On 27 August 2026, in Paris, Ursula von der Leyen told the French employers’ federation that EUR 10 trillion of European household savings are “sitting idle” in bank accounts and that Europe now needs to put them to work for its own companies. Four and a half months later, on 11 January 2027, a rule from the EU’s latest banking directive starts to apply: a bank outside the European Union that wants to keep serving clients living in the EU must do so through a branch inside the EU. The two facts have been travelling together across social media all week, and several clients have written to ask whether the combination reaches their money in Indonesia. Most of what is being said is accurate. What is missing is who the rule actually touches, and for Indonesia the answer is more settled than the tone suggests.
What changes on 11 January 2027
The rule is Article 21c of the sixth Capital Requirements Directive, known as CRD6, which is Directive (EU) 2024/1619. From 11 January 2027, a bank based outside the EU that provides what the directive calls core banking services to clients in a member state must do so through a branch established and authorised in that member state. Core banking services are three things: taking deposits, granting credit, and issuing guarantees or commitments. Brokerage, investment advice, payment apps and crypto platforms fall under other regimes and are not what this article of the directive is about.
The obligation sits with the bank. Nothing in the directive gives anyone the power to freeze, move or seize a client’s balance, and this is not a corralito of any kind. What the rule decides is which banks may lawfully keep a relationship with a client who lives in the EU. A bank that is affected has three options: open an authorised EU branch, rely on a narrow set of exemptions, or stop serving EU clients.
Why the two stories arrived together
The directive was adopted in May 2024. The European Banking Authority reviewed its exemptions in a report of 23 July 2025 and found no evidence to recommend changing the article, which is the “regulator said no” that is being quoted. Neither of those is new. The Paris speech is new, and it is the reason the rule is being read the way it is: the Commission wants European savings invested in European companies through what it calls the Savings and Investments Union, and it has said so in plain words. The speech and the directive are separate instruments with separate purposes. One is a policy ambition about where savings are invested. The other is a supervisory rule about which banks may operate in the EU market. They arrived in the same news cycle and have been read as one plan.
Three dates, and one has already passed
| Date | What it is | Where it stands today |
|---|---|---|
| 10 January 2026 | Deadline for member states to transpose the article into national law | Passed. Spain and 21 other member states had not transposed it as of the Commission’s register of 7 August 2026 |
| 11 July 2026 | Grandfathering cutoff. Contracts signed before this date may keep being serviced without a branch, as long as their terms are not substantially changed | Passed. An account opened after this date with an EU address is not protected |
| 11 January 2027 | The branch requirement applies | Ahead |
The middle row is the one that matters for advice you may have seen online. Opening a foreign account now, “before the rule kicks in”, does not put you in the protected group. The protected group closed on 11 July 2026. An account opened today with a European address is, from January, exactly the kind of relationship the rule is aimed at.
The first row matters for a different reason. The directive never defines what it means to provide a service “in” a member state. Whether that turns on the client’s address, on where the bank markets, or on where the service is delivered will be settled by national law and by supervisors’ practice, and in Spain neither exists yet. Anyone telling you with confidence exactly how the rule will be applied to a Spanish resident is describing their expectation, not the law.
The five questions that decide whether you are affected
In the absence of a definition, banks will do what banks always do and apply the test they can evidence. In practice that comes down to five questions.
Where does the bank think you live? Not where you pay tax, and not where you were born. The residential address on the bank’s file is what its compliance department reports on and what a supervisor can check. A person who lives in Bali but left a Spanish address on the account is, in the bank’s records, a European client.
When was the account opened? Before 11 July 2026 and the contract is grandfathered. After that date and it is not.
In whose name is it? An account in the name of a company incorporated in Indonesia belongs to an Indonesian client whoever the shareholders are. The nationality and residence of the owners are not the test.
Who approached whom? The directive exempts a relationship that the client initiated entirely on their own. Supervisors read this narrowly: it covers the product you asked for, not a menu of others the bank may then offer. Walking into a branch in Indonesia and asking for an account is the clearest example of a client’s own initiative there is.
Does the bank have anything in the EU to lose? A European supervisor can sanction a bank with a branch, a subsidiary or a licence in its territory. A bank with none of those is outside its practical reach. This is the question that separates the Swiss and Singapore private banks, which mostly do have European operations and are already restructuring, from the Indonesian retail banks, which do not.
Where Indonesia stands
None of the large Indonesian retail banks has a branch or subsidiary inside the European Union. Bank Mandiri’s only European entity is a wholesale subsidiary in London, which is outside the EU and does not open personal accounts. That single fact shapes every row below. The EU cannot compel an Indonesian bank to open a European branch, and no Indonesian bank is going to apply for one in order to keep a handful of European account holders. Whatever happens to those relationships will be decided by each bank’s own compliance policy, not by Brussels.
| Your situation | Address the bank holds | Inside the rule? | What to do |
|---|---|---|---|
| Company account of your PT PMA | The company’s, in Indonesia | No | Nothing. An Indonesian client of an Indonesian bank |
| Personal account, KITAS holder, Indonesian address, still tax resident in Spain | Indonesian | No | Nothing. Tax residence is not the bank’s test |
| Personal account, KITAS holder, Spanish address left on file | Spanish | Looks like yes, on paper | Update the address to your Indonesian one |
| Personal account, no KITAS, Spanish address, opened before 11 July 2026 | Spanish | Grandfathered | Nothing, as long as the terms do not change |
| Personal account, no KITAS, Spanish address, opened after 11 July 2026 | Spanish | Yes | Put it on a resident footing once you have a KITAS, or decide what the account is for |
The company account. A PT PMA is an Indonesian legal entity. Its account at an Indonesian bank is a relationship between an Indonesian client and an Indonesian bank, and Article 21c has nothing to say about it, whether the shareholders live in Madrid or in Canggu. Company money held through the company is the position we build for every client, and it is outside this rule by construction.
The resident’s personal account. A KITAS holder has a stay permit, a registered domicile and usually an NPWP tax number in Indonesia, so the bank’s file shows an Indonesian resident. The question we are asked most often is what happens if that person is still a tax resident of Spain, for example because they have not yet completed a full year abroad or still have family and property there. For the bank, nothing happens. Tax residence is a matter between you and two tax authorities and is reported through a different regime, described below. It is not what a bank uses to classify where its client lives. The one thing worth doing is checking that the address the bank holds is the Indonesian one, because a stale Spanish address on the file is the only way a resident can look like a European client.
The non-resident account. This is the one case the rule reaches. A personal account at an Indonesian bank is designed for people who live in Indonesia, and in practice accounts for non-residents exist on conditions that vary from bank to bank. If you hold one with a Spanish address, it was opened after 11 July 2026, and it is in your own name, then from January 2027 an Indonesian bank that chose to look at the question would find a relationship that European law says needs a branch. We do not expect Indonesian banks to go looking. We do expect some of them, over time, to tighten onboarding for applicants with EU addresses, the way banks elsewhere have done under earlier rules. For anyone in this position who is moving to Indonesia, the sensible course is to put the account on a resident footing once the KITAS is issued, which is the same administrative step as above. For anyone who is not moving, the honest answer is that an account of this type was never a structure to build on, and January 2027 is a reasonable moment to decide what it is for.
What this is not
Much of the commentary adds that more and more people are watching where you put your money. That refers to a different regime. Under the OECD Common Reporting Standard, Indonesia already reports the accounts of Spanish tax residents to Spain, and has done for years, and CRD6 changes nothing about it. If you are a Spanish tax resident with an Indonesian account, Spain knows about it today and will know about it in 2027 regardless of this directive. The two questions, who may serve you and who is told about it, are separate, and it helps to keep them separate when deciding what to do.
Questions we are being asked
Can I keep a bank account outside the EU after 11 January 2027?
Yes. The rule restricts which non-EU banks may serve clients living in the EU without an EU branch. It does not prohibit you from holding the account, and accounts opened before 11 July 2026 are grandfathered.
Does CRD6 affect my PT PMA’s bank account in Indonesia?
No. The account holder is an Indonesian company, so the relationship is between an Indonesian client and an Indonesian bank, whatever the residence of the shareholders.
I have a KITAS but I am still a tax resident of Spain. Am I affected?
Not by this rule, as long as the bank holds your Indonesian address. Tax residence is reported under the Common Reporting Standard, which is a separate regime and is unchanged.
Should I open a foreign account now, before the rule applies?
Opening one now does not protect it. The grandfathering date was 11 July 2026. An account opened after that date with an EU address is within the rule from January 2027.
Will Indonesian banks close accounts of Europeans?
No Indonesian retail bank has an EU branch, so European supervisors have no practical hold over them. What individual banks do about EU-address clients will be their own policy decision. Holding the account on a resident footing removes the question.
The 2027 account check
If you hold money outside the EU and want to know which row of the table you are in, send us three facts: the address your bank holds for you, the month and year the account was opened, and whose name it is in. We will tell you where you stand and whether anything needs doing before January. There is no charge for the answer.
And if Indonesia is in your plans, the way we set clients up puts them outside this rule by construction: company money through the PT PMA, personal money as a resident on a KITAS, and the bank holding the address you actually live at.
Correct at the date of publication. Spain had not transposed CRD6 when this was written, and the practical application of the rule will depend on national law and on each bank’s own policy. Ask us to look at your position, or know more about company setup.