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ARTICLE · 05 FEBRUARY 2025

CRD VI And Third Country-Branches – Irish Transposition In Focus

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The Irish Department of Finance has published a consultation on national discretions regarding Ireland's implementation of the Capital Requirements Directive VI...

IrelandFinance and Banking
Callaghan Kennedy
Callaghan Kennedy
Lorna Smith
Lorna Smith
Stephen Carty
Stephen Carty
Philip Keegan
Philip Keegan
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What You Need to Know

  • The Irish Department of Finance has published a consultation on national discretions regarding Ireland's implementation of the Capital Requirements Directive VI ("CRD VI")1
  • A key issue is whether branches established by third-country firms under CRD VI ("Third-Country Branches") will be subjected to full credit institution requirements.

Consultation

On 16 January 2025, the Irish Department of Finance published a consultation paper2 on national discretions regarding the implementation of CRD VI (the "Consultation"). The consultation period runs until 14 February 2025.

The Consultation sets out seven questions. The primary question, which will be in focus for stakeholders and third country banks currently operating within the EU, is whether Ireland should apply i) the full regime applicable to a CRD credit institution to these Third-Country Branches, or to a sub-set of them (and if so, what criteria should be used), or ii) the

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