The European CRD VI directive takes effect on January 11, 2027, requiring non-EU banking institutions to open an authorized branch on European soil to take deposits, grant credit, or issue guarantees to clients located in the EU. Article 21c of this directive includes a grandfather clause protecting contracts concluded before July 11, 2026, which may be executed without a branch after the deadline. The European Banking Authority has warned against abusive use of the reverse solicitation exception, which is strictly controlled and cannot serve as a disguised market access strategy. The case of Payward, Kraken’s parent company, illustrates the growing interest of crypto players in obtaining European banking status beyond the MiCA license the platform already holds in Ireland. Brussels aims to clarify, by the end of 2027, who can legally access European citizens’ savings and credit.
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