EBA publishes report on exemption of third country entities from the requirement to set up a branch for the provision of banking services to EU financial sector entities

RegCORE Client Alert | Financial Services

EBA publishes report on exemption of third country entities from the requirement to set up a branch for the provision of banking services to EU financial sector entities

QuickTake

On 23 July 2025, the European Banking Authority (EBA), in consultation with the European Securities and Markets Authority (ESMA) and the European Insurance and Occupational Pensions Authority (EIOPA), published its long-awaited report mandated by Article 21c(6) of Directive 2013/36/EU (as amended by CRD VI) (the Report) Available hereShow Footnote. The Report assesses whether third country undertakings (TCUs) should be exempted from the requirement to establish a branch in the EU when providing “core banking services” to EU financial sector entities (FSEs) other than credit institutions. The analysis draws on available supervisory data and stakeholder input, with a focus on financial stability and EU competitiveness.

It is important to highlight that, for the purposes of this Report, the EBA defines FSEs as including investment firms, asset management companies, insurance and reinsurance undertakings, payment institutions, e-money institutions, issuers of asset-referenced tokens and crypto-asset service providers. Entities such as central counterparties, credit rating agencies, trade repositories, institutional for occupational retirement provisions (IORPs i.e. pension funds) and insurance distributors are not classified as FSEs.

Article 21c CRD VI introduces a general prohibition on the direct provision of “core banking services”—namely deposit-taking Which includes “taking deposits and other repayable funds”.Show Footnote, lending Which includes “consumer credit, credit agreements relating to immovable property, factoring, with or without recourse, financing of commercial transactions (including forfeiting)”Show Footnote and guarantees/commitments—by TCUs into the EU, unless the TCU establishes an authorised (i) EU incoming third country branch (TCB) or (ii) subsidiary in the relevant EU Member State. To put it differently, Article 21c CRD VI clarifies the general prohibition of direct provision of core banking services into the EU directly from third countries - i.e. without a branch or a subsidiary in the EU. This is a significant shift towards a harmonised, explicit authorisation requirement for third country banking services, aiming to ensure regulatory oversight and financial stability within the EU.

Importantly the Article 21c CRD VI regime includes several exemptions and carve outs, notably:

• Reverse solicitation: Where the service is provided at the exclusive initiative of the EU client or counterparty, the TCU is not required to establish a TCB. This exemption is strictly construed: any form of solicitation or intermediation by the TCU or its affiliates negates the exemption.
• Provision to credit institutions: TCUs may provide core banking services directly to EU credit institutions without a TCB
• Intra-group services: Services provided to undertakings within the same group as the TCU are exempt.
• MiFID carve out: Investment and ancillary services under MiFID II (Annex I, Sections A and B) provided by third country investment firms are not affected by the CRD VI regime. Appropriate MiFID II rules (and exemptions), including on permitted reserve solicitation continue to apply to such MiFID II activity.
• Grandfathering/“Acquired Rights”: Existing contracts entered into before 11 July 2026 are protected to facilitate transition, but this is narrowly framed to prevent circumvention.

The EBA’s mandate was to assess whether the CRD VI exemption from the branch requirement should be extended to other EU FSEs, including investment firms, asset managers, insurance and reinsurance undertakings, payment and e-money institutions and certain crypto-asset service providers.

This Client Alert summarises the key findings, regulatory context and implications for market participants flowing from the Report. The Report will be expected to be followed by national competent authorities (NCAs) across all EU Member States, including those within and those outside of the EU’s Banking Union, but it is conceivable that the European Central Bank (ECB), acting in its role at the head of the Banking Union’s Single Supervisory Mechanism (SSM) may publish its own further expectations.

Key takeaways from the Report

In its assessment, the EBA does not recommend that the European Commission (currently) pursue a legislative proposal to broaden the current exemptions under CRD VI, which are presently limited to (i) interbank and intragroup transactions as well as (ii) reverse solicitation. The EBA cites several reasons for this position, including insufficient data regarding the significance of services provided by TCUs and the uncertain impact of introducing further exemptions. The EBA’s analysis reveals that the direct provision of core banking services from third countries to EU FSEs is limited and concentrated in specific Member States (notably Ireland and Luxembourg) and sectors (such as money market funds, alternative investment funds and investment firms).

The data shows in terms of market analysis that:

• Money Market Funds (MMFs): Only MMFs in a handful of Member States (Ireland, Luxembourg, France, Greece, Lithuania) report material deposit exposures to TCUs, often linked to foreign currency operations and global custody arrangements.
• Alternative Investment Funds (AIFs): Cash exposures to TCUs are generally low and concentrated in a few jurisdictions, often related to non-EU currency operations.
• Investment Firms: Deposits with TCUs are a small proportion of total deposits, with some concentration in certain countries (Malta, Ireland, Estonia, Netherlands, Germany).
• Insurance and Reinsurance Companies: Significant risk exposures to third countries are limited and concentrated in a few Member States (Malta, Ireland, Netherlands, Germany, Luxembourg, Sweden, France).

As the most tangible next step, the EBA suggests providing further guidance through its Q&A tools to support supervisory authorities in clarifying the application of the Article 21c CRD VI regime, particularly in relation to the interaction with other existing sectoral legislation – including but not limited to the types of entities above. 

Such guidance would address scenarios in which asset managers or funds may access core banking services—such as placing deposits, opening cash accounts, or delegating safekeeping to sub-custodians—particularly where there is ambiguity about the interaction between Article 21c CRD VI and existing frameworks like the AIFMD, UCITS Directive and the MMF Regulation. This is especially relevant in cases where these frameworks already permit placing deposits with third-country banks or delegating safekeeping to sub-custodians. The Report also examines concerns that credit institutions might have an unfair advantage over other FSEs by having easier access to third country services but finds no substantial evidence to warrant regulatory changes.

Data limitations and methodology

The EBA’s analysis underpinning the findings presented in the Report was, by admission, constrained by the limited availability and granularity of supervisory data, particularly outside the banking sector. Data was available for certain asset managers (money market funds (MMFs) and alternative investment funds (AIFs)), investment firms (Class 2) and insurance/reinsurance companies, but not for UCITS (except MMFs), non-bank payment service providers, or e-money institutions. The EBA supplemented quantitative analysis with qualitative input from industry stakeholders.

Based on what the EBA has collected, the Report found that:

With respect to the use of core banking Services by EU FSEs:

• Deposit-taking: Cash exposures to TCUs by EU FSEs are generally low in both absolute and relative terms at the EU level, with concentrations in a small number of Member States (notably Ireland and Luxembourg). For MMFs and AIFs, exposures to third country banks are often linked to foreign currency operations or delegation of depositary functions.
• Lending: Data on cross-border lending by TCUs to EU FSEs is limited. Where available (AIFs, insurance/reinsurance), the volumes are not material at the EU level and are concentrated in a few jurisdictions.
• Guarantees and Commitments: Quantitative and anecdotal evidence suggests very limited use of guarantees and commitments from TCUs by EU FSEs.

Concerning stakeholder feedback and market impact:

• Cost and operational impact: Some stakeholders highlighted potential increases in costs and operational complexity, particularly for non-bank payment service providers (e.g., in USD payment clearing) and for asset managers/funds needing to adapt to new requirements. However, the EBA found these impacts to be limited and largely anecdotal.
• Competitiveness and level playing field: Concerns were raised regarding potential unlevel playing fields between credit institutions (which retain access to direct TCU services) and other FSEs. The EBA notes that the existing exemptions and carve outs provide flexibility for most business needs.
• Custody and sub-custodian arrangements: Both non-EU global custodians and EU asset managers flagged potential disruption to existing custody chains, especially where deposit-taking or overdraft facilities are ancillary to custody services.
• Insurance sector: Large cross-border insurance groups noted potential impacts on treasury and liquidity management, but some acknowledged that most international banks already have EU subsidiaries or branches.
• Financial stability: No material financial stability risks were identified in relation to the prohibition or the requirement to establish a TCB.

Key concerns

Even if the EBA’s analysis drew on quantitative supervisory data (without ad-hoc data collection) as well as anecdotal qualitative information the Report identified several key concerns:

• Increased costs and delays for non-bank payment service providers (PSPs) and investment firms when handling foreign currency transactions, due to the need to involve TCBs or EU affiliates in payment chains.
• The EBA concludes that the evidence does not justify an exemption at this time, noting that FSEs retain the flexibility to use services directly from TCUs or through existing EU intermediaries. The EBA does, however, recommend ongoing monitoring of this issue. In particular, the EBA concludes that:
  • based on current quantitative and qualitative evidence, there is no clear case for extending the exemption from the branch requirement to EU FSEs beyond credit institutions.
  • the (current) combination of existing exemptions (reverse solicitation, intra-group, MiFID carve out) and transitional arrangements is considered sufficient to address the operational needs of EU FSEs.
  • the actual impact on EU FSEs is limited and that most core banking services can be provided by EU-based institutions or TCBs of international banking groups.
• Uncertainty regarding the exemption of MiFID investment services from branch requirements when core banking services are linked to custody and safekeeping and whether bundled services fall under the MiFID carveout or require stricter compliance
• The EBA finds that some flexibility is already present and sees no compelling reason to expand it. The Article 21c exemption applies only when core banking services are not otherwise regulated under MiFID.
• Impact on custody services provided by non-EU global custodians, including through sub-custodian arrangements.
• The EBA notes that only 20% of the market is held by third country EU subsidiaries. TCUs can already utilise EU institutions or TCBs to provide core banking services from within the EU to support custody operations.

Reverse solicitation in light of the Report 

To recap under EU law:

• Reverse solicitation is the concept that, if a (prospective) client in Country A on their own initiative approaches a financial institution based in Country B, the financial institution does not need to obtain a licence or authorisation from Country B's authorities to provide financial services to that customer. This concept is recognised in EU sectoral legislation as well. The concept applies to an intra-EEA situation where Country A and Country B are both EEA Member States. The concept also applies to a third country situation where Country A is an EEA Member State and Country B is a third-country.
• Reverse solicitation to provide cross-border services from a third country to the EEA without a licence is problematic since EEA Member States interpret it differently. Member States’ NCAs have varied views on how much marketing a financial institution can do and how long it can continue to serve clients.
• TCUs who want to rely on reverse solicitation need to determine whether their activities fall within that state’s interpretation of reverse solicitation or otherwise risk breaching that state’s regulatory perimeter.

The Report aims to “clarify” the scope and application of reverse solicitation as an exemption to the Art. 21c CRD VI requirement, by stating what does not fall within permitted reverse solicitation. Accordingly, if a TCU “actively markets to EU clients, uses intermediaries to indirectly promote its services, or offers additional services not initially requested by the client, the exemption does not apply.” 

In this context, an “intermediary” is any entity or person that (i) acts on behalf of the TCU or (ii) has close links with the TCU and is involved in the solicitation of the EU client or counterparty. This includes (a) entities acting on their own behalf but in the interest of the TCU; (b) entities with "close links" to the TCU (such as group companies or affiliates); and/or (c) any other person acting on behalf of the TCU (such as agents, representatives, or other intermediaries).

Importantly, the reverse solicitation exemption under Article 21c(2) of CRDVI is considered to be strictly construed due to the explicit limitations and anti-circumvention measures embedded in CRD VI’s legislative text and its interpretation by the EBA. The exemption allows a TCU to provide core banking services directly from a third country to an EU FSE only when the service is provided at the exclusive initiative of the EU client or counterparty. This means:

• No active solicitation: The exemption is lost if the TCU, or any entity acting on its behalf, solicits, markets to or promotes its services to an EU client or counterparty. This includes direct marketing, indirect approaches, or any form of communication intended to encourage the client to request the service.
• No intermediation or close links: The exemption does not apply if the solicitation is made through an entity acting on behalf of the TCU, or with close links to the TCU, or through any other person acting on its behalf. This is designed to prevent circumvention by using affiliates, intermediaries, or related parties to approach EU clients.
• Scope limited to solicited services: The exemption only covers the specific categories of products, activities, or services that the client or counterparty has solicited. However, it does extend to any services, activities, or products necessary for, or closely related to, the originally solicited service, including those provided subsequently, but not to unrelated or new services.
• No “Chaperoning” or “Umbrella” Use: The exemption cannot be used as a blanket permission for ongoing or future business. Each instance of reverse solicitation must be assessed on its own merits and circumstances.

The issues above are not new. They are however due to the Report, a further narrowing of supervisory principles and expectations that have been consistently communicated since 2017 as an answer to Brexit and since 2022 in light of more tech-powered distribution models by each of the EBA, ESMA, EIOPA, the ECB-SSM and a host of NCAs where reverse solicitation, chaperoning and umbrella usage should be seen to be more the exception rather than the rule of how to conduct business from a third country into the EEA. Accordingly, the interplay of “permitted” reverse solicitation with the scope of Art. 21c CRD VI’s requirements may require a review by TCU’s of their market access strategies using EEA based introducers and/or fronting entity relationships.

Given the strict interpretation and the risk of regulatory challenge, robust documentation is essential for any firm seeking to rely on “permitted” reserve solicitation as well as an exemption to Art. 21c  CRD VI’s requirements. The following documentation and procedures are recommended in addition to a formal “Market Access and Permitted Reverse Solicitation Policy”:

• Client-initiated request evidence: Firms should retain clear, dated records demonstrating that the initial approach for the service came from the EU client or counterparty, without any prior solicitation or marketing by the TCU or its affiliates. This could include written requests, emails, or other communications initiated by the client.
• No solicitation confirmation: Internal records should confirm that no marketing, promotional activity, or solicitation was undertaken by the TCU, its affiliates, or any third party acting on its behalf in relation to the client or the specific service requested by the EU client.
• Service scope documentation: The firm should, with legal counsel, document the specific services, products, or activities requested by the  EU client and ensure that any subsequent services provided are strictly closely related to the original request, as permitted by Article 21c(3) CRD VI.
• Ongoing monitoring: Firms should implement procedures to monitor ongoing client relationships to ensure that any new or additional services provided under the exemption remain within the scope of the original client-initiated request or are otherwise separately documented as reverse solicitation.
• Internal policies and training: Firms should have clear internal policies and staff training on the limits of reverse solicitation, including procedures for identifying, documenting and approving such requests.
• Audit trail: All relevant communications, client requests, internal assessments and compliance checks should be retained and readily accessible for supervisory review.

The reverse solicitation exemption is narrowly framed to prevent circumvention of Art. 21c CRD VI and is subject to strict regulatory scrutiny. Firms must be able to demonstrate, with clear and contemporaneous documentation, that the client relationship and the provision of services genuinely originated from the exclusive initiative of the EU client and that no prohibited solicitation or intermediation occurred. Failure to maintain such documentation could result in regulatory challenge and enforcement action.  

Strategic and operational implications for regulated firms in light of the Report

EU FSEs (other than credit institutions) seeking to receive core banking services from TCUs will, as a rule, need to ensure that the TCU has a TCB or subsidiary permitted to act in the relevant Member State. This will require a review of existing and planned cross-border arrangements, particularly for treasury, liquidity and custody operations.

Firms must carefully assess whether their activities fall within the scope of the available exemptions discussed above. In particular, intra-group arrangements should be reviewed to ensure compliance with group definitions and structures. Firms must also consider the following operational implications (along with tax and transfer pricing considerations – not discussed herein):

• Contractual and operational adjustments: To existing contracts with TCUs for core banking services should be reviewed for compliance with the new regime. Where necessary, contracts may need to be novated to an EU entity or TCB and/or restructured to fit within an exemption. This is particularly relevant for lending arrangements, deposit-taking and guarantees. Asset managers and funds, for example, will need to adapt their cash borrowing contracts to reflect the new counterparty structure. Firms must ensure that all new and amended contracts clearly reflect compliance with the new regime, including the identity of the EU-based service provider and the scope of services. This may require extensive legal review and updates to standard documentation.
• Transition of Acquired Rights: While Article 21c(5) provides for the preservation of “Acquired Rights” under contracts entered into before 11 July 2026, this safeguard is narrowly framed and intended only to facilitate the transition. NCAs may also, as discussed below, have diverging views on whether and what may qualify as an Acquired Right. Firms must carefully assess which contracts/services and products are covered and plan for the eventual migration of services/products and solutions.
• Client communication and consent: Clients may need to be notified of changes to service providers or contractual terms and in some cases, their consent may be required. This can be particularly complex for example for funds with a large and diverse investor base or for insurance groups with cross-border operations.
• Cost and competitiveness considerations: While the EBA found no clear evidence of material cost or competitiveness impacts at this stage, firms should anticipate potential increases in operational costs, delays and complexity, especially for cross-currency payment and custody chains particularly for services such as payment clearing in foreign currencies (e.g., USD). Non-bank PSPs and investment firms have highlighted concerns about increased costs and potential inefficiencies. Ongoing monitoring and engagement with regulators is advisable.
• Strategic review of business models: Firms with significant reliance on third country banking services should undertake a strategic review of their business models, considering the need for moving to operations with an EEA presence, potential restructuring of treasury and custody operations and the feasibility of alternative providers within the EU. This may require significant changes to internal processes, IT systems and reporting lines for EU FSEs.

In light of the above, all firms should monitor regulatory Q&A and guidance for further clarification, especially regarding the eligibility of third country banks for deposit and custody functions but also take note of further sector-specific considerations.

• Sector-specific considerations:
  • Differential treatment: Credit institutions remain able to receive core banking services directly from third countries, while other FSEs do not, raising concerns about an unlevel playing field for firms carrying out similar (economic) activities but not, at an entity level being authorised as a credit institution. See however proposals from the ESRB discussed here on a move from entity-based to activity-based rulemaking and supervision.Show Footnote
  • Asset managers and funds: The ability to place deposits or open cash accounts with third country banks is often integral to fund operations, especially for MMFs and AIFs operating in foreign currencies. The new regime may restrict these practices unless the third country bank has an EU presence, potentially impacting liquidity management and investment strategies.
  • Insurance and reinsurance companies: Large cross-border insurance groups may face challenges in centralising treasury and liquidity operations if they can no longer rely on group entities or international banks outside the EU for core banking services. Intra-group loan agreements with non-EU entities may need to be restructured to comply with the new requirements.
  • Payment and e-money institutions: Non-bank PSPs may experience increased complexity and costs in clearing payments in foreign currencies, as they may be required to route transactions through an EU intermediary, potentially affecting speed and efficiency.

These sectoral specific considerations are important as the new CRD VI regime does not always clearly address how it interacts with sectoral rules that explicitly allow certain cross-border banking relationships.

Residual supervisory and legal uncertainty with sectoral legislation 

While the EBA has signalled in the Report that it will effectively “kick the can on uncertainty down the road” and instead use its supervisory tools of Q&As to “further clarify” (i) the CRD VI regime, (ii) the principles presented in its Report and (iii) how it interplays with existing (and indeed possibly future) legislation, a Q&A tool does not enjoy the full force of law nor does it oblige NCAs to always follow it. It also does not guarantee that NCAs will not have divergent interpretations of the “clarity” provided in the Q&A.   

In any event, many sectoral regulations—such as the Alternative Investment Fund Managers Directive (AIFMD), the Undertakings for Collective Investment in Transferable Securities Directive (UCITS) and the Money Market Funds Regulation (MMF Regulation)—explicitly permit or even require certain cross-border banking relationships with third country banks under defined conditions.

This creates a complex regulatory landscape where the requirements of CRD VI may not be fully harmonised with sectoral rules, leading to uncertainty for regulated firms about which regime prevails in specific circumstances. For example, while CRD VI may require the establishment of an EU branch for the provision of core banking services, sectoral rules may allow funds to place deposits or open cash accounts with third country banks, provided those banks meet certain prudential standards. It should be noted that presently the precise boundaries and interaction of these exemptions with sectoral regulations are not always clear:

MiFID II carve-out: Article 21c(4) and 47(2) CRD VI exclude investment services and related ancillary services under MiFID II (as supplemented by IFR/IFD) from the new regime. Yet, there is uncertainty about whether core banking services that are connected to, but not strictly ancillary to, MiFID-type services (such as deposit-taking linked to custody as well as certain margin lending transactions/portfolio monetisation transactions in traditional as well as crypto-asset financial instruments that are not covered by the EU’s SFTR) are covered by this carve-out. The EBA notes a lack of clarity, especially when custody services are provided on a standalone basis rather than as an ancillary service. Specifically, absent further clarity, this includes 1. Ambiguity in coverage: The carve-out specifically mentions investment and ancillary services under MiFID II but does not clearly define the extent to which core banking services (taking deposits, lending, guarantees/commitments) are exempt when they are connected to these services. This creates uncertainty about whether all core banking services provided in conjunction with MiFID services are exempt or only specific types. and 2. Standalone vs. ancillary services: There is uncertainty regarding whether core banking services provided on a standalone basis (e.g., deposit-taking or lending not directly tied to an investment service) are covered by the carve-out. The carve-out appears to apply only when these services are ancillary to MiFID II investment services, leaving ambiguity about standalone core banking services.Show Footnote

• Sectoral permissions vs. CRD VI prohibitions: Provisions in the AIFMD, UCITS Directive and MMF Regulation allow for the opening of cash accounts or placing of deposits with third country banks under certain conditions. CRDVI, however, may prohibit such arrangements unless the third country bank has an EU presence, unless an exemption applies. The Report highlights that Article 21c CRDVI does not expressly address how it interacts with these sectoral provisions, leaving firms and supervisors uncertain about the permissibility of certain cross-border relationships.
• Supervisory data and reporting gaps: The lack of harmonised definitions and reporting requirements across CRD VI and sectoral regulations further complicates supervision. For example, supervisory data is often risk-based and does not always map directly to the activities or services captured by CRD VI. This makes it difficult for both firms and supervisors to determine whether specific arrangements fall within the scope of the new requirements or are covered by sectoral exemptions.
• Transition and Acquired Rights: As explained above, the Acquired Rights safeguard is narrowly framed and intended only to facilitate the transition. Sectoral regulations may not contain equivalent transition provisions, creating uncertainty about the treatment of legacy contracts and the need for renegotiation or restructuring.

Worryingly, if NCAs interpret the interaction between CRD VI and sectoral rules inconsistently, the most immediate consequence is increased uncertainty and an unhelpful “unlevelling” of the playing field – i.e. very contrary to what EU sectoral legislation, let alone CRD VI is trying to achieve. This could result in arbitrage as well as obstacles to cross-border activity and thus increases in inadvertent breaches as well as wider legal and compliance risks.

Outlook 

The European Commission is expected to consider the Report’s findings, the EBA’s efforts in Q&A in any future legislative proposals – when that might happen is presently too early to tell. In the interim, EU FSEs should review their reliance on third country banking services and assess the need for adjustments to their operational models in light of the new requirements under CRD VI.

Ultimately the CRD VI regime introduces significant compliance, operational and contractual challenges for regulated firms, particularly those with complex cross-border operations or reliance on non-EU banking partners. The regime will have a number of impacts on institutional relationships and products as well as those with retail clients and well beyond banking sectoral legislation in CRR III/CRD VI.

Given the above, firms should also monitor further guidance and clarifications from EU authorities regarding the interaction of Article 21c CRD VI with other sectoral frameworks. While the EBA, has for now, concluded the European Commission should not pursue legislative action – it remains to be seen whether it will feel bound by that recommendation in the immediate if not longer term. The same applies to the ECB-SSM perhaps expressing its own views in a bid to clarify the CRD VI and the Report’s expectations in a Banking Union context.

In any event, both TCUs and EU FSEs should proactively assess their exposure to the new requirements, engage with counterparties and regulators and prepare for potential changes in market practice and supervisory expectations as the regime is implemented and further clarified. Ongoing monitoring of regulatory developments, especially regarding the interaction with sectoral rules and the practical application of exemptions, will be essential for compliance and business continuity.  

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