AFB Practice Roundtable: The Ongoing Impact of CRD VI (Art. 21c and Art. 48) on Non-EU Headquartered Banks

Art. 21 of CRD VI introduces a new regulatory framework for Third-Country Branches (TCBs), providing core banking services in the EU, including enhanced supervisory, governance and reporting requirements.

Article 48 establishes periodic reporting obligations for TCBs, requiring firms to provide regulators with comprehensive information regarding their activities, asset and liabilities, risk profile, financial condition and compliance arrangements.

Ahead of the reporting reference date of 31 March 2027, AFB, in partnership with Deloitte, invites members to a practice roundtable to discuss the practical implications of the changes and the emerging supervisory expectations for non-EU banks operating in the UK.

Why attend?

This roundtable will bring together firms to discuss regulatory expectations, controls, governance arrangements, and implementation challenges and practical approaches to achieving reporting readiness. The key discussion areas will be:

• CRD VI TCB Reporting: Requirements, Scope and Supervisory Expectations
  An overview of the new third-country branch reporting framework, including reporting scope, frequency, remittance timelines and the key supervisory expectations around completeness, accuracy, traceability, and data quality
• Reporting Governance, Ownership & Control Frameworks
  Practical approaches to control framework, operating-model design, finance and business ownership, validation, reconciliation, attestation and senior-management oversight to support accurate and controlled submissions
• Operational & Technology Readiness for TCB Reporting
  Data sourcing, booking-register dependencies, data gaps, systems readiness, testing, XBRL and validation requirements, and opportunities to build sustainable automation into the reporting process
• Peer Insights, readiness challenges & Practical Lessons
  The sharing of real-world experiences from firms preparing for CRD VI, including common implementation challenges, lessons from testing and mobilisation, and practical considerations for achieving a robust first submission

AFB will circulate an agenda and series of questions to attendees in advance, which will be used to aid discussions.

The Chatham House Rule will apply to this event to encourage open dialogue and discussion.

Please note that there will be a limit of one representative from each AFB member to allow a wider range of firms to attend and benefit from the discussion.

Who should attend?

This session will be useful to programme leads, regulatory specialists, Controls & Governance leads, senior stakeholders of Finance, Risk, Legal and Compliance teams to share insights, compare approaches, and explore emerging supervisory expectations as they progress their implementation plans.

Facilitators

Atif Yusuf- Partner

Atif has over 18 years of experience in Banking & Capital Markets. He is a leader within the Prudential Regulation business. He specialises in audit, finance transformation and regulatory change. Atif has led audits of large retail banks, broker-dealers and mid-tier banking institutions. He also leads large-scale finance transformation and cost reduction programmes. His experience spans both the UK and Middle East, supporting financial institutions through complex regulatory and business change initiatives.

Fauzi Waraich – Partner

Fauzi has over 19 years of Professional Services experience with a specialism in Capital Markets. He is one of the Risk and Regulation leads within Deloitte’s Technology & Transformation business, leading the Operating Model Transformation team. He has worked across front-to-back change programmes on the regulatory agenda, legal entity restructuring, operating model, cost reduction and operational efficiency topics.

Andrew Freeman- Partner

Andrew has over 20 years of experience providing assurance and advisory services to Financial Services clients. He co-leads the Regulatory Reporting Assurance proposition. He specialises in prudential regulation, regulatory reporting and assurance over capital and liquidity requirements. Andrew leads regulatory specialist support for external audit clients across the sector. He has extensive knowledge of the UK PRA and FCA regulatory frameworks and reporting requirements. His experience helps financial institutions navigate complex regulatory obligations and supervisory expectations.

James Henson – Director

James is a Director in Deloitte’s Legal practice, specialising in wholesale banking and capital markets regulation. James supports many aspects of Deloitte CRD VI’s offering, including Article 21c rules and the requirements for third-country branches.

Namrata Sharma – Associate Director

Namrata has over 12 years of experience providing assurance and advisory services to Banking & Capital Markets clients. Namrata has developed considerable expertise in internal controls, front-to-back trade life cycle, financial reporting, Sarbanes-Oxley (SOX) COSO compliance & controls testing automation, project management and managing risk on engagements. Namrata is a core part of Deloitte’s CRD VI team & currently leading CRD VI TCB engagement.

Logistics

Fee: Included in membership

Venue:  Deloitte, 2 New Street Square, London, EC4A 3BZ

Date: Monday 02 November 2026

Time: 15:30 – 17:00 (arrivals and coffee from 15:00)

If you would like to submit a question or have any specific areas that you would like the session to address, please send them to AFB at secretariat@foreignbanks.org.uk. You will receive details on how to join this session a week before the event.