Responding to CRD VI for third country banks

CRD VI is anticipated to come into effect Jan 2027, meaning third country banks can no longer provide in-scope cross-border banking services to EU clients. The current near-final text; i) increases regulatory scrutiny across capital requirements, facilitating further oversight from national competent authorities (NCAs) of third country banks, and ii) introduces a mandatory subsidiarisation criteria of third country branches (TCBs). 

For third country banks, building a a robust response to CRD VI requires evaluation and design across entity structures, technology platforms and, operating model – with key consideration of broader regulatory / compliance impact resulting from changes in operating structure.