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ARTICLE · 26 JUNE 2025

Fund Financing: EU Branch Requirements

Maples Group
Maples Group
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For new lending arrangements entered into by an EU-domiciled fund after 11 July 2026 with a non-EU lender, that lender will need to have an authorised branch...

IrelandFinance and Banking

Background

The Capital Requirements Directive VI1 ("CRD VI") introduces new EU branch requirements for lenders. In this client note, we will consider the impact of these branch requirements for third country lenders and the European fund financing space.

The transposition deadline for CRD VI for Member States is 10 January 2026. For further information on the implementation of CRD VI in Ireland, please review our previous client note from January 20252.

The Branch Requirement

The new Article 21c, introduced by CRD VI, requires that non-EU undertakings wishing to provide "core banking services" (deposit-taking, lending, and guarantee services) in a Member State must establish a branch in that Member State. They must also obtain authorisation in accordance with EU law, unless they provide such services through a subsidiary.

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