Sixth Capital Requirements Directive (CRD6) – Article 21c transposition tracker

Article 21c of the Capital Requirements Directive (“CRD”), as inserted by the sixth Capital Requirements Directive (“CRD6” or “CRD VI”), will impose new restrictions on certain third country undertakings intending to provide “core banking services” within an EU Member State. Under the new rules, such undertakings will be required to establish a regulated branch in the EU (a “third country branch” or “TCB”), unless an exemption applies.

EU Member States must transpose the Article 21c third country branch requirement into their national laws by 10 January 2026, with the rules taking effect from 11 January 2027. We are monitoring the latest developments from the UK and across our EU offices. Click here to access our transposition tracker from contributors across CMS.

To help you prepare, we have also published a brochure which sets out further detail on the third country branch requirement, together with our commentary on emerging issues and suggested next steps for potentially affected firms. Click here to access our brochure and ensure your firm is ready for the new rules.