Authors Helena Viita senior advisor; Miia-Mari Kasi senior associate and Eira-Alina Tiainen associate at Roschier Helsinki.

CRD VI Implementation in Finland: the access of third-country undertakings to the Finnish market

Implementation status and regulatory approach

European Union (EU) legislation has traditionally imposed relatively limited harmonised requirements on third-country credit institutions (TCIs) seeking to offer banking services within the union. This is set to change with the introduction of Art 21c of the Directive (EU) 2024/1619 (CRD) amending the Capital Requirements Directive 2013/36/EU (CRD) which requires a TCI wishing to carry out “core banking services” within any EU member state to establish a branch in the EU member state and obtain a local licence (the TCB requirement).

Member states were required to adopt and publish the necessary implementing legislation by 10 January 2026. In Finland the delayed implementation process of CRD VI has...