Alerts Archive

LMA publishes paper examining the impacts of Article 21c of CRD VI

The LMA is pleased to publish our new LMA Regulatory Insights paper examining the impact of Article 21c of CRD VI on cross‑border corporate lending into the EU.

From 11 January 2027, Article 21c will fundamentally reshape cross‑border lending into the EU. Given that contracts entered into after 11 July 2026 cannot benefit from grandfathering, significant uncertainty remains. 

The Directive leaves several key questions unanswered – including how third‑party involvement interacts with the reverse solicitation exemption, how secondary market activity should be treated, and how lifecycle events affect contracts that benefit from grandfathering. In parallel, most Member States have yet to complete national transposition, raising the prospect of divergent approaches across the EU.

Against this backdrop, the paper examines the impact of Article 21c on everyday loan markets activity, including:

• co‑borrowing structures;
• sponsored and syndicated transactions;
• secondary market activity (including participations, assignments and novations); and
• lifecycle events and the circumstances in which grandfathering may be lost.

The paper considers how the market may reasonably respond in practice where there is no EU‑level or consistent Member State guidance, while recognising that outcomes will remain jurisdiction‑specific and subject to local legal analysis.

Click here to access our Insights paper.