An amendment to an EU directive is set to complicate lending into the EU for non-EU banks, including UK banks. The relevant amendment was inserted into the EU Capital Requirements Directive IV (2013/36/EU) (CRD) as Article 21c by Capital Requirements Directive VI (2024/1619/EU) (CRD VI). In summary, Article 21c CRD requires EU member states to pass domestic legislation preventing in scope third country undertakings from providing core banking services into an EU member state except through an authorised branch in that member state. This means that non-EU lenders may not now be able to lend to EU borrowers directly from the UK, where previously those lenders may have been able to do. Member States were required to transpose CRD VI into national law by 10 January 2026, with the measures to actually apply from 11 January 2027—see: Article 2 CRD VI. Contracts entered into prior to 11 July 2026 can be ‘grandfathered’ (see below). The provisions also apply to the three additional EEA states, Norway,

Ireland-Banking & Financial Services analysis: This article was written by David Molloy, partner (Debt Finance), Kevin Lynch, partner (Debt Finance), Darragh Geraghty, partner (Debt Finance), Imelda Shiels, partner (Debt Finance), Ruth Lillis, partner (Debt Finance), Ciara Buckley, partner (Debt Finance), Sarah Thompson, partner (Financial Regulation), Robert Cain, partner (Financial Regulation), Katherine Quirke, of counsel (Debt Finance) and Sinéad Cantillon, senior professional support lawyer (Debt Finance), of Arthur Cox LLP. It examines the impact of Article 21c of Directive (EU) 2024/1619 (the Capital Requirements Directive VI (CRD VI)). It covers the Irish transposition approach and key timing considerations, exemptions and alternative approaches including reverse solicitation, the circumstances in which banking services may be regarded as being provided 'in the State', grandfathering, and syndication and secondary market issues.

Ireland—Banking and Financial Services analysis: This article, written by Kevin Lynch, partner (Debt Finance), and Ben Rayner, Of Counsel (Debt Finance), of Arthur Cox LLP, examines the practical implications of Article 21c of Directive (EU) 2024/1619, the Capital Requirements Directive VI (CRD VI) for cross-border corporate lending from an Irish perspective. It considers the restrictions on non-EU banks providing core banking services to EU borrowers, the Loan Market Association's (LMA’s) guidance on grandfathering and available exemptions, the implications of Ireland's pending transposition of CRD VI and the key operational and structuring steps institutions should take ahead of the application of the new regime in January 2027.

Ireland-Banking & Financial Services analysis: This article was written by Ruth Lillis, partner (Debt Finance), Sarah Thompson, partner (Financial Regulation), Katherine Quirke, of counsel (Debt Finance) and Sinéad Cantillon, senior professional support lawyer (Debt Finance) of Arthur Cox LLP. This article examines the application of Article 21c of Directive (EU) 2024/1619 (the Capital Requirements Directive VI (CRD VI)) to aviation finance transactions. This briefing focuses on aviation-specific structures and is intended as a practical, transaction-level guide for market participants.

Exclusions which can be used to avoid dealing as agent or arranging a transaction by entering into such a transaction on the advice of an authorised person

On 26 March 2021, the Commission published a guidance paper regarding its change of approach to the use of Article 22 EUMR (Article 22 Guidance). In short, the Article 22 Guidance encouraged national competition authorities to refer to the Commission transactions that do not meet national merger control thresholds and would therefore otherwise escape merger control in the EU. For further information,

Life Sciences analysis: The question for the court was essentially: does the historic Court of Justice decision of Medeva (C-322/10 ) apply such that a product is prevented from being granted an SPCif it has previously been authorised as part of a combination? The court concluded the answer is: yes. The court confirmed that the IPO was correct to refuse an SPC for drospirenone based on Medeva, such that an earlier marketing authorisation (MA) for drospirenone combined with estrogen meant that the MA for drospirenone alone was not the first MA for drospirenone. This case matters for SPC strategy: any earlier MA (monotherapy or combination) can prevent SPC rights for an active ingredient. Written by Dan Byrne, partner at Venner Shipley LLP.

An exclusion in the Regulated Activities Order which enables a solicitor to avoid carrying on the regulated activity of arranging an investment.

An exclusion which applies when a client is introduced to an authorised person to arrange and/or to advise on a regulated mortgage contract

An opinion from the European Commission confirming that a State's plan to dispose of radioactive waste is unlikely to result in the radioactive contamination of the water, soil or airspace of another Member State.

A direction made by a local planning authority to withdraw permitted development rights that would otherwise apply by virtue of the Town and Country Planning (General Permitted Development) Order 2015, SI 2015/596 (in England) and the Town and Country Planning (General Permitted Development) Order 1995, SI 1995/418 (in Wales).

STOP PRESS: A revised version of the National Planning Policy Framework was published on 17 August 2026. This content is being reviewed in light of the revised version. Article 4 directions can be used by local planning authorities (LPAs) to withdraw permitted development rights that would otherwise apply by virtue of the Town and Country Planning (General Permitted Development) Order 2015, SI 2015/596 in England (the England GPDO) or the Town and Country Planning (General Permitted Development) Order 1995, SI 1995/418 in Wales (the Wales GPDO). An article 4 direction does not prevent the development to which it applies, but instead requires that planning permission is first obtained from the LPA for that development. For more information see Practice Notes: Permitted development in England, Permitted development rights and the prior approval system and Permitted development in Wales. When article 4 directions should be used Statutory requirements The LPA must be satisfied it is ‘expedient’ that development that would normally benefit from permitted development rights should not be carried out unless permission is granted for it on an application. Policy