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CRD VI Transposition – Country Progress
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.
last update from 31/3/26
Country |
Current Status |
Summary |
|---|---|---|
|
Austria |
Pending - No legislative action initiated |
Austria has no publicly confirmed legislative activity for CRD VI. |
|
Belgium |
Ongoing - CRD VI not yet adopted |
Belgium has initiated CRD VI transposition with a preliminary draft approved by the Council of Ministers and sent for opinions; no bill is publicly before Parliament and no law is adopted. Grandfathering: Not confirmed. Exemptions: Not clarified. Last official milestone: Council of Ministers approval on 28 November 2025. |
|
Bulgaria |
Pending - No legislative action initiated |
Bulgaria has no publicly confirmed legislative activity for CRD VI. |
|
Croatia |
Completed - CRD VI formally transposed on 20 February 2026 |
Croatia 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 investment services remain outside the TCB scope). Last official milestone: publication of the new Banking Act in the Official Gazette, TCB rules apply from January 2027. |
|
Cyprus |
Ongoing - CRD VI not yet adopted |
Cyprus 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 investment services separate). Last official milestone: draft amendments published. |
|
Czech Republic |
Completed - CRD VI formally transposed on 20 February 2026 |
Czech 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 investment services separate). Latest official milestone: publication in the Collection of Laws. |
|
Denmark |
Completed - CRD VI formally transposed on 11 June 2025 |
Denmark 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 investment services separate). Last official milestone: national act adopted; TCB rules apply from 2027. |
|
Estonia |
Ongoing - CRD VI not yet adopted |
Estonia is in the process of amending its Credit Institutions Act and related legislation through a draft law which has completed inter‑ministerial coordination rounds during 2025 and January 2026; and was formally submitted to the Government session on 23 February 2026. Last official milestone: Draft submitted and under consideration at Government level. |
|
Finland |
Ongoing - CRD VI not yet adopted |
Finland has prepared a formal Government proposal (H 22/2026) implementing the CRD package, explicitly transposing CRD VI. The proposal was approved by the Government and has been submitted to Parliament on 12 March 2026. Last official milestone: Government proposal submitted to Parliament on 12 March 2026. |
|
France |
Pending - No legislative action initiated |
France has no publicly confirmed legislative activity for CRD VI. |
|
Germany |
Ongoing - CRD VI not yet adopted |
Germany has passed the Banking Directive Implementation and Bureaucracy Relief Act (BRUBEG) on 29 January 2026. BRUBEG is expected to be promulgated at the end of March 2026 with the TCB rules applying as of January 2027. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID investment services separate). Last official milestone: BRUBEG adopted, pending promulgation. |
|
Greece |
Pending - No legislative action initiated |
Greece has no publicly confirmed legislative activity for CRD VI. |
|
Hungary |
Pending - No legislative action initiated |
Hungary has no publicly confirmed legislative activity for CRD VI. |
|
Iceland |
Pending - No legislative action initiated |
Iceland 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. |
|
Ireland |
Ongoing - CRD VI not yet adopted |
Ireland conducted a public consultation on national discretions under CRD VI, which was published on 16 January 2025 and closed on 14 February 2025. The Department of Finance published its decisions on the exercise of national discretions. However, no draft bill or transposing legislation has yet been published. Last official milestone: publication of decisions on national discretions by the Department of Finance. |
|
Italy |
Completed - CRD VI formally transposed on 8 January 2026 |
Italy has completed transposition on 8 January 2026; the third‑country branch regime is in force together with supervisory add‑ons. Grandfathering: Confirmed (EU baseline — 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 investment services separate). Last official milestone: legislative decree published and effective (January 2026); TCB rules apply from January 2027. |
|
Latvia |
Ongoing - CRD VI not yet adopted |
Latvia has approved the draft laws amending the Credit Institution Law at Government level on 19 November 2025. Last official milestone: draft approval by the Cabinet of Ministers. |
|
Liechtenstein |
Ongoing - CRD VI not yet adopted |
Liechtenstein 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. |
|
Lithuania |
Ongoing - CRD VI not yet adopted |
Lithuania 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. |
|
Luxembourg |
Ongoing - CRD VI not yet adopted |
Luxembourg has closed the consultation and introduced the bill; committee stage is ongoing and no final law is adopted. Grandfathering: Not confirmed (per file). Exemptions: Yes (per draft). Last official milestone: bill deposited; dossier in committee. |
|
Malta |
Ongoing - CRD VI not yet adopted |
Malta has completed a full public consultation and issued a draft; parliamentary review is indicated as ongoing; no final law is adopted. Grandfathering: Not confirmed. Exemptions: Not clarified. Last official milestone: consultation closed; draft package issued. |
|
Netherlands |
Ongoing - CRD VI not yet adopted |
The Netherlands has submitted the implementation bill which is currently under parliamentary review; committee report issued on 4 March 2026. On 23 December 2025, the Dutch authorities announced that the transposition of CRD VI is delayed until Spring 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 investment services separate). Last official milestone: bill submitted; currently under parliamentary review. |
|
Norway |
Ongoing - CRD VI not yet adopted |
Norway has published draft legislation with detailed CRD VI implementation; the parliamentary stage is pending. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID investment services separate). Last official milestone: consultation completed; draft published. |
|
Poland |
Ongoing - CRD VI not yet adopted |
Poland has published a Government draft to implement CRD VI/CRR III; parliamentary adoption is pending and no final law is 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. |
|
Portugal |
Pending - No legislative action initiated |
Portugal has no publicly confirmed legislative activity for CRD VI. |
|
Romania |
Pending - No legislative action initiated |
Romania has no publicly confirmed legislative activity for CRD VI. |
|
Slovakia |
Ongoing - CRD VI not yet adopted |
Slovakia has published a draft law and entered parliamentary review; the proposal adopts the full third‑country branch regime, however no final law is yet adopted. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID investment services separate). Last official milestone: draft published; committee processing initiated. |
|
Slovenia |
Completed - CRD VI formally transposed on 25 February 2026 |
Slovenia 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 investment services separate). Last official milestone: completed transposition (February 2026); TCB rules apply from January 2027. |
|
Spain |
Pending - No legislative action initiated |
Spain has no publicly confirmed legislative activity for CRD VI. |
|
Sweden |
Ongoing - CRD VI not yet adopted |
Sweden has published the Government memorandum and closed the consultation; parliamentary processing continues and the third‑country branch framework is intended to apply from 2027. Grandfathering: Confirmed (EU baseline — contracts concluded before 11 July 2026 may continue). Exemptions: Yes (reverse solicitation; intragroup; interbank; MiFID investment services separate). Last official milestone: consultation closed on 15 September 2025. |
The team
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