CRD VI: why your foreign bank account will need a residence outside the EU from 2027

On 19 June 2024 the European Union published a directive that almost nobody outside banking legal departments read. It is called CRD VI, and the article that matters carries the number 21c.

From 11 January 2027, a bank outside the European Economic Area may no longer hold accounts for people resident in the EU unless it operates a licensed branch in the exact member state where that customer lives.

The prohibition is not addressed to you. It is addressed to your bank. The result for you is the same.

What applies from 11 January 2027

Article 21c requires a firm from a third country that provides core banking services in an EU member state to hold an authorised branch in that member state.

Core banking services are three things: taking deposits, which covers every current account, savings account and fixed-term deposit. Lending. And the provision of guarantees and commitments. Anyone providing one of them to an EU resident falls under the rule.

Two details decide how hard this bites.

First, a licence in Dublin covers Ireland and nothing else. Third-country branches carry no passporting rights across the Union. A Swiss bank that wanted to keep its EU private clients would have to run the authorisation process separately in every single member state where it holds them.

Second, the deposit-taking limb is the broadest of the three. For lending and guarantees the rule captures firms that would qualify as credit institutions if they were established in the EU. For deposits it applies to third-country firms regardless of that status. Anyone hoping this is a wholesale matter of syndicated loans and corporate finance will not find comfort in the drafting.

Does it apply to EU citizens or EU residents?

To residents. That distinction is the single most important point in the whole regime.

Article 21c attaches to where the client is established, not to what passport the client holds. A Briton living in Málaga is caught. An Irish citizen living in Panama is not. The bank is not looking at your nationality. It is looking at your tax residence and your proof of address.

What follows from that is what the answer is, and what it is not. A second passport does nothing for you here. It changes your citizenship, not your residence. Anyone holding a Caribbean citizenship while still registered in Dublin or Stockholm is an EU resident like everyone else.

What works is residence. Residence is usually faster, cheaper and less complicated to obtain than a second citizenship.

The deadline that has already gone

There is grandfathering. Contracts and client relationships entered into before 11 July 2026 may continue to be performed, as long as nothing material about them changes.

That date is behind us.

Anyone who was waiting to see whether this became real has already missed the only deadline that would have given them something for free.

And the grandfathering is weaker than it sounds. It protects the continued performance of an existing contract. It obliges no bank to keep you. A bank remains free to end the relationship on its own initiative at any time, as thousands of British customers of EU banks and EU customers of British banks discovered after 2016.

What happens to an account I open now?

It is entirely legal today, and it is exposed from January 2027.

An account opened now sits in the gap: after the 11 July 2026 cut-off, before the rule takes effect on 11 January 2027. Until then nothing changes, because the provision does not yet apply.

From 11 January 2027 it is caught. The reason is in the wording: Article 21c covers not only commencing but expressly also continuing the activity. Holding your account open is continuing. From January 2027 the bank needs a branch in your member state, a defensible record that you approached it entirely on your own initiative, or it ends the relationship.

In practice that means one of three letters arrives at some point during the year. Closure, transfer to another company in the banking group, or a request to confirm your residence.

An account on its own therefore does not solve the problem. It buys you four months. What it does solve is access: the door is open today and will not be in December. Open the account now and move your residence outside the EU before January, and you hold a banking relationship formed under easier conditions that then simply sits outside the scope of the rule. Open only the account, and you have the beginning of a process rather than the end of one.

Why banks will move earlier than the law requires

For a bank in Zurich, Singapore or Tbilisi the arithmetic is plain. On one side, a private client with a six or seven figure balance. On the other, an authorisation process with capital, liquidity and governance requirements in a foreign legal system, plus the liability if the assessment turns out wrong.

The arithmetic does not work. It does not narrowly fail to work, it fails by a distance.

There is a theoretical exception, known as reverse solicitation: the bank may serve you where you approached it demonstrably and exclusively at your own initiative. In practice the bank carries the full burden of proving that, and national supervisors have been given powers to monitor exactly how the exception is being used. Legal departments that know this do not build a business model on it.

So the change will not happen on 11 January 2027. It happens in the months before, quietly, through onboarding rules that stop accepting EU addresses.

I am British and I live in Spain, France or Portugal

You are caught, and you are caught twice over.

For Article 21c what counts is not your citizenship and not where you pay your pension into. It counts that you are resident in a member state. Spain, France, Portugal, Italy, Cyprus, Malta and Ireland are all member states. For a bank in Zurich or Singapore there is no difference between an address in Manchester and an address in Málaga, except that the Málaga address is the one that now creates the problem.

The second layer is the one this readership already lived through. Your UK bank is a third-country bank for these purposes. After Brexit, a wave of British banks closed accounts for customers with EU addresses rather than build EU permissions. From January 2027 the underlying rule is no longer a matter of each bank's own risk appetite. It is EU law, harmonised, with an application date on it.

The pattern is worth naming, because it is the argument for acting early rather than a reason for alarm: rights that looked permanent turned out to have a cut-off date attached, and everyone who had not sorted their position by that date was on the wrong side of it.

I live in Ireland, Sweden, Denmark, Finland, Norway or Iceland

Ireland transposed Article 21c on 10 July 2026 through the European Union (Capital Requirements) (Amendment) Regulations 2026, S.I. No. 326 of 2026. It is a straight copy-out of the European text, with no Irish additions and no Irish softening, and neither the Department of Finance nor the Central Bank intends to publish guidance. The regime applies from 11 January 2027.

Denmark moved earliest of all. The Danish parliament passed its transposing act in June 2025 and the branch requirement enters into force on 1 January 2027. Danish residents are among the first in Europe for whom this is settled national law rather than a pending file.

Sweden has completed its transposition. Finland's legislation cleared parliament and was awaiting final publication through mid-2026.

Norway and Iceland are the genuinely open cases, and the honest answer is that the timing is unresolved. CRD VI is marked as EEA-relevant, but it has not yet been incorporated into the EEA Agreement. Norway has largely completed its own legislative work, and entry into force there depends on that incorporation. Iceland had not adopted final implementing legislation through mid-2026. What that does not mean is that a Norwegian or Icelandic address keeps a door open. Banks in Zurich and Singapore set onboarding policy by the strictest reading of a region, not by the transposition status of one country in it, and they set it once for the whole EEA.

Across the Union the picture is uneven in a way that matters practically. The European Commission's own transposition monitoring shows member states that have still not notified complete measures, with infringement proceedings pending against them. The date does not move because your member state is late. What varies is how the national text reads on the edges, not whether 11 January 2027 arrives.

I live in the United Kingdom

You are not caught, and you should read that carefully.

The rule applies to clients established in the EEA. A UK resident is not one. Your access to banks in Switzerland, Singapore, the United States and everywhere else is unaffected by Article 21c, and there is currently no equivalent restriction being introduced in UK law.

What is affected is the other direction: your UK bank's EU-resident customers. If you hold a British account and are considering a move to Portugal, Spain or Ireland, the account you keep in London becomes a third-country account on the day you register your new address, and it is the move that triggers the question, not the bank.

For a UK reader the sensible reading of CRD VI is not that it is somebody else's problem. It is a working demonstration of how quickly a category of access can be closed by calendar, in a jurisdiction you might have been planning to move to.

What is not affected

The rule is severe enough on its own and needs no exaggeration.

Investment accounts are outside it. Services covered by MiFID II sit outside Article 21c, along with deposit-taking and credit that are genuinely ancillary to them. A brokerage account held outside the EU is a different legal question, even though plenty of brokers are tightening their own acceptance criteria independently.

The EEA is not a third country. Banks in Liechtenstein, Norway and Iceland hold European passporting rights and may continue to serve EU residents. That makes Liechtenstein one of the last locations that stays regularly reachable for an EU resident after 2027, with an account there typically starting from CHF 100,000. The honest other side: the EEA takes on European resolution rules too, so an account in Vaduz still sits inside the same supervisory framework. It solves the access problem, not the access-by-the-state problem.

Interbank and intragroup business is exempt, which matters to banks and not to you.

What the EU actually achieves with this

Officially the subject is financial stability and the supervisory gaps left by Brexit.

The effect can be described independently of the intent. Through the automatic exchange of information, European tax authorities have known for years which accounts a taxpayer holds abroad. Transparency is not the problem being solved here. What CRD VI changes is not what the EU knows about your money, but where your money is allowed to sit.

It is not a capital control in the classic sense. Nobody is stopping you from making a transfer. The rule operates one step earlier: it decides who is permitted to hold your money at all. A control that restricts access rather than transfers needs no emergency and no exceptional circumstances. It runs on a calendar.

The rest of the picture belongs alongside it: the centralised account registers, the authority access to them, the European resolution rules that can reach deposits above the guarantee limit in a crisis, and the preparatory work on the digital euro. Each measure has its own justification. Together they describe a legal space in which wealth is not only visible but reachable.

Nobody needs to attribute intent to state the outcome: anyone who wants to hold assets outside that framework has one route fewer from January 2027.

The two routes that remain

First, a residence outside the EU. Article 21c attaches to where the client is established. Someone not established in the EU is not caught. That is the direct and durable route, and it simultaneously opens banks that have been wary of European addresses for years anyway.

Which country makes sense depends less on the tax rate than on whether banks accept the address and whether you actually want to be there. Two directions that work in practice for this readership:

The Philippines. Section 23(D) of the Philippine tax code contains a remarkably plain sentence: a foreign national is taxable there on Philippine-source income only, resident or not. Pensions, dividends and income from elsewhere fall outside the Philippine net. The banking effect matters more still: Asian banks decline European addresses long before CRD VI enters the conversation. With Philippine residence you are a regional client in Singapore rather than a European liability, and Davao to Singapore is a direct flight under four hours. That produces a structure that sets up cleanly: Davao to live, Singapore for the assets. The permanent residency route and how it actually runs is on MyDavaoBase, our Philippines site.

Latin America. Paraguay, Panama and Mexico have been the standard answers for a durable residence under territorial taxation for years, and all three are well established with Swiss and US-facing banks.

The rest. Other countries work, and a few set off alarms on the banking side immediately. Which one carries your case depends on your bank, your assets and where you genuinely want to spend time. That is what the free consultation is for.

Second, the account runs through a company outside the EU rather than in your own name. The bank's counterparty is then a non-EU entity and the rule does not bite in the same way. This is the practical route for business accounts, and a US LLC is usually the cleanest vehicle for it. It changes nothing about tax: a company managed from inside your home country stays taxable there, and your domestic anti-avoidance rules apply unchanged. Anyone taking this route has to set it up properly or they acquire a second problem alongside the first.

Why an address on its own is not a route

A third idea circulates: obtain a tax number and a utility bill somewhere, give that address to the bank, and step outside the scope.

One thing is worth knowing about that. What you sign when you open an account is not an address field. It is a self-certification of your tax residence. It is a legally binding declaration, and a false declaration is a separate offence in many jurisdictions, independent of whether any tax was underpaid. The risk sits with the account holder, not with the bank and not with the adviser.

A residence outside the EU works. An address that does not reflect a residence is a bet, not a route. The difference between the two is exactly the work that has to be done.

What to do now

Grandfathering has expired. The rule applies from 11 January 2027, and the point at which banks finish rewriting their onboarding rules comes before that date rather than after it.

That produces an order of operations, and the order matters more than the individual parts.

The account and the residence are one process, not two purchases. The account first, because opening one still works today and will not in a few months. The residence second, but before January, because otherwise the account becomes exposed at precisely the moment the rule takes effect. Doing only one of the two leaves you with either a banking relationship on a timer or a residence without the bank it was meant for.

Concretely: open the account in Singapore or Switzerland now, set up the Philippine residence in parallel, and from January you are simply not an EU client as far as the bank is concerned. Both need lead time. A residence does not appear in a fortnight, and the sequence does not reverse.

We open accounts outside the EU and we set up the residences those accounts will require from 2027. One process from one firm, not two providers waiting on each other. In a free consultation we work out which combination carries your case and in what order it has to be built.

Sources and legal texts

Everything on this page can be read at source.

• Directive (EU) 2024/1619 (CRD VI), published in the Official Journal on 19 June 2024. The branch requirement is Article 21c; the requirements for third-country branches run from Article 47 to Article 48s.
• Ireland: European Union (Capital Requirements) (Amendment) Regulations 2026, S.I. No. 326 of 2026, signed 10 July 2026, transposing Article 21c into Irish law.
• Directive 2014/65/EU (MiFID II) for the boundary with investment services.
• EBA report under Article 21c(6) CRD VI, July 2025. The European Banking Authority examined whether the exemptions should be widened and decided against it.
• European Commission transposition monitoring, CRD VI for the current national status.

The directive is transposed separately in each member state and the national rules differ in detail. What governs your case is the law of the state in which you are resident.