Updated: August 29, 2026 · Based on CRD VI, in particular Article 21c
The current discussion about CRD VI almost always focuses on private individuals:
What happens to a Swiss account? Can an account still be opened in Dubai from 2027? Is the EU banning foreign accounts?
For entrepreneurs, one crucial point is often missing:
Article 21c does not only affect private individuals. The business account of a GmbH or another EU company with a bank outside the EU may also fall within the new rules.
At the same time, the starting position for a US LLC, UK Ltd. or UAE company is fundamentally different.
One question will therefore become particularly important for entrepreneurs from 2027:
Which bank fits my international company, and how does CRD VI change the available options?
Quick answers
Does CRD VI also affect business accounts?
Yes.
Article 21c is not limited to private customers. The decisive question is whether a third-country bank provides certain core banking services within the EU.
Companies established in the European Union may therefore also be affected.
Is the account of a German GmbH at a Swiss bank affected?
It can be.
The GmbH is an EU company. If a Swiss third-country bank maintains a deposit account or grants a loan to it, Article 21c is generally relevant from 2027.
What applies to a US LLC?
A US LLC genuinely established outside the EU has a different starting position.
The banking customer is the US company, not the individual behind it.
There is therefore a strong basis for concluding that Article 21c does not apply to a genuine non-EU company in the same way as it applies to a GmbH.
However, this should not be reduced to “US LLC = not affected”.
The specific structure must be reviewed, especially where the company is managed exclusively from the EU or has its actual operating presence there.
The decisive distinction: Where is the banking customer established?
CRD VI is intended to regulate more closely the cross-border provision of certain banking services by third-country banks within the EU.
We explain what CRD VI generally changes for foreign accounts from 2027 in our article “Foreign Accounts from 2027: Will the EU Ban Accounts in Switzerland, Dubai & Co.?”.
For companies, this means:
| Account holder | Starting position from 2027 |
|---|---|
| German GmbH or UG | EU company → Article 21c generally relevant |
| Spanish SL | EU company → generally relevant |
| French SARL | EU company → generally relevant |
| US LLC | non-EU company → generally a different starting position |
| UK Ltd. | non-EU company → generally a different starting position |
| UAE FZCO or FZE | non-EU company → generally a different starting position |
This distinction is often overlooked in the current debate about foreign accounts.
For internationally active entrepreneurs, it is considerably more important than whether the account is used for “private” or “business” purposes.
What does CRD VI mean for a GmbH's foreign account?
Consider a German GmbH with a business account at a Swiss bank.
From the perspective of EU banking law, Switzerland is a third country.
The GmbH, on the other hand, is a customer within the EU.
If the Swiss bank provides the GmbH with one of the core banking services covered by Article 21c, the new branch regime may generally become relevant from January 11, 2027.
This applies in particular to:
- deposit accounts,
- credit and loans,
- guarantees and commitments.
The fact that the customer is a company does not fundamentally change this.
The same may apply, for example, to an:
- Austrian GmbH,
- Spanish SL,
- French SARL,
- Italian S.r.l.
with a direct banking relationship at a bank in Switzerland, the United States, Dubai or another third country.
The same principle generally applies to other corporate accounts held by EU companies with third-country banks.
What does this mean in practice?
It does not mean that the bank must automatically close the account.
The bank must, however, decide whether and how it can continue serving its EU corporate customers under the new regulatory framework.
A large international institution may already have an appropriate EU structure.
A smaller institution may decide that the regulatory burden is not worthwhile.
As a result, certain EU companies may no longer be accepted in the future.
What applies to existing business accounts?
For companies, July 11, 2026 is also an important cut-off date.
Existing contracts concluded before that date generally benefit from grandfathering in respect of contractual rights already acquired.
This does not mean that every subsequent change is automatically protected.
Particular care is therefore required with:
- new credit facilities,
- contract renewals,
- additional banking products,
- material changes to existing contracts.
A bank may also change its customer policy independently of CRD VI.
Companies that already hold an account with a third-country bank should therefore review at an early stage how their institution intends to deal with the new regime.
What does CRD VI mean for the business account of a US LLC?
The starting position is different for a US LLC or another company genuinely established outside the European Union.
Examples include:
- US LLC,
- UK Ltd.,
- UAE FZCO or FZE,
- other companies genuinely established outside the EU.
For a US LLC business account, the LLC itself is the banking customer.
The banking agreement is not held in the name of the individual owner but in the name of the company.
This creates a different initial regulatory connection from that of a German GmbH.
Current legal analyses therefore provide a strong basis for concluding that a company genuinely established outside the EU does not fall under Article 21c merely because its beneficial owner lives in the EU.
This is not an automatic loophole
An important distinction is required here.
For a US LLC with a German or Spanish UBO, the bank will still examine:
- who the ultimate beneficial owner is,
- where that person lives,
- where the company is actually managed,
- the company's economic purpose,
- where its customers and business partners are located,
- where its funds originate,
- which transactions will run through the account.
What does this mean for bank selection?
CRD VI does not solve the most important banking challenge faced by international companies:
Not every bank accepts every company.
In our work with international companies, we regularly see the same pattern:
An entrepreneur already owns a US LLC, for example, and only during account opening discovers that the preferred bank does not accept it or that the application is rejected.
The reasons vary considerably.
Bank A accepts the US LLC but not the UBO's country of residence.
Bank B accepts the company and the UBO but does not provide the required currencies.
Bank C may be suitable in principle but requires a stronger US connection or more extensive evidence of business activity.
Bank D may be suitable for normal payment operations but not for the planned transaction volume.
For this reason, Bizkonto does not simply assess which banks generally open accounts for US LLCs or international companies. We consider which institutions fit the specific case.
You can find more information about common rejection reasons in our article “Business Account Rejected: Causes and Possible Solutions”.
The decisive question is therefore not:
“Which bank opens accounts for US LLCs?”
It is:
Which bank fits my international company?
Depending on the company, UBO, activity and payment profile, suitable institutions may be located in very different regions, including the United States, Switzerland, the Caribbean, the United Arab Emirates or Asia.
Our international business account comparison provides an initial overview.
What entrepreneurs should review before 2027
Anyone already using international banking relationships should clarify several points.
Who is the actual account holder?
Is it:
- a German GmbH,
- another EU company,
- a US LLC,
- a UK Ltd.,
- a UAE company?
This question can be decisive for the Article 21c analysis.
Which banking service is being used?
A traditional deposit account, loan or guarantee carries a different regulatory weight from pure payment services or certain investment services.
When was the contract concluded?
Contracts concluded before July 11, 2026 generally benefit from grandfathering for acquired rights.
Does the bank still fit the structure?
A bank may change its onboarding policy independently of CRD VI.
International companies in particular should not assume that a banking solution that works today will remain unchanged permanently.
Consider a second banking relationship
A company whose entire liquidity is held with a single institution carries operational risk.
A more resilient banking setup may use accounts at different institutions in different regions.
A US LLC as part of an international structure
For a European company such as a GmbH or OÜ, a US LLC may be relevant for a variety of reasons.
It may be used, for example, for:
- opening an account abroad,
- international business activity,
- consulting and online businesses,
- shareholdings,
- investments,
- international payment flows,
- holding certain assets.
For banking purposes, a US LLC or another international company creates its own corporate structure outside the European regulatory framework. It may also form an important part of an internationally diversified corporate or asset structure.
Owners of an existing US LLC can find further details in our guide to a business account for a US LLC in Europe.
Do you not yet have a US LLC?
Entrepreneurs who do not yet have a US LLC and want to establish an international corporate structure can coordinate formation and banking from the outset.
Together with our partner Staatenlos, we can coordinate LLC formation and the subsequent account-opening process.
Simply send us a message through our contact form.
Which banks may be suitable for my company?
This question cannot be answered based on the legal form alone.
At Bizkonto, we review with you, among other things:
- company and jurisdiction,
- UBO's country of residence,
- business activity,
- required currencies,
- expected payment volumes,
- SEPA and SWIFT requirements,
- countries involved,
- requirements of the institutions under consideration.
We can then narrow down which banking solutions fit the actual structure and support you through the administrative account-opening process.
Conclusion
CRD VI changes international banking not only for private individuals.
A GmbH or another EU company may also be affected if it receives core banking services directly from a bank outside the EU.
For a company genuinely established outside the EU, such as a US LLC, the regulatory starting position is fundamentally different.
This does not mean that every non-EU company can automatically open any international account.
The practical challenge remains the same:
The bank must fit the company, the UBO and the actual intended use of the account.
This selection is likely to become even more important from 2027 if individual banks tighten their customer policies regarding EU connections.
If you already own a US LLC, UK Ltd., UAE company or another international company and are looking for a suitable business account, Bizkonto can review the administrative requirements of your case with you.
Frequently Asked Questions
Does CRD VI affect my GmbH's business account?
In principle, yes, if a third-country bank provides the GmbH with a core banking service covered by Article 21c within the EU and no exemption applies.
What applies to my GmbH with a Swiss bank account?
The GmbH is an EU company. Its account with a Swiss third-country bank may therefore fall under the new regime. Existing contracts concluded before July 11, 2026 generally benefit from grandfathering for rights already acquired.
Is a US LLC affected by CRD VI?
There is a strong basis for concluding that a US LLC genuinely established outside the EU does not fall under the central Article 21c connection in the same way as an EU company.
The specific classification should nevertheless be reviewed, especially where there is EU management or an EU operating presence.
Does the EU residence of the UBO make a US LLC an EU customer?
Not automatically. The UBO's residence and the company's establishment are separate questions. The UBO's EU residence remains relevant to KYC, risk assessment and the overall structure.
Is a UK Ltd. also a non-EU company?
Yes. From the EU's perspective, the United Kingdom is a third country. The company's actual establishment and structure must also be considered.
Is a UAE Freezone Company affected?
A company genuinely established in the UAE also has a different starting position from an EU company. The specific assessment depends on the structure and banking relationship.
Are payment institutions also affected?
Not automatically. Article 21c covers certain core banking services. The provider's specific licence and the service actually provided are decisive.
Do I need to change my existing banking relationship now?
Not automatically. First review who the account holder is, when the contract was concluded, which services are used and how the bank itself intends to deal with CRD VI.
Sources used
This article is based in particular on:
- Directive (EU) 2024/1619, CRD VI, Article 21c
- the German Banking Act, sections 53c to 53cq and section 64c
- Deutsche Bundesbank information on BRUBEG and the third-country branch regime
- current publications by international law firms on the application of Article 21c to EU and non-EU companies
Note: This article provides general information on banking and regulatory developments. It does not constitute legal, tax or financial advice. The interpretation of Article 21c, especially for companies incorporated outside the EU but managed from within the EU, has not been conclusively resolved in every situation and may differ depending on the Member State and the circumstances.