Overview
- From 11 January 2027 non‑EU and non‑EWR banks must operate a BaFin‑approved German branch to provide deposit, lending or guarantee business to customers in Germany.
- The rule bars active solicitation by banks without a German branch while preserving a narrow 'reverse solicitation' exception that requires clear proof the customer initiated contact.
- Contracts concluded before 11 July 2026 generally keep their protection but it is unresolved whether post‑cutoff amendments such as credit‑limit increases remain grandfathered.
- Some third‑country banks face capital, staffing and reporting demands—examples include minimum local capital tied to liabilities—that could make a German branch uneconomic and lead banks to curtail or end services to German residents.
- Customers should check the BaFin public register, get written confirmation from their bank about continuity after 11 January 2027, keep records proving any reverse‑solicitation contact and plan alternative payment or financing arrangements because reduced competition could affect pricing and credit availability.