Updated: August 29, 2026 · Based on CRD VI, in particular Article 21c
Since August 2026, there has been growing discussion about whether the EU will effectively ban foreign accounts from 2027.
Some reports create the impression that EU residents will no longer be allowed to open bank accounts in Switzerland, Dubai, the United States, Singapore or other countries outside the European Union.
The discussion is based on a real change in European banking law: the Capital Requirements Directive VI (CRD VI) and, in particular, the new Article 21c.
However, the directive does not contain a general ban on foreign accounts.
The new rules are primarily directed at banks outside the EU. They may nevertheless have noticeable consequences for European customers:
Access to certain banks outside the EU may become more difficult from 2027.
What exactly will change? Which accounts and services are affected? And what can EU residents do in practice?
Quick answers
EU foreign-account ban 2027: Will foreign accounts really be prohibited?
No.
CRD VI does not prohibit EU residents from owning or opening an account outside the European Union.
Instead, the directive tightens the conditions under which banks from third countries may provide certain banking services within the EU.
What changes on January 11, 2027?
From January 11, 2027, third-country banks must generally maintain an authorised branch in the relevant EU Member State if they provide certain core banking services there.
The services concerned include in particular:
- deposits and other repayable funds,
- loans,
- guarantees and commitments.
Does this only affect private individuals?
No.
The provision is not limited to retail customers. Companies established within the EU may also be affected.
A German GmbH with an account at a Swiss or US bank can therefore also be a relevant CRD VI case.
Will existing foreign accounts be closed?
Not automatically.
For contracts concluded before July 11, 2026, CRD VI provides grandfathering protection for contractual rights already acquired.
The key dates
| Date | Significance |
|---|---|
| June 19, 2024 | CRD VI published |
| July 11, 2026 | Cut-off date for grandfathering of existing contracts |
| January 11, 2027 | New third-country branch regime becomes materially applicable |
For existing customers, the date on which the agreement with the bank was concluded is therefore particularly important.
What CRD VI actually changes
The decisive point about CRD VI is not a prohibition imposed on customers.
The additional regulatory burden falls on the bank.
If a bank from Switzerland, the United States, the United Arab Emirates or another third country wants to provide certain core banking services within an EU Member State, it will generally need an appropriately authorised structure.
This creates additional requirements relating to, among other things:
- capital,
- liquidity,
- governance,
- risk management,
- reporting,
- regulatory supervision.
For large international banking groups with many European customers, this effort may still be worthwhile.
Smaller or specialised banks may reach a different conclusion.
A bank could, for example, decide:
The regulatory burden is no longer worthwhile for our relatively small number of customers in Germany or Spain.
This would not mean that customers are no longer allowed to have a foreign account.
The bank could, however, stop accepting new EU customers.
That is precisely why the range of foreign accounts available may become smaller from 2027.
What is affected and what is not?
Not every financial service provided by a bank outside the EU automatically falls under the same rules.
| Service | Treatment under Article 21c |
|---|---|
| traditional bank or deposit account | generally relevant |
| credit or loan | generally relevant |
| guarantee or commitment | generally relevant |
| certain investment services | generally covered by the MiFID exemption |
| interbank transactions | exempt |
| certain intragroup transactions | exempt |
| reverse solicitation | possible exemption |
What about a Swiss securities account?
This is an important distinction.
Certain investment services remain subject to the European MiFID regime and are exempt from the new branch requirement under Article 21c.
A securities-only custody account is therefore not the same from a regulatory perspective as a traditional deposit account.
Anyone using both a custody account and a current, cash or deposit account with the same bank should nevertheless consider each service separately.
Does CRD VI also affect GmbHs and other EU companies?
Yes, and this point is often overlooked in the public discussion.
Article 21c is not only relevant to private individuals.
It may also apply to a:
- German GmbH or UG,
- Spanish SL,
- French SARL,
- Italian S.r.l.,
- other company established within the EU.
For example, if a German GmbH holds its business account directly with a Swiss bank, the new regime may be just as relevant as it is for an individual German banking customer.
The starting position is different for a company established outside the EU, such as a US LLC, UK Ltd. or UAE company.
| Account holder | Starting position |
|---|---|
| individual resident in the EU | Article 21c generally relevant |
| GmbH, SL or other EU company | Article 21c generally relevant |
| US LLC, UK Ltd. or UAE company | generally a different starting position; the specific structure must be reviewed |
We explain why this distinction matters for entrepreneurs in detail in our article “Business Account Outside the EU from 2027: What CRD VI Means for GmbH, US LLC & Co.”.
Reverse solicitation: When the customer approaches the bank
One of the most important exemptions is known as reverse solicitation.
It may apply where a customer contacts a bank outside the EU entirely on their own initiative and requests a banking service.
In simple terms:
The bank does not seek out the EU customer; the customer independently approaches the bank.
However, the exemption is narrow.
If the customer is actively approached by the third-country bank or by a person acting on its behalf, the requirement of exclusive customer initiative may not be met.
Reverse solicitation should therefore not be viewed as a general workaround for the new rules.
Nor does the exemption require a bank to accept EU customers.
A bank may independently decide that it no longer serves residents of particular countries.
What happens to existing foreign accounts?
CRD VI does not cause existing foreign accounts to be closed automatically on January 11, 2027.
For contracts concluded before July 11, 2026, the directive protects contractual rights already acquired.
However, this grandfathering should not be interpreted too broadly.
It does not automatically mean that:
- new products may be added,
- new credit facilities may be entered into,
- existing contracts may be changed or extended without restriction,
- the bank may never terminate the relationship.
Contract amendments, renewals or new services may trigger a new regulatory assessment.
The bank may also change its customer policy independently of CRD VI.
What can private individuals do from 2027?
Private individuals who already have or want to open a foreign account will continue to have several options.
Review an existing account
Existing customers of a bank outside the EU should first determine when their agreement was concluded and monitor how their bank implements CRD VI.
Approach suitable banks directly
Opening an account with a third-country bank may remain possible, particularly where the request genuinely originates from the customer.
Whether a bank accepts EU residents remains its own decision.
Distinguish between an account and a custody account
Anyone primarily using a securities account at a Swiss or other third-country bank should review which services are actually provided. Investment services are treated differently from traditional deposit business.
Consider alternative payment providers
Anyone who primarily needs foreign currencies, international payments, cards or multi-currency functions does not necessarily require a traditional bank account.
Depending on the use case, appropriately regulated payment institutions may also be suitable. Their licence and the specific service provided are decisive.
Bizkonto supports business accounts for companies only and does not assist with private account openings.
What does this mean for entrepreneurs?
For entrepreneurs, the situation is particularly relevant.
CRD VI does not simply distinguish between “private” and “business” use.
The decisive factors are where the respective banking customer is established and which service is provided.
This creates two very different situations:
EU company: A GmbH or SL may be affected by the new rules in the same way as an individual EU customer.
Company outside the EU: A US LLC, UK Ltd. or UAE company has a different regulatory starting position. Whether Article 21c applies must be assessed based on the actual establishment and the specific circumstances.
We explain these differences in detail in our article:
Business Account Outside the EU from 2027: What CRD VI Means for GmbH, US LLC & Co.
Conclusion
CRD VI does not prohibit EU residents from continuing to hold or open bank accounts in Switzerland, Dubai, the United States or other third countries.
The new rules primarily affect banks.
For some institutions, the additional regulatory burden may mean that they no longer accept EU customers.
Foreign accounts will therefore not disappear, but the range of available banks may become smaller.
Another distinction that is often missing from the current debate is important:
The new rules may affect private individuals and companies established in the EU alike.
For companies outside the EU, the starting position may be different.
Entrepreneurs should therefore consider not only the country in which the bank is located, but also which legal entity holds the account and how the overall banking structure is organised.
Frequently Asked Questions
Will the EU ban foreign accounts from 2027?
No. CRD VI contains no general prohibition on EU residents holding or opening accounts outside the EU.
When do the new rules apply?
The new branch requirement for the affected third-country banks becomes relevant from January 11, 2027.
What happens to existing accounts?
Contracts concluded before July 11, 2026 generally benefit from protection for existing contractual rights. The bank may nevertheless review or terminate the relationship for its own reasons.
Does CRD VI also affect companies?
Yes. A GmbH or another company established within the EU may also be an affected customer.
Is my Swiss securities account affected?
Investment services generally fall under the MiFID regime and are exempt from the Article 21c branch requirement. An additional deposit account must be considered separately.
Can I still open a Swiss bank account from 2027?
There is no personal prohibition. Whether a particular Swiss bank continues to accept EU residents depends on its regulatory structure and customer policy.
What is reverse solicitation?
It means that the customer contacts a third-country bank entirely on their own initiative. Under certain conditions, this may create an exemption from the branch requirement.
Does this also apply to a US LLC?
A company genuinely established outside the EU generally has a different starting position from an EU customer. The specific structure, including actual establishment and management, should nevertheless be assessed individually.
Does CRD VI apply identically in every EU country?
CRD VI creates a common European framework but is implemented nationally. Individual issues may therefore be interpreted or specified differently from one Member State to another.
Sources used
This article is based in particular on:
- Directive (EU) 2024/1619, CRD VI, in particular Article 21c
- the German Banking Act, in particular sections 53c to 53cq and section 64c
- Deutsche Bundesbank information on BRUBEG and the new third-country branch regime
- current publications by international law firms on the application of Article 21c
Note: This article provides general information on banking and regulatory developments. It does not constitute legal, tax or financial advice. Some questions concerning the application of Article 21c have not yet been conclusively resolved and may be assessed differently depending on the Member State and the circumstances.