In our previous publication on the Capital Requirements (Implementation) Act 2026 (Implementatiewet kapitaalvereisten 2026, the Implementation Act (Dutch only)), we discussed the key features of the new branch regime for non-EU banks introduced under the Capital Requirements Directive VI (Directive (EU) 2024/1619, CRD 6). With 11 July 2026 fast approaching, an important turning point is drawing near: agreements relating to ‘Core Banking Services’ concluded after 11 July 2026 will no longer be protected by the transitional law. This means that non-EU banks entering into new agreements with Dutch companies after that date for the provision of Core Banking Services – namely taking deposits, granting loans or issuing guarantees – will immediately fall within the scope of the new branch regime, including the associated establishment and authorisation requirements. For further information on this topic, please refer to our previous publication. For companies in the Netherlands, this means that the contracting party, the financing structure and the timing of any new credit documentation will once again become relevant when assessing the applicability of CRD 6.
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