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As Article 21c of CRD VI ushers in a new era for third-country access to the EU banking market, firms need clarity, strategy and the right expertise.
As the EU’s new branch requirements for core banking services take effect on 11 January 2027, CRD VI is set to reshape operating models across the sector. Yet with carefully managed exemptions, differing national transpositions, and a policy landscape still settling into place, there is still room to navigate these changes with confidence.
Our guide to CRD VI distils the key issues and practical implications for firms. We are working with clients to cut through the complexity, anticipate what matters most, and chart a smooth, assured path through Article 21c, turning regulatory change into practical, actionable solutions.
Ireland has now transposed Article 21c of CRD VI into domestic law through the publication of the European Union (Capital Requirements) (Amendment) Regulations 2026. The regulations introduce no additional Irish-specific requirements or restrictions. Additionally, the grandfathering cut-off date remains as 11 July 2026 despite the delayed transposition. With the new regime set to take effect in January 2027, our updated guide reflects these developments and explores the practical implications for non-EU banks, borrowers and other market participants.
Click below to download our guide to CRD VI
Video Transcription
Hi, my name is Rob Cain. I’m a partner in the Financial Regulatory Group at Arthur Cox. In July 2024, the EU’s new CRD VI rules were passed as part of a package designed to finalise Basel III. The most significant change introduced as part of the package is Article 21(c), which introduces a new general prohibition on third-country firms providing core banking services directly into the EU. From the 11th of January 2027, non-EU banks will no longer be able to offer deposit-taking, lending, or guarantees into the EU on an unlicensed basis.
Instead, they’ll need to establish a licensed branch in every member state in which they want to operate or book products through an authorised EU entity. These changes have a particularly significant impact on Ireland because we do not currently regulate cross-border commercial lending, for example. So with less than 12 months before Article 21(c) comes into effect, third-country firms that service Irish clients need to prepare now. We’ve been advising a wide range of clients on Article 21(c), and our new guide to CRD VI breaks down what’s required, who’s affected, and the steps you should take ahead of January 2027.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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