Brussels: CRD6 transposition has become the latest compliance problem for national banking regulators. On 1 October 2026, the European Commission sent reasoned opinions to Greece, Spain, the Netherlands, Portugal, Romania and Finland for failing to transpose the sixth Capital Requirements Directive, Directive (EU) 2024/1619, into national law.
The deadline passed on 10 January 2026, so the six countries are already about nine months late. A reasoned opinion is the second formal step of the infringement procedure. It gives each government two months to reply and to notify complete national measures, and it opens the path to a referral to the Court of Justice if the gap persists. Each case carries its own reference, from INFR(2026)0169 for Greece to INFR(2026)0206 for Romania.
CRD6 amends the rules that govern how banks are authorised, supervised and managed. It tightens expectations for the suitability of board members, brings environmental, social and governance risks into supervisory work, and creates a harmonised regime for branches of banks from outside the Union. Those branch rules are due to apply from January 2027, which leaves little room for delay in the countries that have not yet acted. For that reason, CRD6 transposition affects firms’ planning as much as the Commission’s statistics.
Banks face a practical problem when CRD6 transposition lags in one member state. Group compliance teams must apply one set of supervisory expectations in countries with finished laws and another where the old rules still stand. Third-country banks that run branches in the late states cannot know which licensing and reporting conditions will govern them, and national supervisors lack a firm legal basis for some of the new powers. The CRD6 transposition gap therefore weakens the single rulebook that the banking union relies on.
The same package also touched banking law elsewhere. The Commission sent Sweden a reasoned opinion for incomplete transposition of the Bank Recovery and Resolution Directive, including the rules on minimum requirements for own funds and eligible liabilities, the creditor hierarchy and instruments governed by third-country law. Together, the cases show that Brussels is checking the details of the banking crisis framework as well as the headline deadlines.
Most late transposition cases end once the national parliament passes the missing law, and the Commission then closes the file. The six countries now have until early December to answer on CRD6 transposition. If any of them misses that window, the Commission can refer the case to the Court and ask for financial penalties, as it has done in other transposition disputes. Banks and supervisors should watch the national legislative calendars, because CRD6 transposition in those capitals will set the practical shape of supervision from 2027.
