Could new EU banking rules affect your U.S. bank account?

If you are an American living in the European Union, you may have read that U.S. banks could start closing accounts of customers who live in Europe. The reports relate to new EU banking rules that take effect on January 11, 2027.

The short answer: there is no EU rule requiring U.S. banks to close Americans’ accounts. The new rules regulate how banks outside the EU may provide certain services to people living in the EU. Some U.S. banks may respond by limiting services or ending customer relationships, but that would be the bank’s own business decision.

Contracts entered into before July 11, 2026 can generally benefit from transitional protection under the new rules.

What is changing on January 11, 2027?

The EU has updated its banking rules through the Capital Requirements Directive VI (CRD VI). One provision, Article 21c, applies to certain banks and other credit institutions established outside the EU that provide banking services to customers or counterparties in the EU.

The full legislation can be found in Directive (EU) 2024/1619 (CRD VI).

From January 11, 2027, a non-EU institution providing certain core banking services in an EU country will generally need an authorized presence there, such as a branch or subsidiary, unless an exemption applies.

The services covered include:

• accepting deposits and other repayable funds;
• lending, including certain consumer and mortgage loans; and
• guarantees and commitments.

MiFID investment services, including many brokerage and investment activities, are carved out from Article 21c. Brokers and investment firms may still have their own policies for customers living in the EU, but those issues are separate from this particular rule.

The European Banking Authority (EBA) provides further background in its report on banking services provided from third countries.

Does the EU require U.S. banks to close accounts of Americans in Europe?

No. CRD VI regulates banks and other financial institutions, not account holders. It does not say that Americans living in Europe must lose their U.S. accounts.

Importantly, Article 21c does not prohibit an American living in the EU from holding money with a U.S. bank. It regulates how certain banking services may be provided by a non-EU institution to customers and counterparties in the EU.

Each U.S. bank will decide how to comply. Depending on its situation, a bank may:

• serve EU customers through a European branch or subsidiary;
• rely on an exemption, for example where the customer approaches the bank on their own exclusive initiative;
• restrict certain products or services; or
• decide that serving customers resident in the EU is no longer commercially or legally practical, and end the relationship.

Only in that last case would an account be closed, and it would be a choice by the bank rather than an EU requirement.

What happens to my existing U.S. bank account?

Contracts entered into before July 11, 2026 can generally benefit from transitional protection.

In practical terms, the new regime is not intended to automatically disrupt contractual rights that already existed before that date. This can be important if you have maintained the same U.S. banking relationship for years.

Grandfathering has limits, though:

• Questions can arise if an existing agreement is materially changed, renewed or extended.
• Adding new products, such as a new loan or credit line, may need to be assessed separately.
• Transitional protection does not oblige a bank to continue serving you indefinitely.
• Banks can still apply their own policies to customers who live outside the United States.

For a more detailed analysis of grandfathering, reverse solicitation and how CRD VI applies to U.S. institutions, see Skadden: CRD VI – What US Banks Need to Know.

Are U.S. banks already closing accounts?

Americans living in France have reported receiving notices from U.S. financial institutions concerning restrictions or possible account closures.

In September 2026, The Local France reported that Americans in France had received letters from U.S. banks about the new EU banking requirements.

That does not mean accounts are being closed across Europe on a large scale.

The impact is likely to differ by bank, type of account, services involved and country of residence. CRD VI is an EU directive that is implemented through national law, so some practical details may also differ between EU member states.

The European Banking Authority has noted that the effect of Article 21c is difficult to measure and that several exemptions apply.

It is therefore too early to conclude that Americans living in the EU will generally lose access to their U.S. bank accounts.

Does this apply if I live in the UK, Switzerland or Norway?

CRD VI is EU law. If you live in the United Kingdom or Switzerland, which are not EU member states, Article 21c does not directly apply to your U.S. banking relationship.

Norway, Iceland and Liechtenstein are part of the European Economic Area (EEA). EU financial rules are often extended to the EEA, but the timing and implementation can differ.

If you live in one of these countries, keep an eye on communications from your bank and on how the rules are implemented locally.

Is this related to FATCA?

Not directly, although both can affect Americans abroad.

Some European banks have limited services to U.S. citizens for years because of FATCA reporting obligations.

CRD VI works in the other direction: it concerns banks outside the EU, including U.S. banks, providing certain banking services to customers or counterparties inside the EU.

Does CRD VI affect my European bank account?

No. CRD VI does not require European banks to close accounts because the account holder is American.

You may still run into restrictions at a European bank because of FATCA, U.S. securities regulations or the bank’s own policies, but those issues already existed and are separate from the new Article 21c rules.

If your European bank has contacted you about your U.S. status, read more about what to do when your bank sends you a FATCA form.

What should Americans in the EU do now?

If you live in the EU and have a U.S. bank account, loan, mortgage or other banking relationship, there is no reason to assume your account will automatically be closed in 2027.

It is sensible to:

• make sure your U.S. bank has your correct European residential address;
• read any notices or changes in terms from your bank carefully;
• check whether your bank continues to serve customers in your EU country;
• not assume that an existing account automatically gives you access to new products or services;
• think about a backup option for receiving U.S. income, such as Social Security, a pension or salary, and paying U.S. obligations; and
• contact your bank directly if you receive a notice about restrictions or closure, and ask for the specific reason and your available options.

Avoid using a U.S. address where you do not live in order to keep an account open. Giving a bank incorrect residence information can breach your account terms and may also raise questions about state tax residency.

Moving money? Your reporting obligations stay the same

If you move funds from a U.S. account to a European one, keep in mind that foreign financial accounts may need to be reported to the U.S. government.

Depending on your situation and the value of your accounts, this may include:

• the FBAR (Foreign Bank Account Report); and
• Form 8938, Statement of Specified Foreign Financial Assets.

Not sure how a change in your banking setup affects your U.S. filing obligations? Contact Americans Overseas for free, no-obligation advice.

The bottom line

From January 11, 2027, new EU rules change the conditions under which non-EU banks can provide certain banking services to customers and counterparties in the EU.

Some U.S. banks may reconsider how they serve customers who live in Europe. In individual cases, they may restrict services, stop offering new products or close accounts.

But this is not an EU-wide order to close the U.S. bank accounts of Americans living in Europe.

Existing contracts entered into before July 11, 2026 can generally benefit from transitional protection, although later changes or new products may need to be assessed separately.

The practical impact will depend largely on your bank, the services you use and the country where you live.

Americans Overseas will continue to follow developments that may affect Americans living abroad.

Contact us for more information

Sources

• Directive (EU) 2024/1619 (CRD VI), including Article 21c — EUR-Lex
• EBA — Report on the direct provision of banking services from third countries under Article 21c CRD VI, July 23, 2025
• EBA — Final Guidelines on the authorisation of third-country branches, July 7, 2026
• Skadden — CRD VI: What US Banks Need to Know, July 7, 2026
• The Local France — Your questions answered on how new EU banking law affects Americans in France, September 7, 2026