Article

Third-country bank and non-bank lending into the EU post-CRD VI

Third-country bank and non-bank lending into the EU post-CRD VI
Published Date
Jan 14 2026
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For non-European banks, the lack of regulatory harmonisation across EU member states makes cross-border lending into the EU complex, with several member states (including France and Italy) prohibiting direct lending.

The implementation of the CRD VI third-country branch (TCB) licensing requirement on January 11, 2027 will further constrain direct lending into those other member states which have historically permitted direct lending.

This bulletin explores the possible use of non-bank lending entities and funds as a means of conducting lending activities with corporate borrowers in certain EU jurisdictions and the implications of the new loan origination requirements for funds under AIFMD II in this context.

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