CRD VI Transposition – Country Progress

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The Capital Requirement Directive VI (CRD VI) introduces a harmonized EU framework governing the provision of core banking services by third‑country banks, with full applicability by 11 January 2027. While the regulatory objectives and key reference dates are defined at EU level, the practical application of CRD VI depends on transposition into Member State law.

Although the transposition deadline expired on 10 January 2026, the implementation status across EU Member States remains uneven, leading to differences in timing, scope and supervisory interpretation.

The following transposition status tracker provides an overview of the current state of CRD VI implementation across relevant EEA jurisdictions and serves as a practical navigator to assess regulatory readiness, identify jurisdiction‑specific risks, and support informed strategic decisions on future servicing models.

CountryCurrent StatusSummary
AustriaOngoing - CRD VI not yet adoptedAustria has initiated CRD VI transposition through Ministerial Draft 108/ME XXVIII.GP, expressly transposing Directive (EU) 2024/1619 and amending the current regulatory framework. The draft has been submitted to the Federal Ministry of Finance on 18 June 2026. No final law adopted. Last official milestone: ministerial draft published on 20 May 2026 and submitted to the Federal Ministry of Finance on 18 June 2026.
BelgiumCompleted - CRD VI formally transposed on 22 July 2026Belgium has completed CRD VI transposition through the Law of 22 July 2026, adopted by the plenary of the House of Representatives on 16 July 2026 (DOC 56 1489/007), published in the Belgian Official Gazette (Moniteur belge / Belgisch Staatsblad) on 7 August 2026 and entered into force on 17 August 2026. The Law amends the Law of 25 April 2014 (Banking Law) and largely mirrors CRD VI as far as Articlle 21c is concerned. Grandfathering: Confirmed (contracts concluded before 11 July 2026 safeguarded as acquired rights). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: publication in the Moniteur belge on 7 August 2026; TCB rules apply from 11 January 2027.
BulgariaCompleted - CRD VI formally transposed on 22 July 2026Bulgaria has completed CRD VI transposition through amendments to the Credit Institutions Act (CIA), adopted by the National Assembly and promulgated in State Gazette issue 67 of 2026. The amendments introduce the third-country branch regime recognising the specific exemptions. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; interbank; intragroup; MiFID II investment and ancillary services). Last official milestone: promulgation in State Gazette issue 67 of 2026; TCB rules apply from 11 January 2027.
CroatiaCompleted - CRD VI formally transposed on 13 March 2026Croatia has adopted the CRD VI transposition act (20 February 2026); the new Credit Institutions Act transposing CRD VI into national laws was published on 5 March 2026 in the Official Gazette and entered into force on 13 March 2026. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue until expiry unless amended). Exemptions: Yes (reverse solicitation - client's own initiative only; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: publication of the new Banking Act in the Official Gazette; TCB rules apply from January 2027.
CyprusOngoing - CRD VI not yet adoptedCyprus has published draft amendments introducing the third-country branch regime; parliamentary adoption is pending. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: draft amendments published.
Czech RepublicCompleted - CRD VI formally transposed on 7 August 2025Czech Republic has completed CRD VI transposition (Act No. 280/2025 Sb., published on 7 August 2025; in force as of 11 January 2026), implementing the third-country branch regime under CNB supervision. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Latest official milestone: publication in the Collection of Laws; TCB rules apply from 11 January 2027.
DenmarkCompleted - CRD VI formally transposed on 11 June 2025Denmark has transposed CRD VI into its national laws on 11 June 2025; the third-country branch framework applies from 2027. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: national act adopted; TCB rules apply from January 2027.
EstoniaCompleted - CRD VI formally transposed on 17 June 2026Estonia has completed the parliamentary adoption of its CRD VI transposition package through Draft Act No. 848, amending the Credit Institutions Act and related legislation. The draft was introduced on 15 March 2026 and has subsequently been adopted by the Riigikogu on 17 June 2026. The legislative package implements CRD VI requirements, including amendments relating to credit institution governance and operational requirements. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: Riigikogu adoption of Draft No. 848 ("Vastu võetud"); TCB rules apply from 11 January 2027.
FinlandCompleted - CRD VI formally transposed on 14 July 2026Finland has adopted the legislative package implementing CRD VI through laws based on Government Proposal HE 22/2026 vp. The resulting laws, including Act 714/2026 amending the Act on Credit Institutions, were issued on 9 July 2026 and published on 14 July 2026. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official national milestone: CRD VI implementation laws published on 14 July 2026; TCB rules apply from 11 January 2027.
FranceCompleted - CRD VI formally transposed on 9 April 2026France has completed the transposition of CRD VI through Ordinance n° 2026-255 of 8 April 2026, published in the Official Journal on 9 April 2026. The French legislator expressly confirmed, in the Rapport au Président de la République accompanying the Ordinance, a no-gold-plating approach: Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: Ordinance published and effective (April 2026); TCB rules apply from 11 January 2027.
GermanyCompleted - CRD VI formally transposed on 30 March 2026Germany has completed transposition on 30 March 2026, formally promulgating the Banking Directive Implementation and Bureaucracy Relief Act (BRUBEG) on the Federal Law Gazette. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: BRUBEG promulgated (30 March 2026) and effective; TCB rules apply from 11 January 2027.
GreecePending - No legislative action initiatedGreece has no publicly confirmed legislative activity for CRD VI.
HungaryCompleted - CRD VI formally transposedHungary has communicated its full transposition to the European Commission prior to the January 2026 deadline.
IcelandPending - No legislative action initiatedIceland has no publicly confirmed legislative activity for CRD VI. Although CRD VI has been adopted for incorporation into the EEA Agreement by an EEA Joint Committee Decision, entry into force is pending the fulfilment of constitutional requirements.
IrelandCompleted - CRD VI formally transposed on 10 July 2026Ireland has completed CRD VI transposition through the European Union (Capital Requirements) (Amendment) Regulations 2026 (S.I. No. 326 of 2026), signed by the Minister for Finance on 10 July 2026. The statutory instrument amends the European Union (Capital Requirements) Regulations 2014 (S.I. No. 158 of 2014) and copies out CRD VI closely, without gold-plating the provisions set out in Article 21c (Third-country branch requirement). Grandfathering: Confirmed (EU baseline, contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: S.I. No. 326 of 2026 signed and in force from 10 July 2026; TCB rules apply from 11 January 2027.
ItalyCompleted - CRD VI formally transposed on 8 January 2026Italy has completed transposition on 8 January 2026; the third-country branch regime is in force together with supervisory add-ons. Grandfathering: Confirmed (Fixed-term contracts concluded before 11 July 2026 may continue while pre-existing open-ended contracts shall be terminated or transferred to a duly authorized intermediary unless reverse solicitation applies). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: legislative decree published and effective (January 2026); TCB rules apply from January 2027.
LatviaCompleted - CRD VI formally transposed on 9 June 2026Latvia has completed CRD VI transposition through amendments to the Credit Institutions Law, adopted on 14 May 2026, published on 26 May 2026 and in force from 9 June 2026. Confirmed (pre-11 July 2026 contracts). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services). Latest milestone: entry into force on 9 June 2026; TCB regime applies from 11 January 2027.
LiechtensteinOngoing - CRD VI not yet adoptedLiechtenstein has initiated CRD VI transposition through a Government-adopted report and motion amending the Banking Act and related laws; the proposal is pending parliamentary review, with first reading expected in June 2026 and entry into force planned for 1 January 2027. Last official milestone: Government adopted the report and motion on 28 April 2026; bill pending first parliamentary reading.
LithuaniaOngoing - CRD VI not yet adoptedLithuania received the European Central Bank (ECB) Opinion (14 August 2025) at the request of the Ministry of Finance on a draft law transposing CRD VI into national laws. Last official milestone: ECB opinion (CON/2025/23) on draft law received.
LuxembourgCompleted - CRD VI formally transposed on 6 May 2026Luxembourg has completed CRD VI transposition through the Law of 5 May 2026, published in the Official Journal on 6 May 2026 and in force from 10 May 2026. The Law introduces the harmonised third-country branch (TCB) framework and related CRD VI requirements. The separate independence chapter is being transposed through draft law 8705. Grandfathering: Confirmed (EU baseline, contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: entry into force of the Law on 10 May 2026; TCB rules apply from 11 January 2027.
MaltaOngoing - CRD VI not yet adoptedMalta has completed a full public consultation and issued a draft; parliamentary review is indicated as ongoing; no final law has yet been adopted. Grandfathering: Not confirmed. Exemptions: Not clarified. Last official milestone: consultation closed; draft package issued.
NetherlandsCompleted - CRD VI formally transposed on 22 September 2026The Netherlands has completed the Capital Requirements Implementation Act 2026 (Implementatiewet kapitaalvereisten 2026) on 22 September 2026, which amends the Financial Supervision Act (Wft), the Bank Act 1998 and the Economic Offences Act. The bill was approved by the House of Representatives on 28 May 2026 and by the Senate on 16 June 2026, and entered into force on 22 September 2026. Legacy contracts are subject to phasing-out (no changes permitted). Grandfathering: Confirmed (phasing-out — pre-11 July 2026 contracts may continue without changes only). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: bill entered into force on 22 September 2026; TCB rules apply from 11 January 2027.
NorwayCompleted - CRD VI formally transposed on 19 June 2026Norway has adopted the Act (Law No. 40 of 19 June 2026) amending the Financial Institutions Act and related legislation. The legislative amendments are in line with the Ministry of Finance's proposal in Proposition 39 L (2025-2026). While certain amendments entered into force on 1 July 2026, the remaining legislative amendments, including the TCB requirement, will enter into force at a later date. Grandfathering: Confirmed (EU baseline, contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: Law No. 40 adopted by the Parliament on 19 June 2026, TCB rules apply from 11 January 2027.
PolandOngoing - CRD VI not yet adoptedPoland has published a Government draft to implement CRD VI/CRR III; parliamentary adoption is pending and no final law has yet been adopted. Grandfathering: Confirmed (EU baseline — pre-11 July 2026 contracts may continue; no additional national rule). Exemptions: Yes (full TCB framework in the draft). Last official milestone: Government draft published.
PortugalPending - No legislative action initiatedPortugal has no publicly confirmed legislative activity for CRD VI.
RomaniaOngoing - CRD VI not yet adoptedRomania has initiated CRD VI transposition through a draft law amending Government Emergency Ordinance No. 99/2006 (and Law No. 236/2022), expressly transposing Directive (EU) 2024/1619 and Art. 2 of Directive (EU) 2024/2994. The draft was published by the Ministry of Finance for public consultation in February 2026, with favourable opinions from BNR and ASF; no final law has been adopted. Grandfathering and exemptions follow the CRD VI baseline through the OUG 99/2006 amendments. Last official milestone: publication of the draft law for public consultation (February 2026).
SlovakiaCompleted - CRD VI formally transposed on 27 February 2026Slovakia has transposed CRD VI through Act No. 30/2026 Coll., which amends the Slovak Banking Act and entered into force on 27 February 2026. The third-country branch (TCB) regime applies from 11 January 2027. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services). Last official milestone: Act No. 30/2026 Coll. in force on 27 February 2026, TCB rules apply from 11 January 2027.
SloveniaCompleted - CRD VI formally transposed on 25 February 2026Slovenia has published the new Banking Act on 25 February 2026, which entered into force on 12 March 2026, with the TCB regime applying as of 11 January 2027. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID II and ancillary services are exempted from CRD VI). Last official milestone: completed transposition (February 2026); TCB rules apply from 11 January 2027.
SpainOngoing - CRD VI not yet adoptedSpain has initiated the transposition of CRD VI. On 4 June 2026, the Spanish Economy Ministry confirmed that the government was intensively working on transposing the Directive. No draft legislation or final transposition act has yet been publicly identified. Last official milestone: confirmation by the Economy Ministry on 4 June 2026 that transposition work is ongoing.
SwedenCompleted – CRD VI formally transposed on 3 June 2026Sweden has transposed CRD VI through Bill 2025/26:253 "EU's banking package", which the Parliament approved on 3 June 2026 and which entered into force on 1 July 2026, with the third-country branch regime following on 11 January 2027. Grandfathering is confirmed along the EU baseline, meaning contracts signed before 11 July 2026 may continue until they expire, provided they are not amended. Exemptions also follow the EU baseline and cover reverse solicitation, intragroup services, interbank services, and MiFID II and ancillary services. Last official milestone: Parliament's approval of Bill 2025/26:253 on 3 June 2026, with entry into force of most amendments on 1 July 2026, while TCB rules apply from 11 January 2027.

Last updated on 28th September 2026

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EY Switzerland Financial Services Managed Service Lead
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Law Leader Financial Services, Ernst & Young AG
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