CRD VI: No more foreign bank accounts for Europeans?
The headline that EU citizens will be barred from opening bank accounts abroad from 2027 has been circulating for weeks, and we receive daily messages from clients asking whether they need to open an account now before the door closes. The rule exists, it is real, and it takes effect on 11 January 2027. But it is addressed to banks rather than to you, and it concerns people who live in the EU rather than everyone who holds an EU passport.
What the rule actually says.
The legislation is the sixth Capital Requirements Directive, CRD VI, formally Directive (EU) 2024/1619. It was adopted in July 2024 and the provision that matters is Article 21c. In substance it provides that, from 11 January 2027, a bank from a third country, meaning a country outside the EU and the European Economic Area, may provide certain core banking services to clients in the EU only through an authorised branch in the member state concerned. Core banking services means three things: taking deposits, which is to say accounts holding balances; lending; and issuing guarantees.
CRD VI is therefore a market-access rule. It governs who may carry on banking business in the EU. It is not a rule that prohibits you from holding an account abroad, and it contains not a single provision that penalises you as a customer. If a bank breaches the rule, the bank has the problem, not you.
Nor is the idea new. Germany has for decades prohibited foreign banks from actively soliciting the German market without a licence from BaFin. What is new is that the EU now codifies this uniformly for all member states and tightens it with the branch requirement.
The error in the headline: citizens versus residents.
Now to the most important point. The directive speaks of clients established or resident in the EU. The test is residence, not nationality.
A German national who lives in Dubai, is tax resident in the Emirates and has a home there is not a client in the EU. The rule does not apply to him, and he can open an account with a bank in Singapore, Hong Kong, Georgia or Switzerland exactly as he can today. Conversely, an American living in Berlin is a client in the EU, and the rule applies to him even though he holds no European passport.
For anyone who has emigrated or intends to, CRD VI is irrelevant, provided they actually leave the EU. For anyone who remains resident in Europe it becomes more complicated, but by no means impossible.
Who is actually affected.
The rule bites on banks in third countries: Switzerland, the United States, Singapore, Hong Kong, Georgia, the Emirates and, in short, every country outside the EU and outside the EEA.
It does not bite on banks in the EU or in the European Economic Area, and the EEA includes Liechtenstein, Norway and Iceland. A Liechtenstein bank may therefore continue to accept clients from Germany and Austria without maintaining a branch in either country. For many clients resident in the EU, Liechtenstein is consequently the obvious answer when the objective is an account outside the eurozone, in Swiss francs and with an institution steeped in private banking.
The three exemptions written into the directive.
The directive contains exemptions, and they are not loopholes that somebody invented but provisions that appear in the text itself.
Exemption one: grandfathering
Contracts concluded before 11 July 2026 continue to run. Article 21c says so expressly. Anyone who already holds an account with a bank in Switzerland, Singapore or Dubai keeps it, and the bank is not required to close it. That date has already passed, so for existing accounts the matter is settled.
Exemption two: the client's own initiative, known as reverse solicitation
This is the most important exemption. The rule prohibits third-country banks from actively soliciting clients in the EU; it does not prohibit a client from approaching a bank of his or her own accord. If you travel to Zurich yourself, present yourself at a bank yourself and submit the application yourself, the bank has not solicited in the EU but merely responded to a request. That is the passive freedom to provide services, and it survives under CRD VI.
For the bank, however, this exemption carries risk, because the bank must be able to document that the initiative came from you. Many banks will therefore be cautious, and some will decline EU-resident clients as a matter of policy because the effort is not worth it to them. That is not a legal prohibition but a commercial decision by the bank, and in practice this is exactly where it is decided whether you obtain an account or not.
Exemption three: the branch
Banks that wish to continue actively serving the EU market may establish an authorised branch in the member state concerned. Large institutions may well do so; for smaller or purely national banks it will not be worth it. Those banks will concentrate on clients who are not resident in the EU, or on clients who come to them on their own initiative.
How it still works from 2027.
Depending on your starting position, an account outside the EU remains available from 2027 by the following routes.
| Your situation | What applies | The route |
|---|---|---|
| You live in Germany or Austria and want a personal account outside the eurozone | CRD VI applies to the third-country bank | Your own initiative: you approach the bank actively and state your interest. This works best with banks that have set up their process for it. Alternatively, a bank within the EEA, above all in Liechtenstein. |
| You have emigrated or are about to | CRD VI does not concern you | You must be able to prove your residence outside the EU to the bank, but that has always been the case. |
| You own a company outside the EU | What matters is where the company is actually managed | If it is managed where it is registered, with a director on the ground, an office and substance, it is not an EU client. If it sits abroad only on paper, its account was a problem before CRD VI and is now a bigger one. |
| You already have an account | Grandfathering | Keep it and do not close it. Anyone who gives up a functioning account in order to do something new before 2027 is making life unnecessarily difficult. |
What not to do now.
Three things we are seeing frequently at the moment, and against which we expressly warn.
Opening an account somewhere in a panic simply in order to have one.
An account you do not need, at a bank you do not know, in a country with which you have no connection, serves no purpose.
Falling for providers promising a guaranteed account opening despite the EU ban.
The directive is addressed to banks, and anyone who promises to circumvent it is promising that a bank will put its licence at risk. No bank will. What works legitimately are the routes described above: residence, own initiative, the EEA and substance.
Confusing the subject with tax.
A foreign account changes nothing about your tax liability. The automatic exchange of information exists, the account is reported, and the tax office knows about it. An account abroad is a tool for diversification, for currencies and for access to other markets, nothing more.
Frequently asked questions.
Will Germans be unable to open bank accounts abroad from 2027?
No. CRD VI is addressed to third-country banks that wish to actively serve clients in the EU. Anyone resident outside the EU is unaffected. Anyone resident in the EU may still approach a bank on their own initiative or choose a bank in the EEA, for example in Liechtenstein.
What happens to my existing account in Switzerland or Dubai?
Nothing. Contracts concluded before 11 July 2026 are grandfathered under Article 21c. The bank is not required to close the account, and you should not give it up without good reason.
Does CRD VI apply to Liechtenstein?
No. Liechtenstein is part of the European Economic Area and its banks are not third-country institutions within the meaning of the directive. They may continue to accept clients from Germany and Austria without a branch in either country.
What is reverse solicitation?
The client's own initiative. Where a client approaches a third-country bank of his own accord, without the bank having solicited in the EU, the bank may provide the service. The bank must document that initiative, which is why some institutions decline EU-resident clients out of caution.