Directive 2024/1619 (CRD VI) will (among other things) establish a new and more prescriptive EU regulatory regime for EU branches of non-EU banks. New harmonised licencing, authorisation, capital, liquidity, booking, and internal governance and risk management requirements will apply from 11 January 2027. New reporting requirements will apply from 11 January 2026.
In July 2025, the EBA launched three consultations on the specifics around the new ongoing requirements for such branches, which CRD VI refers to as ‘third-country branches’ (TCBs for the purposes of this note). In previous iterations of the Capital Requirements Directive, there was little detail concerning the accounting arrangements or required booking models for TCBs. This topic has in recent years come into increasing supervisory focus in the EU via initiatives such as the ECB’s ‘booking model’ project, where global financial institutions who book transactions involving EU counterparties or with EU connections were assessed. We are now presented with specific requirements addressing how TCB should account for particular transactions, assets and liabilities.
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