11 January 2027: what the CRD6 directive really changes for your bank account in Georgia

For a few weeks now, one date has kept coming up in my clients’ messages: 11 January 2027. That is when Article 21c of the European CRD6 directive starts to apply. I keep reading that a Georgian, Swiss or Dubai bank will no longer be allowed to open an account for you, and that Europe is shutting the door on savings that want to leave. So the question I get most often is simple: can you still open a bank account in Georgia if you live in the European Union?

The answer is yes. But the rule deserves a close reading, because it does change how you access foreign banks.

What the CRD6 directive actually says

Directive (EU) 2024/1619, known as CRD6, requires banks based outside the Union to have an authorised branch in a member state before they provide “core banking services” to European clients. There are three such services: taking deposits, granting loans and issuing guarantees. In France, Ordinance no. 2026-255 of 9 April 2026 transposed the text. The market-access rules apply from 11 January 2027.

Three points matter most:

• The obligation falls on the bank, not on you. The text places no obligation on private individuals. Recital 6 of the directive even states that consuming banking services outside the Union “is to remain unaffected”.
• Transfers are not affected. Payment services, international transfers, securities accounts and investment services fall under other regimes and remain outside its scope.
• Existing contracts are protected. An account or loan signed before 11 July 2026 is not affected, as long as it is not materially changed: an extension, an additional drawdown or a change in its nature, according to Skadden.

The key: who makes the first move?

The directive provides a so-called “reverse solicitation” exemption. If you contact a foreign bank on your own initiative, it can serve you without a European branch. Retail clients are expressly covered.

On the other hand, the exemption falls away as soon as the bank solicits you, directly or through anyone acting on its behalf. Nor does it allow the bank to then offer you other product categories. And it is up to the bank to prove that the initiative came from you, which a simple tick-box on a form does not do.

In practice, the Georgian bank will no longer come looking for you. You have to go to it. On that point, the post doing the rounds is right.

Europe holding on to the money? I would qualify that

I understand the political reading. European states are heavily indebted and need their citizens’ savings. Each new rule makes access to the outside world a little more complicated. I share that concern about the direction of travel.

But we need to be precise, because concern should not turn into panic. In France, taking deposits or granting loans without a licence was already prohibited before CRD6. The French Banking Federation points out that a comparable system has existed since 2015. For a French resident, the directive mainly harmonises an existing rule at European level, and it even adds written exemptions.

The real risk lies elsewhere. After Brexit, several British banks closed the accounts of clients living in the EU, even though no law required them to. They judged that the cost of compliance exceeded the value of the client. CRD6 may trigger the same reflex at some foreign banks: turning away European residents, out of caution, unless they come of their own accord.

What I advise an investor buying in Georgia

• Open your account on the spot, in person. In Georgia, you can open an account in person with your passport in under an hour, according to FFI. It is the clearest approach, since the initiative is plainly yours.
• Keep a record of your approach. Emails, appointments you booked yourself, travel dates: enough to show that you made the first move.
• Beware of solicitors. An intermediary who brings you a bank you never asked for can cancel the exemption. An adviser carrying out your own decision, on the other hand, is not a problem.
• Paying the developer stays simple. You can still buy an apartment in Tbilisi or Batumi and pay from your European bank: transfers are not covered.
• For a local loan, check case by case. A loan from a Georgian bank that you request on your own initiative remains possible, but each bank will set its own policy.
• Declare your accounts. If you are tax resident in France, every foreign account must be declared each year. That is not new, but it is essential.

A note for my Swiss readers: Switzerland is not part of the European Union. A Swiss resident is therefore not covered by Article 21c.

My view

CRD6 does not close the door. It shifts responsibility for the first move from the bank to the client. For anyone looking to diversify part of their wealth, my conclusion is the same as the one I give my clients: better to do it calmly, on the ground and with proper records, than in a rush against a deadline.

Want to set up your banking and your investment in Georgia properly? Start with the simulator, find out about my support for real estate investment in Georgia, or let’s book a meeting.

This article is general information, not personalised legal or tax advice.