Can I keep my US bank account if I live in the EU

What the EU rule of 11 January 2027 means for accounts and cards with US, UK and Swiss banks: which accounts close and which stay open, what to do before the bank's deadline, where to keep the money and how exit tax is calculated on a move out of the EU.

Our clients have started receiving these letters. One of the ten largest US banks wrote on 1 October 2026 to a client with an address in the Czech Republic about the client's US credit card. New EU requirements begin in January 2027, the bank said, and for a client whose primary address is in a member state of the European Economic Area, "to meet the new requirements, we’ll need to close your account(s) listed above".

The bank asked the client to review the address and update it if needed by 1 December 2026, and the client can choose to close the accounts any time before that date. Here is what we tell them.

What changes on 11 January 2027

The rule comes from Directive (EU) 2024/1619, which amends the Capital Requirements Directive 2013/36/EU, and its new Article 21c(1) reads: "Member States shall require undertakings established in a third country as referred to in Article 47 to establish a branch in their territory and apply for authorisation in accordance with Title VI to commence or continue carrying out the activities referred to in Article 47(1) in the relevant Member State."

Article 2(1) of the amending directive sets the date: "However, Member States shall apply the measures necessary to comply with the amendments set out in Article 1, points (9) and (13), from 11 January 2027." Point 9 is the one that inserts Article 21c.

Article 47(1) names the activities. Point (a) covers "any of the activities referred to in points 2 and 6 of Annex I to this Directive by an undertaking established in a third country that would qualify as a credit institution". Point (b) covers "the activity referred to in point 1 of Annex I to this Directive by an undertaking established in a third country."

Annex I starts with "Taking deposits and other repayable funds." Point 6 is "Guarantees and commitments." Point 4, "Payment services as defined in Article 4(3) of Directive 2007/64/EC.", is not among the activities in Article 47(1).

Which accounts close and which stay open

Article 21c(2) lists three exceptions. The first is a client who "approaches an undertaking established in a third country at its own exclusive initiative for the provision of any service or activity referred to in Article 47(1) of this Directive". The other two are "a credit institution" and "an undertaking of the same group as that of the undertaking established in a third country".

The same paragraph closes the door to marketing through others. When the bank reaches a client through a related entity "or through any other person acting on behalf of such undertaking, it shall not be deemed to be a service provided at the own exclusive initiative of the client or counterparty, or of the potential client or counterparty."

Article 21c(3) limits what such a client can be offered. The initiative "shall not entitle the third-country undertaking to market other categories of products, activities or services than those that the client or counterparty had solicited, other than through a third-country branch established in a Member State."

Investment services stay outside the rule. Article 21c(4) reads: "The requirement laid down in paragraph 1 of this Article shall not apply to services or activities listed in Annex I, Section A, to Directive 2014/65/EU, including any accommodating ancillary services, such as related deposit taking or the granting of credit or loans the purpose of which is to provide services under that Directive." Recital 6 adds "the provision of trading of financial instruments services or private wealth management".

Existing contracts have a clause of their own. Article 21c(5) reads: "In order to preserve clients’ acquired rights under existing contracts, the requirement laid down in paragraph 1 shall be without prejudice to existing contracts that were entered into before 11 July 2026." Recital 6 says such measures "should apply solely for the purpose of facilitating the transition to implementation of this Directive, and should be narrowly framed to avoid instances of circumvention."

The letter to our client concerns card accounts that were already open.

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The EEA, Switzerland and the United Kingdom

For Norway, Iceland and Liechtenstein, which take EU banking law through the EEA Agreement, the EEA-Lex database of the EFTA Secretariat lists the directive in Joint Committee Decision 090/2026 with the status: "entry into force of the Decision is pending fulfilment of constitutional requirements by Iceland, Liechtenstein and/or Norway pursuant to Article 103".

Banks in Switzerland and the United Kingdom are also undertakings established in a third country. Murblz experts have described the rules for UK banks in the guide to keeping a UK bank account after moving abroad.

Before 1 December 2026

Recital 6 covers supervision: "To prevent the circumvention of the rules applicable to the cross-border provision of banking services by third-country undertakings, competent authorities should be able to monitor the provision of those services."

The exceptions in Article 21c(2) apply to a client "established or situated in the Union", and we tell clients that the address in the bank's records must be the real one. Murblz experts move income, payments and direct debits to new bank accounts before the old ones close.

Where to keep the accounts

Recital 5 describes the routes that stay open to a bank from outside the EU: "The provision of core banking services listed in Annex I, points 1, 2 and 6, to Directive 2013/36/EU should be made conditional on an explicit and harmonised authorisation requirement in Union law, specifying that undertakings established in a third country which seek to provide such core banking services in the Union should at least establish a branch in a Member State and that such branch should be authorised in accordance with Union law, unless the undertaking wishes to provide banking services in the Union through a subsidiary."

The letter says that accounts opened with the bank's entity in the EEA are not affected. Murblz experts open personal accounts and business accounts with banks established in the EU and in other countries, and the guide to an account abroad despite SCHUFA covers clients with a difficult credit history.

Residence outside the EU

Recital 6 of the directive starts with the line: "The consumption of banking services outside the Union, as in the context of the World Trade Organisation Understanding on commitments in financial services, is to remain unaffected."

A client who lives outside the EU and the EEA is outside the scope of Article 21c. Murblz experts arrange residence permits and the relocation itself, and the guide to the easiest countries to get residency compares the requirements.

And you thought there would be no exit tax?

Another win for European compliance! From 11 January 2027, non-European banks are closing the accounts of EU residents.

For companies, Article 5(1) of Council Directive (EU) 2016/1164 taxes the move when "a taxpayer transfers its tax residence to another Member State or to a third country, except for those assets which remain effectively connected with a permanent establishment in the first Member State". For individuals, each country writes its own exit tax, and the quotes from national laws below are our translations from the official texts.

Exit tax country by country

In Germany, section 6 of the Foreign Tax Act treats as a sale of shares at fair market value "the end of unlimited tax liability as a result of giving up the residence or the habitual abode". It covers shareholdings under section 17 of the Income Tax Act, where the person "within the last five years held, directly or indirectly, at least 1 percent of the capital of the company". The rule applies to people who "within the last twelve years before the events named in subsection 1, sentence 1, numbers 1 to 3, were subject to unlimited tax liability for a total of at least seven years". On application, the tax may be paid "in seven equal annual instalments". The law adds: "As a rule, the application is to be granted only against the provision of security." And: "The annual instalments bear no interest." Murblz experts have covered the details in the guide to the German exit tax in 2026 and in the checklist for leaving Germany.

In France, article 167 bis of the General Tax Code applies to people "tax domiciled in France for at least six of the ten years preceding the transfer of their tax domicile outside France". It taxes unrealised gains on shares that "represent at least 50% of the profits of a company" or whose total value "exceeds €800,000 on that same date". On a move to another EU state, or to a state with French conventions on administrative assistance and tax recovery that is not on the French list of non-cooperative states, payment is deferred automatically. For other states, the deferral comes only on request, with a representative in France and guarantees whose amount "is equal to 12.8% of the total amount of the capital gains and receivables".

In Spain, article 95 bis of Law 35/2006 on personal income tax applies to residents "for at least ten of the fifteen tax periods preceding the last tax period". It counts as capital gains "the positive differences between the market value of the shares or holdings of any type of entity owned by the taxpayer and their acquisition value". It applies when the shares together are worth more than 4,000,000 euros, or when the holding in one company "is greater than 25 percent" and is worth more than 1,000,000 euros. On a move to another EU or EEA state with an effective exchange of tax information, the taxpayer may choose to declare the gain only if, "within the ten years following the last one that must be declared for this tax", the shares are sold, the EU or EEA residence ends or the duty to notify is breached.

In the Netherlands, article 4.16 of the Income Tax Act 2001 treats as a disposal of a substantial holding "ceasing to be a resident taxpayer other than by death". Article 2.8 counts this as "income to be preserved", which is taxed by a protective assessment under article 2.9. Under article 25 of the Collection of State Taxes Act 1990, payment is deferred under a ministerial regulation, which may require "sufficient security", and the deferral ends when the shares are disposed of.

In Denmark, section 38 of the Share Gains Taxation Act treats gains on shares as realised when "the Danish right to tax ceases for a reason other than the death of the taxpayer". It covers people whose shares have "a total market value of 100,000 kroner or more" and who were taxable on share gains "in one or more periods totalling at least 7 years within the last 10 years before the end of tax liability". Section 39 grants a deferral of payment, and on a move outside the Nordic tax convention of 1989 and outside Directive 2010/24/EU the deferral requires "adequate security".

In Norway, section 10-70 of the Tax Act taxes the part of the total gain that "exceeds 3 million kroner". The taxpayer may be granted "12 years' deferral" against security, with one exception: "On a move and transfer to another EEA state, however, security is required only if there is a real risk that the tax claim and any interest claim cannot be recovered." Murblz experts have described the Italian rules in the guide to the Italian exit tax.

How we calculate exit tax: an example

Example: a person resident in Spain for the last fifteen years holds shares worth €5,000,000, bought for €1,000,000, and moves to a country outside the EU and the EEA without a deferral. Article 95 bis(2) provides that such gains "shall form part of the savings income under letter b) of article 46 of this Law and shall be allocated to the last tax period that must be declared for this tax", by a supplementary self-assessment "without penalty, late-payment interest or any surcharge".

Articles 66 and 76 of the same law set the state and regional rates on savings income. Before the personal minimum and other income, the tax on the gain of €4,000,000 comes to the following.

Murblz experts calculate the tax for every country on a client's list before the move. Our tax residency calculator counts the days spent in each country, and the guide on how to become tax resident abroad describes the steps.

Companies, trusts and capital

Article 1 of Directive 2016/1164 reads: "This Directive applies to all taxpayers that are subject to corporate tax in one or more Member States, including permanent establishments in one or more Member States of entities resident for tax purposes in a third country." Article 5(2) gives the right to defer the tax "by paying it in instalments over five years" when the company moves to another member state or to an EEA country. For the EEA, that paragraph "shall apply to third countries that are party to the EEA Agreement if they have concluded an agreement with the Member State of the taxpayer or with the Union on the mutual assistance for the recovery of tax claims, equivalent to the mutual assistance provided for in Council Directive 2010/24/EU".

Murblz experts have described the lawful ways to move money and assets abroad in the guide to capital relocation. Company owners also come to us for company registration, trusts and foundations, investment property and accounting and reporting abroad.

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