CRD VI and Georgian Bank Accounts: What EU Residents Need to Know
A new set of EU banking rules starts to bite in 2027, and it has sparked worry about Georgian bank accounts. Here is what CRD VI actually changes for an EU resident who holds — or wants to open — an account in Georgia, and the parts that are not changing at all.
At a glance
- CRD VI is an EU directive; its key provision for non-EU banks, Article 21c, applies from 11 January 2027.
- It governs when a non-EU bank (such as a Georgian one) may provide core banking services — deposits, lending, guarantees — to clients based in the EU.
- It does not ban EU residents from holding Georgian accounts, and does not order existing accounts to be closed.
- Arrangements entered into before 11 July 2026 are grandfathered.
- Reverse solicitation: if you approach the bank on your own initiative, the branch requirement does not apply to you.
Over the past year a rumour has circulated among relocators and investors that the EU is about to “ban” EU residents from banking in Georgia, or force Georgian banks to close their accounts. That is not what the new rules say. The regulation in question — the sixth Capital Requirements Directive, usually shortened to CRD VI — is a piece of prudential banking law aimed at banks, not at individual account holders. It is worth understanding what it actually does before acting on headlines.
What CRD VI actually is
CRD VI is the European Union’s updated framework for how banks are supervised. For anyone outside the EU, the part that matters is Article 21c. From 11 January 2027, it generally requires a bank established outside the EU to set up and get authorised as a branch (or subsidiary) inside an EU member state before it can provide certain core banking services to clients located in that country. In other words, the rule is about the bank’s obligations when it reaches into the EU market — not about whether a private individual is allowed to keep money abroad.
Which services are actually covered
Article 21c is tied to a defined list of core banking services: taking deposits and other repayable funds, lending (including consumer credit and property-secured loans), issuing guarantees and commitments, factoring, and financing commercial transactions. The concern it addresses is a non-EU bank systematically offering these services into the EU without any supervised presence there. Services that fall outside this core list are treated differently, and the practical focus of the debate has been on cross-border lending and large-scale deposit-taking rather than on someone holding a personal current account.
If you already have a Georgian account
CRD VI includes a grandfathering provision: arrangements entered into before 11 July 2026 may continue to be performed even after the branch rule takes effect in January 2027. So an existing Georgian account is not something the directive tells banks to unwind. The rules bite on new provision of covered services into the EU from the application date onward, not on the fact that you already bank in Georgia. If you are planning to open one, our guide to opening a Georgian bank account walks through what the banks ask for.
Reverse solicitation: the key exemption
The most important carve-out for individuals is reverse solicitation. Where a client in the EU approaches a non-EU bank on their own exclusive initiative — not in response to the bank’s marketing or outreach — the licensed-branch requirement does not apply to that relationship. For a person who decides, on their own, to open an account in Georgia and contacts the bank themselves, this is the exemption that keeps the door open. The practical takeaway is to make sure the contact genuinely comes from you, and to keep a record of how the relationship started.
CRD VI is not the same as CRS
It is easy to mix these up, so to be clear: CRD VI is prudential regulation — it is about whether and how a bank can offer services across a border. The Common Reporting Standard (CRS) is a separate, tax-transparency framework under which participating countries automatically exchange financial-account information with each other’s tax authorities. They are different rules with different purposes. If your concern is whether your home country’s tax office can learn about a foreign account, that is a CRS question, not a CRD VI one — and it is worth getting proper tax advice on your specific situation.
How Georgiafy helps
We help individuals and businesses open and maintain Georgian bank accounts in a way that fits the current rules — on the client’s own initiative, with clean documentation, and with the right account type for what you actually need. If you already bank in Georgia and simply want to understand where you stand, we can walk you through it in plain terms and point you to proper legal or tax advice where your situation calls for it.
Frequently asked questions
Will my existing Georgian bank account be closed because of CRD VI?
There is nothing in CRD VI that orders existing accounts to be closed. Arrangements entered into before 11 July 2026 are grandfathered, and the branch requirement applies to new provision of covered services into the EU from 11 January 2027 — not to the simple fact that you already hold a Georgian account.
Can an EU resident still open a Georgian account after January 2027?
Yes. The reverse-solicitation exemption means that if you approach the bank on your own exclusive initiative, the licensed-branch requirement does not apply to that relationship. Keeping evidence that you initiated the contact is sensible.
Does CRD VI apply to a personal account or only to lending?
It is tied to a list of core banking services — deposits, lending, guarantees and similar. The practical focus has been on cross-border lending and systematic deposit-taking into the EU. An individual opening an account on their own initiative falls under reverse solicitation.
Is CRD VI the same as CRS?
No. CRD VI is prudential banking regulation about cross-border provision of services. CRS is a separate tax-transparency standard for automatic exchange of account information between tax authorities. Different rules, different purposes.
Thinking about a Georgian bank account?
We help EU residents open and keep a Georgian account the right way — on your own initiative, with the documentation in order — and explain where the new rules do and don’t affect you.
This article is general information, not legal or tax advice. CRD VI is being transposed into national law by each EU member state and the detail can vary; confirm how it applies to your situation with a qualified adviser before acting.