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.

This note follows on from our briefing on the new requirements under CRD VI for EU branches of non-EU banks and examines the EBA’s proposals in relation to: i) draft regulatory technical standards (RTS) on how TCBs should manage their booking arrangements (the “booking RTS”); and (ii) draft guidelines on the types of “other financial instruments” – beyond cash and government securities – that TCBs may use to meet capital endowment requirements (the “endowment guidelines”).

The EBA also published draft RTS on cooperation mechanisms and the conditions for the functioning of supervisory colleges, which we do not consider in this note.