Incorporation · Accounting · VisaAdvisory in German / English

EU banking rule · January 2027

From 2027 an account needs a holder
who belongs there.

There are two ways to meet that. Both work. They differ not in quality, but in what they ask of you.

The obligation falls on the bank, not on you. It creates no prohibition and no new reporting duty for you — but it does raise the question of whether your institution wants to keep you.

Strasia Group — licensed corporate service provider. Hong Kong TCSP licence TC009707, registered ACRA filing agent Singapore FA20260092.

Bank building portal at dusk, slightly ajar

Applies from11.01.2027

Legal basisCRD VI · Art. 21c

Obligation falls onThe bank

Jurisdictions9

Last updated: 08/2026

The real question

Who will hold your account from 2027?

The rule addresses your bank, not you. From 11 January 2027 an institution outside the EU may provide certain core banking services — deposits, lending, guarantees — to EU clients only through a licensed branch or subsidiary in the relevant member state. Exemptions apply to legacy contracts and where the client approaches the bank on their own initiative. A dedicated branch rarely pays off for small retail volumes — which is why we expect a number of institutions to let go of their EU retail clients. That is our assessment; the movement is driven by banks’ risk policy, not by the rule itself.

Schematic illustration · bank master record

Account holder: John Smith
Legal form: Natural person
Holder domicile: Munich, Germany
Register entry: —
Beneficial owner: John SmithThe same person in both cases — and disclosed to the bank.
Tax residency: GermanyUnchanged. A company does not shift personal tax liability.
Place of management: GermanyOnly holds if management and substance are genuinely there — which is exactly what we plan with you.
Client segment: Retail client, EU-resident
Review status 01/2027: Existing-client review

What changes is the account holder. Not who is identifiable.
An existing-client review is not a termination procedure — it starts as a request for data.

Schematic illustration of the structure — no real account data, no statement about any particular institution.

The two routes

Route 1 works without moving. Route 2 requires a move.

We support both routes: we build the companies ourselves, and for a change of residence we guide you through the visa and the process in the countries where we are established. Which is why we also tell you how to spot when either route would be wrong for you.

Route 1

The company becomes the account holder

Requires genuine business activity. No move needed.

A properly built company in Hong Kong, Singapore or the United States holds the account. The bank’s client is then that company in its own jurisdiction.

Private company limited by shares, entered in the Companies Registry
Business account with a locally licensed bank
Audited annual accounts, company secretary
Realistically 6–10 weeks to completed bank onboarding

What speaks against it

A company has running costs, brings bookkeeping and audit duties and demands genuine substance. And it changes nothing about your personal tax liability. Anyone promising otherwise is selling you a problem.

Route 2

Your residence changes

Requires that you genuinely can and want to move.

A genuine residence outside the EU — with a visa, real presence and honest tax registration — usually means your bank no longer treats you as an EU-resident client. We handle the visa ourselves in several countries.

Country choice and visa — Thailand, Philippines, Malaysia and Singapore we handle ourselves
Clarify exit taxation in advance
Deregistration, evidence, certificate of residency in the destination country
Realistically 9–18 months to a defensible status

What speaks for it

Changing residence settles the residency question at its root — not just for the account. If you want to leave anyway, do not build a structure as a substitute. We are with you from choosing the visa to registering on the ground.

The two routes are not mutually exclusive. Anyone who later emigrates will in many cases first need a structure that holds; the company remains afterwards. As for borrowed utility bills and paper residencies: compliance systems cross-check them, and they break exactly when you need them.

Your situation

Three questions decide which route fits you

Move the sliders. Nothing is stored or transmitted — the assessment happens here on your device.

How firmly is your centre of life in Europe?

Family, schooling, property, relatives, ongoing contracts.

can be unwoundfirmly anchored

Where does your income come from?

From local clients — or location-independent and international.

purely localinternational

Is there genuine business activity?

Own clients, invoices, ongoing revenue — not merely assets.

no, assets onlyyes, an operating business

Move the sliders

Depending on your situation, one route or the other applies — sometimes both.

Lead time

How long the two routes take

Nothing ends for you on 11 January 2027 — on that date the rule starts applying to your bank. The deadline still matters, because both routes need lead time. The bars show typical processing ranges, not commitments.

—

Lead time until 11 January 2027

Contracts concluded before 11 July 2026 fall under a grandfathering provision whose scope is not yet settled. Anyone contracting today can no longer rely on it.

Route 1 — company and business account

Onboarding

done — ongoing operation from here

8–14 weeks from initial review to a usable business account — bank onboarding is the longest part.

Route 2 — change of residence

Country

Exit tax

Visa & move

Deregistration · residency certificate

9–18 months from decision to a defensible status. Changing residence moves more than the banking question — and needs more lead time.

today+6+12+18 months

Shared axis — the bars are to scale with each other.

Route 1 in detail

What “properly built” means

It is not incorporations that fail at bank onboarding, but empty shells — and only after weeks. These six points decide it.

Genuine business activity

A comprehensible business model with real clients and invoices. Not a shell built merely to carry an account.

Real counterparties

Contracts, invoices and payment flows that match the described business. That is exactly what the bank checks.

Decisions made locally

Director, resolutions and management where the company is seated — not merely on paper.

Verifiable address

A business address that withstands scrutiny, with deliverable post and demonstrable use.

Bookkeeping and audit

In Hong Kong annual accounts and audit are mandatory. That is effort — and at the same time what makes the structure bankable.

Correct reporting at home

Report the shareholding, declare the income, factor in automatic exchange of information. Everything stays declared.

We prefer to work with all-inclusive packages

A structure meant to be bankable cannot be ordered in parts — which is why our package contains everything that belongs to it. In Hong Kong for example: incorporation and registration, company secretary, business address, registry fees, formation documents and support with opening the account. In Singapore and the other jurisdictions the scope is composed differently — according to what is required there — but is equally complete.

Before any order you receive a written fixed-price offer — with all items and the running costs for the following years. What is not included is stated as well.

What this structure does not do

Four points that belong before an incorporation — not after.

Not a tax scheme

A company does not change your personal tax liability. Anyone advertising tax exemption is selling you a problem, not an account.

Not anonymity

The beneficial owner is disclosed, reporting duties remain, exchange of information continues. That is precisely what makes the structure robust.

No shield for the private account

An existing account tied to your European private address stays what it is. The company creates a viable route alongside it — it does not repair the old one.

Not automatic under tax law

If the company is in fact managed from Germany, it is taxable there — regardless of its registered seat. Controlled-foreign-company rules also remain relevant. Both belong before the incorporation, and that is exactly where we help: we show which structure holds in your case.

Frequently asked

What readers ask at this point

Does the new EU banking rule affect me at all?+

The rule addresses institutions outside the EU, not you. You are affected indirectly: as a client of a third-country bank while resident in the EU. Whether an individual institution keeps you is its own commercial decision — driven by volume and cost, not by your conduct. Holding a foreign account remains entirely lawful; CRD VI changes nothing about your reporting and tax obligations.

Can my bank simply close my existing account?+

In practice it almost never starts with a termination but with a request for data: proof of address, tax residency, purpose of the relationship. Only then does the institution decide whether to continue. Termination rights follow your account agreement and the law at the bank’s seat — not the EU directive.

Will a Hong Kong company save my private foreign account?+

No. That is the most honest answer on this page. Your private account tied to a European address stays exactly that. What the company does provide is a second, durable route for business funds — with an account holder resident in its own jurisdiction. Anyone wanting to resolve personal residency needs route 2.

What about my securities account abroad?+

Pure investment services — custody, trading, portfolio management — are expressly excluded from Article 21c. What is covered is deposits, lending and guarantees. Equating a foreign securities account with a foreign bank account is a factual mistake. Cash balances on the settlement account may be assessed differently.

Is it enough if I approach the bank on my own initiative?+

The directive contains a narrow exemption where the client requests the service on their own initiative — so-called reverse solicitation. It is designed as a case-by-case exemption and read strictly. It does not work as a permanent basis for a banking relationship, not least because interpretation may differ between member states.

How long does a properly built structure take?+

Incorporation and registration take a few weeks. The longer part is bank onboarding: realistically six to ten weeks, depending on the business model, the bank and how complete your documents are. Together that is 8 to 14 weeks — provided the substance is right from the start.

Read on

Where to go deeper

HKCompany formation Hong KongLimited, TCSP-licensed, strong payment access SGCompany formation SingaporePte Ltd, ACRA-registered, local banking USCompany formation USALLC or Corp for the US market MYLabuan incorporationFor international holding and treasury structures ↔Jurisdiction comparisonNine jurisdictions side by side →Relocation & residenceRoute 2 with visa, deadlines and evidence

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28 Ferry Street, Yau Ma Tei
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Legal notice. This page provides general information on a regulatory change and does not replace legal, tax or investment advice. A reliable assessment of your situation requires a case-by-case review of your documents. Individual questions — in particular territorial scope and the reach of grandfathering — are not yet conclusively settled and are implemented differently across member states.
Basis: Directive (EU) 2024/1619 (CRD VI), Article 21c. Member state transposition deadline 10 Jan 2026, application from 11 Jan 2027; grandfathering for contracts concluded before 11 Jul 2026. German transposition in the Banking Directive Implementation Act, published in the Federal Law Gazette on 30 Mar 2026.