Clifford Chance
German proposal on CRD6 third-country regime
5 September 2025
On 22 August 2025 the German Ministry of Finance (BMF) initiated the legislative process for the transposition of Directive (EU) 2024/1619 of the European Parliament and of the Council of 31 May 2024 amending Directive 2013/36/EU as regards supervisory powers, sanctions, third-country branches, and environmental, social and governance risks (CRD6) into German law by publishing the ministerial draft of the Act on the Implementation of the Banking Directive and Reduction of Bureaucracy (Bankenrichtlinienumsetzungs- und Bürokratieentlastungsgesetz - BRUBEG). As mandated by CRD6, the draft Act proposes significant amendments to the German Banking Act (Kreditwesengesetz, KWG), in particular to the regime concerning cross-border activities by third-country entities in Germany, including the German waivers regime. Certain key elements of the draft Act are addressed in this briefing.
