CRD VI Consequences For M&A Transactions

CRD VI (Directive (EU) 2024/1619) introduces a new harmonized regime requiring banks to notify competent authorities of, and in some cases receive prior approval for, M&A transactions generally. This expands on the current regime, which relates solely to qualifying holdings in credit institutions, although some EU member states had previously already implemented similar rules on a national level. CRD VI should have been transposed by member states by January 10, 2026 and the M&A provisions should apply from January 11, 2026.

In practice, the majority of member states are yet to publish their final implementing legislation, with only a small number having fully transposed CRD VI so far. The new M&A regime will therefore initially apply in a piecemeal way across the EU. However, firms should be ready to comply with their upcoming obligations when contemplating transactions from 2026 onwards.