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VIDEO · 26 JUNE 2026

CRD VI: Questions And Answers (Podcast)

Arthur Cox
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Partners Sarah Thompson and Rob Cain examine Article 21c of CRD IV as amended by CRD VI, exploring how new restrictions on third-country institutions providing core banking services into the EU will reshape cross-border operations. The discussion addresses implementation uncertainties, grandfathering deadlines, and strategic considerations for financial institutions navigating the January 2027 compliance horizon.

IrelandFinance and Banking
Sarah Thompson
Sarah Thompson
Robert Cain
Robert Cain
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In this episode of our podcast, Sarah Thompson and Rob Cain, Partners in our Financial Regulation Group, break down the major current talking points on Article 21c of CRD IV as amended by CRD VI, which will restrict third‑country institutions providing core banking services into the EU from January 2027. They discuss the current uncertainty around Irish implementation, the impact of the July 2026 grandfathering cut-off, and the practical steps firms are already taking to reassess booking models, decision‑making structures and cross‑border service delivery.

Podcast transcription

Sarah Thompson

Hello and welcome to the Arthur Cox Financial Regulation Podcast. Today we’re going to be talking about one of the most significant developments for institutions providing financial services into the EU, Article 21c. So Article 21c of CRD IV, as amended by CRD VI, introduces a general prohibition on third-country financial institutions providing core banking services into the EU. Those

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