Destinations · Switzerland · CRD VI · Own initiative

Opening a Swiss account without residence: what still works from January 2027

For residents of Sweden, Denmark, Finland and Norway, a Swiss account now runs through one of three routes. For residents of the UK, the EU rule does not apply at all.

A woman sits on a blanket on the shore of a Swiss lake in summer and laughs into the camera

Opening a Swiss account without living in Switzerland: that works now, and it remains possible after 11 January 2027, only by different routes. From that day, under Article 2 of Directive (EU) 2024/1619, EU member states apply the new branch requirement for banks from third countries. For clients resident in Sweden, Denmark or Finland, a Swiss bank's deposit business then runs through one of three routes: your own initiative, the securities account, or an authorised branch or subsidiary in the EU. The grandfathering for contracts concluded before 11 July 2026 no longer helps with a new opening.

Each bank sets its own minimum deposit, from the cantonal bank to the private bank, and it depends on the client segment you apply for. On tax: Swiss banks collect investment income and balances of accounts held by clients who are tax-resident abroad for the automatic exchange of information, according to the Swiss Federal Tax Administration, and the income belongs in your tax return at home, in the UK in the foreign section of Self Assessment. What documents the bank will ask you for is set out in Swiss bank account as a non-resident; which types of bank come into question in principle, on our Switzerland page.

For readers resident in the United Kingdom, by the way, the question does not arise. The EU rule attaches to clients established in the Union, and the UK has left it. A Swiss bank serving a client in London or Edinburgh needs no branch in the EU for that.

The rule from 11 January 2027

Article 21c of Directive (EU) 2024/1619, known as CRD VI, obliges EU member states to require banks from third countries to have a branch with its own authorisation when they take up or continue deposit-taking or lending with clients in the Union. From the directive's point of view, Switzerland is a third country. Under Article 2 of the directive, member states apply these provisions from 11 January 2027.

Each member state writes the rule into its own banking law, and the national texts differ at the edges. How far Ireland, Sweden, Denmark and Finland have got is set out in our article on CRD VI and EU residents. Norway is outside the EU but in the EEA, and the EEA Joint Committee took CRD VI into the EEA Agreement on 20 March 2026; Norwegian residents should plan with the same rule.

Grandfathering: the cut-off date has already passed

Here lies the point many overlook. The directive protects existing client relationships: under Article 21c(5), the branch requirement applies "without prejudice to existing contracts that were entered into before 11 July 2026". And under Article 2, member states apply exactly this protection rule from 11 July 2026.

For you that means: whoever opened a Swiss account before 11 July 2026 stands on safe ground, at least for what was agreed at the time. Whoever opens today is no longer covered by this grandfathering. An account you open in September 2026 is, from January 2027, a new client relationship in the sense of the directive. The hope of opening "quickly before the cut-off" therefore refers to a date that has already gone.

What still works: three legal routes

That does not mean a Swiss account becomes impossible for EU residents from 2027. The directive expressly leaves routes open.

1. Your own initiative. If a client approaches a bank in a third country "at its own exclusive initiative", the branch requirement does not apply under Article 21c(2). Two limits come with it. If the bank itself, or through a connected person, solicits you, it is no longer your own initiative. And the initiative covers only the product you asked for, plus what is necessary for it or closely related. Asking for an account does not automatically cover a later loan.

2. The securities account. Investment services under the Markets in Financial Instruments Directive MiFID II are exempt from the branch requirement under Article 21c(4), including the associated deposits. Whoever mainly wants to have wealth managed in Switzerland, or to hold a securities account there, moves within a different legal framework from someone looking for a plain savings account.

3. The authorised branch or subsidiary. A Swiss bank can have a branch authorised in an EU member state, or run its EU clients through a company in the EU. How such an authorisation works was laid down by the European Banking Authority on 7 July 2026 in final guidelines: what information the application must contain, by which criteria it is assessed, and that it must include a statement from the home supervisor that it has no objections. Two days later came the reporting package for third-country branches, with the first reference date on 31 March 2027. The framework for banks that want to take this route is therefore in place.

What your own initiative looks like in practice

The first route is the most important one for private clients, and it stands or falls with the question of who takes the first step. The directive is strict here. If a third-country bank solicits clients itself, through an entity with close links to it "or through any other person acting on behalf of such undertaking", that does not count as a service provided at the client's own exclusive initiative under Article 21c(2).

Three simple rules follow:

  • You write first. The first request comes from you, ideally in writing, and you keep it.
  • You do not answer advertising. An invitation to an information event, a newsletter or a call from a client adviser is exactly what rules the exception out.
  • You clarify whom an intermediary works for. Whoever approaches clients on behalf of the bank acts "on behalf of such undertaking". Whoever acts solely on your behalf is something else. If in doubt, have that confirmed in writing.

And remember the scope. Your initiative covers what you asked for. If you later want something new, a mortgage for example, the assessment starts again.

If you already have a Swiss account

For existing clients with a contract from before 11 July 2026, the position is more relaxed, but not entirely free of tasks. Keep the account agreement or an early confirmation from the bank so that you can prove the opening date. If your bank writes to tell you how it intends to serve its EU clients in future, read it carefully. If it says your account is moving to another company, that is the subsidiary solution, and it changes more than the letterhead. And check whether you still use the account as agreed at the time, because grandfathering depends on the existing contract, not on the client number.

What the subsidiary solution changes for you

The third route sounds harmless, but it deserves a close look. If your account is in future run by an EU company or an EU branch, it may still carry a Swiss name. Legally, however, your money then sits in the EU, under EU supervision, under EU resolution law and in the deposit guarantee scheme of the EU state concerned.

That is not a disadvantage in itself. It is just not what most people open a Swiss account for. Swiss deposit protection under Article 37a of the Banking Act covers deposits up to CHF 100,000 per creditor, and Article 37h relates the protection to deposits "at Swiss branches". Article 37a contains no residence condition: the privilege attaches to the deposit in your name, not to where you live. Whoever expressly wants to hold francs in Switzerland should therefore ask with every offer: which company runs my account, and in which country is it booked?

The directive also prevents a branch, once authorised, from serving the whole single market. Under Article 48c(4)(d), a third-country branch may not offer its services cross-border in other member states, apart from business at the client's initiative. An authorisation in Sweden does not cover Denmark. For smaller houses with few clients per country, that is an expensive calculation.

What does not change: reporting and tax

A Swiss account has not been a discreet account towards your tax authority for years. Switzerland exchanges account data with its partner states under the Federal Act on the International Automatic Exchange of Information in Tax Matters (AEOIA), and since 1 January 2026 under the extended version of the standard. Your account in Switzerland is reported to your country of residence, and the income belongs in your tax return there. CRD VI changes nothing about that; it is a supervisory rule about banks, not a tax rule. Nor does it change Swiss law itself. Under its Article 4 the directive is addressed to the member states, not to Switzerland. No Swiss bank has to turn EU clients away because of it. It only has to decide by which of the three routes it may serve these clients from 2027.

Which Swiss accounts are realistic in 2026

The Swiss banking landscape is broad. Cantonal banks, private banks, wealth management banks and digital providers have very different requirements for non-residents, from the minimum deposit to whether an opening at a distance is possible. Each bank sets its specific conditions itself, and for EU clients the question of which of the three routes the house chooses comes on top from 2027. Which types of account come into question for non-residents in principle is on our page on Switzerland. Whoever is weighing Switzerland against Asia finds the comparison in Singapore vs. Switzerland.

An alternative in the neighbourhood is obvious: Liechtenstein belongs to the European Economic Area and therefore to the single market, so it is to be judged differently from Switzerland. What is possible there is described in Open a bank account in Liechtenstein.

Residence decides

What remains decisive: CRD VI attaches to your residence, not to your passport. Whoever lives in Stockholm, Copenhagen or Helsinki is an EU client. Whoever has their residence outside the EU, in the UK, in Dubai, in Asia or in Latin America for instance, does not fall under Article 21c, whatever their citizenship. How accounts come about when your residence is no longer at home is described in Opening a bank account abroad.

For EU residents, 2026 therefore leaves one clear route: opening on your own initiative, properly documented, with a product you really need, and in the knowledge that the directive's grandfathering no longer applies to new accounts. Whoever knows that can keep using a Swiss account for what it is meant for.

Which type of bank and which route suit your situation is what the free consultation clarifies in a short conversation.

Note: This article is not tax, legal or investment advice. For individual tax questions, speak to a qualified tax adviser.