support.

Your own reporting duties on foreign accounts in your country of tax residence do not change because of the directive. Check them separately with your tax adviser.

Common mistakes

• "My account will be closed in January." The directive does not require existing contracts to be closed. Only the bank itself can close an account under its own policy.
• "I am not an EU citizen, so this does not concern me." What matters is the country of residence. With EU residence you are an EU client for the bank.
• "I will open an account through a bank manager I know." If the bank approached you, the client initiative exemption does not apply.
• "I will tell the bank I live elsewhere." A false address breaches the bank's terms and the tax information exchange rules. The bank will close the account faster than any directive.
• "Brokerage accounts are banned too." Investment services are excluded. But the cash on such an account should serve the investments, not replace a current account.

How this piece was prepared

This piece is based on the text of Directive (EU) 2024/1619 of 31 May 2024, published in the Official Journal of the EU on 19 June 2024: Article 21c on branches of third-country banks and Article 2 on transposition and application dates. The exemptions are also described on the basis of the European Banking Authority report of 23 July 2025. National laws of EU countries may specify details, so a specific account needs to be checked in your country of residence. It is not a legal opinion on your contract with a bank.