CRD VI and Georgian Bank Accounts: Can EU Residents Still Open an Account?

Rumors are circulating that new EU financial regulations will prevent EU residents from holding offshore accounts. But can you still have a bank account in Georgia under CRD VI rules? Is it really that bad? Let’s break it down.

Can EU residents still have bank accounts in Georgia?

Terminology: We use “EU residents” throughout this article because the rules concern clients who are based or established in the EU, rather than simply people who hold EU citizenship.

CRD VI does not ban EU residents from holding a bank account in Georgia. The new rules concern when a Georgian bank can provide certain banking services to a client in the EU without having an authorised branch in the EU.

It does not stop you from keeping your foreign bank account, nor does it force Georgian banks to drop European clients.

Overview

What the new EU rules actually do

From 11 January 2027, CRD VI Article 21c introduces new rules for banks outside the EU that provide certain banking services to clients in the EU.

The basic rule is that a bank outside the EU will generally need an authorised branch in the EU to provide these covered banking services to clients in the EU.

• Taking deposits
• Giving loans
• Issuing business guarantees

Article 21c also contains important exceptions. The one most relevant to individual EU clients is reverse solicitation.

Clearing up misconceptions

There are three common rumors online, causing confusion right now.
These claims are misleading.

• “EU residents will be banned from holding Georgian bank accounts.” – False
• “Georgian banks must shut down accounts owned by EU residents.” – False
• “Accounts opened after 11 July 2026 will be closed.” – False

• If you entered into your banking contract before 11 July 2026, the existing contract is protected from the new branch requirement. New products or services should be assessed separately.
• The important exception is reverse solicitation: where you approach the Georgian bank on your own initiative, the bank may be able to provide the service without establishing an EU branch.

Reverse Solicitation: How you can still open an account

Reverse solicitation is not a workaround – CRD VI expressly recognises this situation as an exception to the branch requirement:

“The requirement to establish a branch in the Union should not apply to cases of reverse solicitation, that is where a client or counterparty approaches an undertaking established in a third country at its own exclusive initiative for the provision of banking services.”

In practice, this means that an EU-based client can approach a Georgian bank by their own exclusive initiative, without the bank first having to establish an EU branch for that service. The key phrase is “own exclusive initiative.”

To keep your application clean and straightforward:

• Make the first move and contact the bank directly.
• Ensure you weren’t responding to an ad campaign in your home country.
• If you use a consultant, make sure the consultant is not acting on behalf of the bank.

Note: Reverse solicitation is not a blanket exemption for all future banking products. Under Article 21c, the client’s initiative does not entitle the third-country bank to market other categories of products or services beyond those originally solicited, except where the additional service is necessary for or closely related to the original service.

What this means for current account holders

If your banking contract was entered into before 11 July 2026, the new EU branch requirement does not affect that existing contract. Georgian banks are not being instructed by European authorities to shut down your account when the new rules take effect on 11 January 2027.

However, if you plan to enter into a new banking contract or obtain an additional banking service, ask your bank how Article 21c affects that particular service.

For existing account contracts, Article 21c does not by itself require those contracts to be terminated.

What this means for new applicants

Yes, EU residents can still seek banking services from Georgian banks.

For applications from 11 January 2027 onward, reverse solicitation may be important if the service you are seeking falls within Article 21c and you have approached the Georgian bank on your own initiative.

If the reverse-solicitation conditions are satisfied, the bank can assess the application under its normal eligibility, KYC, AML and risk procedures.

Approval has never been automatic, so you should have your paperwork well-organized before applying:

• Valid passport and proof of address
• Tax identification and tax residency info
• In case you open an account remotely, a power of attorney is also required (You can check detailed information about the opening process in this article)

What are Georgian banks actually saying?

This is not theoretical. PB Services has discussed the practical implications with senior management at several of Georgia’s largest banks. They indicated that they expect to continue considering applications from EU clients who meet their compliance requirements, while refining onboarding procedures to document client-initiated contact.

Practical next steps

Don’t let sensational headlines push you into a rushed decision.

The changes do not create a general prohibition on EU residents seeking banking services outside the EU, but the way a Georgian banking relationship is initiated and maintained may become more important from 11 January 2027.

Important Disclaimer: This article reflects regulatory information available as of 16 September 2026. Individual bank policies and local enforcement may vary. This content is for general informational purposes only and does not constitute legal, tax, or financial advice.

References

1. Directive (EU) 2024/1619 of the European Parliament and of the Council (CRD VI)
2. Law of Georgia on Commercial Bank Activities
3. Deposit Insurance Agency of Georgia: About the Deposit Insurance System
4. European Commission: Deposit Guarantee Schemes

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