CRD Passporting establishes the strategic foundation for modern EU Banking Passport operations and defines comprehensive cross-border services, branch systems and international regulatory coordination for financial institutions. As a leading consulting firm, we develop tailored RegTech solutions for intelligent passporting orchestration, automated cross-border compliance systems and predictive EU banking excellence with full IP protection.
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The new third-country regime under CRD VI requires an authorised branch for core banking services in the EU. Third-country branches cannot passport into other member states. Review your structures now.
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We guide your institution systematically through the entire passporting process — from regulatory assessment through supervisory notification to ongoing compliance assurance across all target markets.
Regulatory assessment: Analysis of existing cross-border activities and passporting structures
Notification preparation: Completion of BaFin notification forms per Delegated Regulation 1151/2014 and Implementing Regulation 926/2014
Supervisory coordination: Support for communication with home and host supervisory authorities
CRD VI readiness: Impact assessment of third-country branch regime on your business and structural optimisation
Ongoing compliance: Monitoring regulatory changes and updating passporting documentation
"The intelligent implementation of CRD Passporting requirements is the key to regulatory EU Banking Passport excellence and strategic flexibility in cross-border banking. Our passporting solutions enable institutions to not only achieve compliance but also develop operational superiority in cross-border services and branch management. By combining deep freedom of services expertise with modern technologies, we create sustainable passporting excellence while protecting sensitive business data."

Head of Risk Management
We offer you tailored solutions for your digital transformation
We use advanced algorithms to optimise CRD Passporting implementation and develop intelligent systems for efficient EU Banking Passport criteria orchestration and cross-border services.
Our platforms create adaptive cross-border services systems with continuous regulatory coordination monitoring and automated reporting for all CRD Passporting requirements.
We implement intelligent passporting systems for CRD compliance with machine learning analysis and continuous monitoring of EU Banking Passport criteria and cross-border services performance.
We develop intelligent branch supervision systems that combine CRD Passporting requirements with advanced technology for optimal EU Banking Passport criteria composition and cross-border services integration.
Our platforms automate CRD Passporting monitoring with intelligent regulatory coordination reporting and continuous optimisation of all regulatory cross-border services processes.
We support you in the intelligent transformation of your CRD Passporting and the development of sustainable RegTech capabilities for continuous EU Banking Passport excellence.
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The Advanced IRB Approach (A-IRB) allows institutions to estimate all risk parameters internally — probability of default (PD), loss given default (LGD), exposure at default (EAD) and credit conversion factors (CCF) — using proprietary models. ADVISORI guides you from model development through supervisory approval to ongoing validation — for risk-sensitive capital management under CRR III.
The CRD combined buffer requirement defines how capital conservation buffer, countercyclical buffer, systemic risk buffer and G-SII/O-SII buffers interact under a single framework. ADVISORI advises financial institutions on buffer stacking rules, capital distribution restrictions, MDA calculation and capital conservation planning — ensuring full compliance with the CRD buffer framework.
Capital adequacy requirements under the CRD comprise the overall capital requirement from Pillar 1 minimum, SREP capital add-on (P2R), combined buffer requirement, and Pillar 2 Guidance (P2G). We support banks in supervisory capital quantification, preparation for CRD VI changes, and integration of ESG risks into the capital adequacy assessment.
The Capital Requirements Directive (CRD VI) introduces stricter requirements for governance, fit-and-proper assessments, and ESG risk management. CRD compliance requires end-to-end processes from suitability assessments through internal control systems to ongoing supervisory reporting. ADVISORI supports credit institutions with comprehensive CRD compliance: gap analysis, governance framework design, and regulatory documentation.
The CRD Capital Conservation Buffer under Art. 129 CRD V/VI requires EU credit institutions to hold 2.5% Common Equity Tier 1 (CET1) capital above minimum requirements. When breached, the MDA (Maximum Distributable Amount) calculation triggers automatic distribution restrictions on dividends, bonuses, and AT1 coupons. ADVISORI advises on strategic buffer management, CRD VI implementation, and regulatory capital planning across the EU framework.
The Capital Requirements Directive (CRD) defines comprehensive governance requirements for credit institutions across the EU — from fit-and-proper assessments to management body composition and remuneration policies. CRD VI adds ESG governance obligations and enhanced supervisory board duties. ADVISORI supports you in fully implementing all CRD governance requirements, preparing for suitability assessments, and establishing robust internal governance structures aligned with EBA guidelines.
The countercyclical capital buffer under Art. 130 CRD (Directive 2013/36/EU) requires credit institutions to maintain an institution-specific buffer as the weighted average of applicable national CCyB rates. The calculation under Art. 140 CRD considers the geographic distribution of credit risk exposures. ADVISORI supports you with CRD-compliant buffer calculation, ESRB reciprocity requirements and implementation of CRD VI changes effective January 2026.
The Capital Requirements Directive (CRD VI) imposes comprehensive requirements on credit institutions regarding governance, authorisation, and supervision. We support banks in the strategic implementation of all CRD requirements - from fit & proper assessments and internal governance structures to supervisory interaction. Our RegTech solutions make your CRD compliance efficient and sustainable.
End-to-end consulting for implementing the CRD credit risk framework: from the reformed Standardised Approach (SA-CR) and Output Floor calculations to ECAI due diligence requirements. We support your institution in the compliant implementation of CRR III capital requirements and the strategic optimisation of your risk weighting.
The Capital Requirements Directive (CRD) is the core EU directive governing banking supervision, governance, and authorization of credit institutions. From CRD IV through CRD V to the current CRD VI, it defines the supervisory framework that each EU member state must transpose into national law. ADVISORI has been supporting banks and financial institutions with CRD implementation for over 14 years.
The CRD requires credit institutions to maintain a transparent disclosure process with clear governance. We support banks in establishing three-line quality assurance, drafting the disclosure policy and preparing for the Pillar 3 Data Hub — so your disclosure report withstands supervisory scrutiny.
The European Banking Authority (EBA) operationalises the CRD through binding guidelines on internal governance, remuneration policy, fit-and-proper assessments and ESG risk management. With CRD VI transposition due by January 2026 and the governance guidelines revision (EBA/CP/2025/20), banks face comprehensive adjustments. ADVISORI supports the structured implementation of all EBA requirements — from gap analysis and MaRisk compatibility review to supervisory dialogue.
Fit and Proper ensures that members of the management body, supervisory board and key function holders meet regulatory requirements for knowledge, experience, integrity and time commitment. With CRD VI expanding the scope to key function holders and the revised EBA/ESMA joint guidelines introducing AML/CFT competence requirements, banks face growing complexity in their suitability assessment processes. ADVISORI supports you with systematic implementation of all Fit and Proper requirements across the EU framework.
The CRD defines binding requirements for the internal governance of credit institutions – from the three lines of defence model through internal control systems to the independent compliance function. With the new EBA guidelines (EBA/CP/2025/20) and CRD VI, requirements for risk management governance, control functions, and organizational structures are tightening significantly. ADVISORI supports you with gap analysis, implementation, and ongoing monitoring of your internal governance framework aligned with EBA standards.
Directive 2013/36/EU (CRD IV) together with the CRR forms the regulatory foundation of EU banking supervision under Basel III. We support financial institutions in the full implementation of governance, SREP and Pillar 2 requirements — from gap analysis to supervisory-compliant implementation.
The German implementation of the Capital Requirements Directive IV places specific demands on governance, risk management and BaFin interaction through the KWG and MaRisk framework. We guide banks through full CRD IV compliance in Germany — from gap analysis and SREP preparation to the implementation of compliant remuneration and governance structures.
The use of internal models to calculate risk-weighted assets requires supervisory approval from the ECB and national authorities. We guide your institution through the entire IRB approval process — from model development and validation per the revised ECB guide 2025 to successful regulatory approval. With our expertise, you navigate the tightened CRD VI requirements, the output floor and internal model restrictions with confidence.
The CRD establishes binding liquidity requirements for EU banks — from the Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR) to internal liquidity risk management. ADVISORI supports financial institutions with regulatory implementation, liquidity governance and building robust stress testing frameworks.
The Liquidity Coverage Ratio (LCR) requires credit institutions to hold sufficient high-quality liquid assets (HQLA) to cover net cash outflows over a 30-day stress scenario. The minimum ratio is 100%. Under the EU implementation of Basel III through CRR/CRD, Delegated Regulation 2015/61 governs HQLA categories, inflow/outflow rates, and reporting requirements. ADVISORI supports banks with compliant LCR calculation, HQLA optimization, and supervisory reporting.
CRD Market Discipline creates transparency and trust between financial institutions and stakeholders through Pillar 3 disclosure requirements. As a leading consulting firm, we develop tailored RegTech solutions for automated disclosure processes, intelligent risk communication and strategic transparency optimisation with full IP protection.
CRD passporting (the European Passport) is the right of a credit institution authorised in one EEA member state to provide banking services across all other EEA member states
33 ff. of the Capital Requirements Directive (CRD, Directive 2013/36/EU). The single-licence principle means one authorisation in the home state is valid across the entire EEA. Notification procedures are governed by Delegated Regulation (EU) No 1151/2014 and Implementing Regulation (EU) No 926/2014. The EBA has published technical standards specifying the information to be notified and standard forms for passport notifications between home and host competent authorities.
For branch establishment (freedom of establishment), the credit institution must notify its home supervisor using the standard form in Annex I of Implementing Regulation 926/2014. The home supervisor assesses the notification and forwards it to the host authority, which issues a welcome letter within two months detailing local requirements, particularly anti-money laundering obligations and local reporting duties. For freedom of services (cross-border provision without physical presence), a simplified notification to the home supervisor suffices. Changes to existing passporting activities must be reported at least one month before implementation. For German institutions, BaFin coordinates notifications with the ECB and forwards them to the relevant host supervisory authorities.
CRD VI (Directive (EU) 2024/1619) introduces a harmonised EU framework for third-country branches effective
11 January 2027. Core banking services such as deposit-taking, lending, and guarantees will require an authorised branch in the relevant member state. Key changes: Third-country branches cannot passport their authorisation into other EU member states, unlike subsidiaries which retain full passporting rights. Branches are classified as Class
1 (assets exceeding EUR
5 billion) or Class 2, with capital endowment requirements of 2.5% or 0.5% of average liabilities respectively. Exemptions exist for reverse solicitation (client-initiated only), interbank business, and intragroup transactions. Member state transposition was due by
10 January 2026, with full application from
11 January 2027.
Freedom of establishment allows the creation of a physical branch in another EEA state, requiring a comprehensive notification procedure and compliance with host-country rules. The branch is subject to joint supervision by home and host authorities under the home-host principle. Freedom of services enables cross-border banking without physical presence, for example through digital channels or distance selling, requiring only a simplified notification. The choice between these models has significant implications for supervisory requirements, capital allocation, reporting obligations, and operational costs. Under CRD VI, subsidiaries (rather than branches) offer the strategic advantage of full passporting rights for third-country institutions entering the EU market.
Home-host coordination is a central element of CRD passporting supervision. The home supervisor bears overall responsibility for the institution, including all its branches. The host supervisor monitors compliance with local rules and may exercise enhanced powers over significant branches. The EBA has published guidelines on the supervision of significant branches, defining structured information exchange processes between home and host authorities. In practice, challenges arise from divergent national transpositions of CRD requirements, necessitating careful coordination with both supervisory authorities. For significant branches, the host authority may request participation in supervisory colleges and additional reporting on local operations.
UK banks are classified as third-country institutions post-Brexit and are particularly affected by the CRD VI third-country regime. From
11 January 2027, they must establish an authorised branch in each EU member state for core banking services (deposits, lending, guarantees). This branch cannot be passported into other EU states, restricting the current practice of cross-border lending without local presence. Alternatively, UK banks can establish an EU subsidiary with full passporting rights, though this entails higher capital and governance requirements. The reverse solicitation exemption remains available but under strict conditions: only on the client exclusive initiative, with no active marketing of new product categories.
ADVISORI guides credit institutions through the full passporting lifecycle: from initial assessment of cross-border activities through BaFin notification preparation to ongoing compliance. Our services include regulatory assessment and passporting structure analysis, preparation of notification documents per Regulation 1151/2014 and 926/2014, support for home-host coordination with supervisory authorities, CRD VI readiness assessment including third-country impact evaluation, gap analysis between existing structures and new requirements, and guidance on the strategic choice between branch and subsidiary models. Our consultants bring extensive experience with BaFin and ECB notification processes and understand the country-specific requirements across individual EEA member states.
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