CRD VI and EU Expat Mortgages - What Changed in 2026

CRD VI (Capital Requirements Directive VI) is the sixth iteration of the EU's Capital Requirements Directive - a framework governing the operation of banks and investment firms in the European Union. It tightened the rules for non-EU financial institutions providing services to EU-resident clients.

The directive's practical impact on UK expat mortgages: Non-EU financial institutions - including Guernsey-based and Jersey-based banks such as Skipton International and Market Harborough Building Society - face increased compliance requirements and restrictions when providing mortgage products to clients resident in EU member states.

CRD VI effectively makes it commercially unviable for small and mid-size non-EU lenders to continue serving EU-resident clients - the compliance cost exceeds the revenue from this segment of their business.

The two most significant lender withdrawals from EU-resident expat mortgage applications:

Skipton International (Guernsey):

• Deadline for new EU-resident applications: 31 March 2026
• Applications submitted after this date declined for EU-resident applicants
• Existing Skipton mortgages for EU-resident customers are unaffected and continue
• Product transfers and retention products are also unavailable for EU-resident customers
• Skipton has stated it is working to meet updated regulatory standards - a return is possible but not confirmed or timed

Market Harborough Building Society:

• Also withdrew from EU-resident mortgage applications during 2026
• Smaller market share than Skipton but notable for some EU-resident expat cases

Note: These withdrawals affect new applications only. Existing mortgages with these lenders for EU-resident borrowers continue under their existing terms.

CRD VI affects UK expats (British nationals) living in any EU member state:

• France
• Germany
• Spain
• Italy
• Netherlands
• Belgium
• Ireland
• Portugal
• Sweden
• Denmark
• Finland
• Austria
• Poland
• Greece
• Romania
• Bulgaria
• All other 27 EU member states

Not affected by CRD VI:

• UK expats living in Switzerland (not an EU member)
• UK expats living in Norway, Iceland, Liechtenstein (EEA but not EU - CRD VI scope confirmed separately)
• UK expats living in the UAE, Singapore, Hong Kong, Australia, USA, Canada, and all non-EU countries

Despite the Skipton and Market Harborough withdrawals, alternatives remain for EU-resident expats:

HSBC Expat (Jersey):

• Jersey is a Crown Dependency - not subject to CRD VI in the same way as Guernsey
• HSBC Expat has not withdrawn from EU-resident applications (as of August 2026)
• Residential and BTL mortgages available
• Requires HSBC Expat bank account and minimum income of approximately £75,000

Molo Finance:

• UK-regulated digital lender
• Has not withdrawn from EU-resident applications (as of August 2026)
• Competitive BTL rates (from 4.18% following April 2026 rate cut)
• No bank account requirement
• Primary option for BTL applications from EU-resident expats

Santander International (Isle of Man):

• IoM operates under a different regulatory framework from Guernsey
• Santander International has not announced withdrawal from EU-resident applications
• Requires Santander IoM banking relationship

Specialist channel lenders:

• DBF accesses additional specialist lenders not publicly marketed who may have EU-resident appetite
• These change regularly - contact us for the current EU-resident expat lender shortlist

Private banking:

• For HNW EU-resident expats with £1m+ loan requirements, private banking relationships (EFG, Investec) are largely unaffected by CRD VI

If you are a UK expat living in an EU country and considering a UK mortgage:

1. 1Contact a whole-of-market specialist broker immediately - the EU-resident lender shortlist is smaller and changes as lenders assess their CRD VI positions. Current information is essential.
2. 2Do not assume your usual lender is still available - if you previously used Skipton International or Market Harborough, they are no longer available for new applications. Your existing mortgage is unaffected, but any new application or remortgage needs to go through an alternative lender.
3. 3Consider the timing of your remortgage - if your existing Skipton mortgage is on a fixed rate approaching expiry, plan the remortgage to an alternative lender in advance of the rate expiry. Do not wait until the fixed rate expires and you fall onto the standard variable rate.
4. 4Maintain your documentation - the documentation requirements for the alternative lenders are similar to Skipton's. Having your income evidence, bank statements, and AML documentation ready reduces the time to application.