CRD VI: Quick guide to Member State activity

On 27 October 2021, the European Commission adopted a Banking Package which set out proposed amendments to EU banking rules contained in the Capital Requirements Regulation and the Capital Requirements Directive IV. The main purpose of the amendments was to implement the outstanding elements of the Basel III reforms in the EU, while taking account of EU specificities. However, the reforms also introduce important new changes to the rules for third country bank branches operating in the EU (third country branches). This includes the requirement in certain instances to establish a subsidiary. Further information can be found in our briefing note CRD VI: Third country branches and subsidiaries.

In the table below we set out the latest communications from certain Member State regulators regarding their implementation of the CRD VI together with any recent updates from the European Commission and European Supervisory Authorities. We also set out the latest communications from the UK as regards its implementation of the Basel III reforms.

The table will be updated from time to time.

Member StateLatest developments on domestic implementationNRF contact (unless otherwise stated) 
GermanyOn 22 August 2025, the German Ministry of Finance (Bundesministerium der Finanzen – BMF) published its draft bill for the implementation of Directive 2024/1619 (CRD VI) into German national law. The bill is entitled CRD VI Implementing and Bureaucracy Reduction Act (Bankenrichtlinienumsetzungs- und Bürokratieentlastungsgesetz – BRUBEG).
 
With its draft bill, the BMF intends to implement the European directive on a “one-to-one” basis (no “goldplating”) and to reduce excessive bureaucracy in the German banking sector. In line with CRD VI, the BRUBEG addresses aspects such as the outstanding elements of the Basel III reforms and introduces amendments in connection with supervisory powers, sanctions and environmental, social and governance risks.

Following a consultation process, the governmental draft of the BRUBEG, was published on 10 October 2025 and submitted to the German Bundesrat for consultation.
 
For further information please refer to our blog.
 
Last update: 10 October 2025		Michael Born  
LuxembourgThe formal process of implementation of CRD VI began on 6 October 2025 with the publication of the bill of law n°8627 (Bill) and its submission to Parliament.
 
The next step is the official introduction of the Bill to the Parliament; it is scheduled on 24 October 2025.
 
Last update: 6 October 2025		Dorothee Ciolino
FranceLaw No. 2025‑391 of 30 April 2025 on various provisions adapting EU law in economic, financial, environmental, energy, transport, health, and free movement matters, referred to as the “DDADUE 5 Act,” has empowered the French Government to transpose the Directive within a one-year period. Accordingly, by 30 April 2026 at the latest, substantial amendments will be inserted into the French Monetary and Financial Code in order to implement new measures. 

Last update: 1 August 2025		Sebastien Praicheux
Poland  In Poland, the government plans to adopt draft laws implementing the CRD VI in Q3 2025.   The information has been published in the list of legislative or programme works of the Council of Ministers.  

Last update: 1 August 2025		Agnieszka Braciszewska
Italy  On 8 October 2025, the Government issued a press release regarding the implementation of the CRD VI / CRR III package stating that a draft legislative decree has been submitted by the Government to the Parliament (specifically, the Deputies’ Chamber) for review and approval.
 
At the time of writing no precise timeline has been specified but considering the Government’s sound majority in Parliament and the technical nature of the decrees, the process may not be too long. Following approval by the Deputies’ Chamber, the same text then needs to be approved by the Senate.
 
Last update: 8 October 2025		Maria Gilesi
Netherlands  On 14 October 2025, the Dutch Ministry of Finance submitted a revised draft of the Implementation Act Capital Requirements 2026 (Implementatiewet kapitaalvereisten 2026, the CRD VI Implementation Act) to the Council of State (Raad van State). This latest version introduces a key addition not included in the consultation draft (which was published in April 2025): the implementation of Article 21c(5) CRD VI on existing contracts of third-country firms.

In the explanatory memorandum, the legislator confirms that the Netherlands will apply a phasing-out regime rather than a grandfathering regime. Under this approach:
contracts entered into before 11 July 2026 may continue;
amendments, renewals or extensions of those contracts will, in principle, trigger the
requirement to establish a branch and apply for authorisation; and
novation, term changes and netting are expressly excluded from the permitted scope.

This means that the continuity of pre-existing contractual relationships is in principle preserved only in their original form.

Article 21c CRD VI introduces new limitations on the provision of banking and investment services in the EU by third-country firms on a cross-border basis. The clarification on contract treatment is of particular relevance to firms currently operating into the Netherlands without a local branch, including those relying on reverse solicitation.
The draft Act is now before the Council of State for advisory opinion. Following this stage, it will proceed to parliamentary consideration. The implementation deadline at EU level for CRD VI remains July 2026.

Further legislative guidance may be published during the parliamentary process regarding contract management and supervisory expectations under the phasing-out regime.
 
Last update: 14 October 2025		Nikolai de Koning








FinlandIn Finland, the implementation of the CRD VI is ongoing.

On 26 May 2025, the working group of the Finnish Ministry of Finance, tasked with preparing a proposal for the implementation of the CRD VI, submitted its report (containing a draft government bill) for public consultation.

Amendments based on the CRD VI that address certain organizational issues of supervisory authorities and matters of civil service law were excluded from the working group’s mandate and will instead be prepared separately by the Ministry of Finance as part of official work.

The consultation round for the proposed amendments concluded on 16 July 2025, with the final government proposal currently expected to be presented to the Finnish Parliament later this year (week 51).

The amending legislation has been proposed to take effect from the beginning of 2026.

Last update: 18 November 2025		Helena Viita
 
Miia-Mari Kasi
 
Roschier
Kasarmikatu 21 A
FI-00130 Helsinki
 
European Commission and European Supervisory AuthoritiesOn 3 November 2025, the EBA published a consultation paper on draft guidelines relating to the authorisation of third-country branches under CRD IV, as amended by the CRD VI. The deadline for responses is 8 December 2025. The EBA intends for the guidelines to apply from 11 January 2027.
 
On 5 November 2025, the EBA published a final report on guidelines on environmental scenario analysis under CRD IV, as amended by CRD VI.
 
On 5 December 2025, the EBA issued a consultation on draft Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) concerning material acquisitions, material transfers of assets or liabilities, and mergers and divisions involving credit institutions or (mixed) financial holding companies under the CRD IV.
 
Last update: 5 December 2025		Flupke van den Bogart
Non-Member State  
United KingdomSince our last update:
 
On 30 July 2025, the Prudential Regulation Authority (PRA) updated its webpage on Consultation Paper 12/25 – Pillar 2A review – Phase 1 (CP12/25). The update provides that the PRA has extended the deadline for responses to CP12/25 from 5 September 2025 to 30 September 2025. It has also extended the implementation date for the changes to pension obligation risk and market risk and counterparty credit risk from 2 March 2026 to 1 July 2026.  The implementation date for the remaining proposals in CP12/25 concerning credit risk (Chapter 2) and operational risk (Chapter 3) continue to be aligned with the date of the PRA’s implementation of the Basel 3.1 standards (1 January 2027), as initially proposed. See our blog here.
 
On 30 July 2025, the PRA published Consultation Paper 19/25 – CRR Definitions: restatement in PRA Rulebook (CP19/25). Articles 4, 4a, 4b, and 5 of the UK Capital Requirements Regulation (UK CRR) set out the definitions for key terms used in the UK CRR relating to the requirements which apply to credit institutions and designated investment firms. In CP19/25 the PRA sets out proposed PRA Rulebook Glossary definitions that would replace definitions in Articles 4, 4A, 4B, and 5 of the UK CRR. The deadline for comments on CP19/25 is 30 October 2025. The PRA proposes that changes resulting from CP19/25 would become effective alongside the Basel 3.1 package, expected to be 1 January 2027. See our blog here.
 
On 15 July 2025, HMT published a 2025 Policy Update to the September 2024 Policy Paper ‘Applying the FSMA 2000 model of regulation to the Capital Requirements Regulation’.  The document provides an update on HM Treasury’s plans to commence the revocation of certain provisions of the UK CRR, as well as making the necessary restatements of the UK CRR in UK legislation where required by the FSMA model. It also explains how the PRA will replace UK CRR provisions with regulator rules, supervisory statements, and statements of policy. See our blog here.
 
On 15 July 2025, the PRA published Consultation Paper 17/25 – Basel 3.1: Adjustments to the market risk framework (CP17/25). The Basel 3.1 standards introduce a comprehensive set of amendments to the market risk framework, known as the Fundamental Review of the Trading Book (FRTB). In CP17/25 the PRA proposes to delay the implementation of the new FRTB internal model approach (FRTB-IMA) for another year, until 1 January 2028. See our blog here.
 
On 3 July 2025, the PRA published Policy Statement 8/25 – Updates to the UK policy framework for capital buffers (PS8/25). See our blog here.

Last update: 1 August 2025		Jonathan Herbst