By: David Molloy, Imelda Shiels, Kevin Lynch
From 11 January 2027, non-EU banks and significant investment firms must establish licensed branches in each EU Member State where they provide core banking services, or operate through authorized EU entities. Ireland has implemented CRD VI's Article 21c requirements through faithful transposition, introducing a third-country branch regime that affects cross-border lending involving Irish companies, with important exemptions including reverse solicitation that may enable continued market participation.













