Christian
In this article
An account outside the EU used to be a topic for emigrants and people with secrets. That has changed, from two directions at once. On one side, the idea of a second location for your own money has gone mainstream: not to save tax, but to avoid having everything depend on one bank, one country and one legal framework. On the other side, the EU is making exactly that harder right now. Since the summer of 2026 there is a cut-off date, and from January 2027 a new rule.
This article explains the rule the way it stands in the directive and in the German implementing law, without the drama with which it is told in some forums. Then it turns to the question that actually matters: which routes to an account outside the EU stay open, and which of them make sense for an ordinary entrepreneur or employee living in the EU.
Why an account outside the EU at all
The logic is the same as with any diversification. If you spread your portfolio but keep every account at one bank in one country, you carry a concentration risk at the point where it hurts most: access to your own money. An account freeze over a suspicion that later turns out to be wrong, a banking crisis, a political decision on capital movements. Cyprus in 2013 demonstrated that depositors above the deposit guarantee can be made to contribute to rescuing their bank. That was not an accident, it was the agreed rescue plan.
A second account in a second jurisdiction is the insurance against that. No more and no less. It is explicitly not a hiding place: under the automatic exchange of information practically every bank outside the EU reports the account to the tax office of your country of residence, and interest and dividends belong in your tax return. Anyone who confuses a foreign account with tax planning has not understood the topic and will at some point have it explained expensively.
The new rule: CRD VI and 11 January 2027
The EU banking directive CRD VI governs the conditions under which banks from third countries, meaning outside the EU and the EEA, may serve customers in the EU. The core: anyone offering EU customers deposits, accounts, loans or guarantees needs, from 11 January 2027, an authorised branch in the customer's EU country. Offering an account from Zurich, London, New York or Dubai to a customer in Munich is then no longer permitted without a German branch. In Germany the BRUBEG implements the directive, and the previous practice of Swiss banks using a BaFin exemption for business with German customers falls away with it.
Three things about this are often told wrongly.
Grandfathering applies to contracts signed before 11 July 2026. If you opened your account before that date, the branch requirement does not affect you. The six-month period before the application date produces exactly that cut-off. The protection is tied to the existing contract, though. Material changes, such as a significantly higher credit line, can end it according to lawyers' assessments. And it obliges the bank to nothing: it can still terminate under its own terms.
No account is closed on 11 January 2027. The rule is aimed at the banks, not the customers. It prohibits active offering, not holding. What an individual bank makes of it is a business decision. Some will wind down EU customers without a branch, others will rely on the exemption that comes next.
The exemption is called reverse solicitation. If the customer approaches the bank on their own initiative, without the bank having marketed in the EU beforehand or used an intermediary, the bank needs no branch for that specific product. The exemption is narrow: it covers only the requested service and closely related follow-on services. Law firms such as KPMG Law advise banks to document every such customer enquiry, and according to an analysis by PayTechLaw the German law does not transpose the exemption one to one, how generously BaFin will interpret it is open. For context: the Bundesbank expects the banks' first reports on this around 31 March 2027.
Not affected are EU and EEA banks, which includes Liechtenstein and Norway. Not affected are third-country banks with a German subsidiary holding its own banking licence. And not affected are investment services under MiFID, meaning securities accounts and asset management. A securities account with an attached cash account is a borderline case you should clarify with the bank.
The four routes that stay open
For EU residents the rule leaves four routes to an account outside the EU. They differ in effort and in how robust they are.
Route 1: The EEA detour. Liechtenstein and Norway belong to the EEA and do not fall under the third-country rule. Liechtenstein banks open accounts for non-residents, usually against a minimum deposit that varies by bank. Legally this is the cleanest route, but also the one with the least jurisdictional distance: Liechtenstein is the Swiss franc, EEA law and information exchange all in one.
Route 2: Reverse solicitation, cleanly documented. If you approach a bank in Switzerland, Singapore or the US on your own initiative, you can still become a customer under the exemption. In practice that means: not through an intermediary, not in response to an advertisement, ideally in person at the branch, and knowing that the bank will document the enquiry. Swiss banks already charge customers resident abroad a surcharge, in 2026 between 10 and 25 francs a month depending on the institution, and the number of banks that take German private customers without assets was small even before the rule. Yuh suspended account opening for customers from Germany, France and Italy in February 2026.
Route 3: A real connection to the country. The directive governs business in the EU. If you rent out a flat in Georgia, run an LLC in the US or live in Thailand, you are not banking cross-border into the EU, you are banking locally. This route is the most robust because it does not rest on an exemption but on facts. It does require the facts to be true. Concealing your EU residence from the bank is the fastest way to a frozen account, and the anecdotes about it are plentiful.
Route 4: Open in person, with a passport. The classic foreign account is created in a branch. In the US the large banks do this with a passport and a solid address, without a dedicated programme for non-residents but also without a ban. The path and the order are in the article on US bank accounts for non-residents, the tier above in the article on Chase Private Client. In Singapore the personal visit helps, although banks there restrict EU customers on investment products because of the MiFID rules. In Georgia, Bank of Georgia and TBC open accounts for non-residents in person or via a notarised power of attorney, there are no published minimum deposits, and the practice for remote opening keeps changing.
The order I would recommend
- First clarify what the account is for. Payments in one currency, a liquidity reserve outside the EU, or a base for credit in a second country are three different jobs with three different banks.
- Choose the country by your connection to it, not by a ranking. An account in a country you visit regularly, do business in or own property in survives every compliance review. An account in a country that appeared on a list as "bank-friendly" often does not survive the first query.
- Open in person and stay honest. EU residence on the form, tax number provided, source-of-funds questions answered in full. The bank reports the account anyway.
- Use the account. An account on which nothing happens for years is eventually closed. Regular, explainable movements are the best protection.
- Do not touch a contract that is grandfathered. Accounts from before 11 July 2026 should not be negotiated out of their protection through new credit lines or product changes.
One single account outside the EU, at a real bank, in a country with a real connection, opened in person and used regularly: that is the whole plan B for most readers. Everything beyond that, second passports, structures, exotic jurisdictions, is a different topic with different costs, and it only starts once this one account is in place.
