The case

As of 11 January 2027, banks based outside the EU will generally need a licensed branch in the relevant EU member state to provide core banking services to EU residents. The rule comes from Article 21c of CRD VI (Directive (EU) 2024/1619).

Source: European Banking Authority & IMIdaily

The commentary

The rule is based on residence, not nationality. An EU citizen living in Dubai is not affected, while a non-EU citizen living in Berlin is.

The restriction covers deposit-taking, lending, including mortgages and consumer credit, as well as issuing guarantees and commitments and applies across the European Economic Area, including Iceland, Liechtenstein and Norway, while individual countries may impose stricter requirements.

There are several exemptions. Most relevant to individuals is reverse solicitation, which allows an EU resident to approach a non-EU bank entirely on their own initiative without the bank having an EU branch. However, the bank cannot market or solicit within the EU and then rely on this exemption. Contracts entered into before July 11, 2026 are also protected under grandfathering rules.

In practice, the biggest impact may be commercial rather than legal. Many non-EU banks may decide that the regulatory risk of serving EU residents is too high and simply stop accepting new EU-resident customers, even where reverse solicitation could technically apply.