On Friday 10 July 2026, an extract from the Statutory Instrument (S.I.) transposing CRD VI into Irish law, was circulated to stakeholders by the Department of Finance.

The extract relates to the transposition of Article 21c.

As expected, the extract represents a faithful transposition of the Article 21c requirements and exemptions.

Whilst clarifications in the domestic text could have been helpful in assisting market participants in navigating the Article 21c requirements (other Member States have adopted such a clarificatory approach to transposition), the copy out approach means that Ireland’s national transposition remains fully aligned with the European level text. This is helpful in the sense that no additional requirements or restrictions have been introduced.

We understand that neither the Department of Finance nor the Central Bank of Ireland intend to publish any explanatory memoranda and/or guidance.

The full S.I. was signed in to law on Friday 10 July 2026. The full text is due to be published in the Irish Statute Book in the coming days, and we will be examining how the text of the full S.I. interacts with other provisions of Irish law governing the provision of banking services.

The grandfathering cut-off date remains 11 July 2026 notwithstanding the late transposition.

We will be updating our detailed briefing What does CRD VI mean for financial services in Ireland? | Arthur Cox LLP in the coming days when the full S.I. is published.

Please contact Sarah Thompson, Robert Cain or any member of the Arthur Cox Financial Services team if you have any questions, we would be delighted to hear from you.