On 15 February 2022, the International Regulatory Strategy Group (IRSG) issued a narrative containing its observations on the European Commission’s proposed new harmonised rules for third country providers of banking services carrying out cross-border business into the EU or via EU branches (CRD 6). In summary, the IRSG believes that the proposals represent a major change to existing regimes and would prevent the cross-border provision of banking services from a third country firm into the EU where this is not done either via a third country branch in the EU, or via reverse solicitation. Given the issues associated with reverse solicitation, the proposals effectively result in a new authorisation requirement.