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07 October 2025
On 22 August 2025, the German legislator published the "German Draft Implementation Act" (BRUBEG) of the Banking Directive (EU) 2024/1619 ("CRD6").
This marks an important, substantial step towards a new harmonized and more restrictive regime for branches of non-EU/EEA firms, e.g., from the US, UK and Asia, which provide "core banking services" of deposit-taking, lending, and providing guarantees and commitments to German clients, so-called third-country branches ("TCB") under Art. 21c CRD6. The new regime will have a significant impact on business models, including new requirements on governance, booking, risk management and reporting.
This briefing summarizes the key provisions of the German Draft Implementation Act and their implications for non-EU/EEA firms. For a general overview of the TCB regime, see our Client Briefing The New EU Third Country Branch Framework: What Firms Need to Know published in November 2024.