However, the law does not automatically require expatriates to close their existing US or UK bank accounts.
The actual consequences depend on the bank, the services provided, the date the banking relationship began and the application of specific legal exemptions.
For some expatriates, the biggest change may come not from the legislation itself, but from how international banks decide to implement it.
What Is Changing in European Banking Law in January 2027?
The European Union has introduced new banking requirements through Directive (EU) 2024/1619, commonly known as the Capital Requirements Directive VI (CRD VI).
One of its most significant provisions for expatriates is Article 21c, which regulates the provision of certain banking services by financial institutions established outside the European Union.
Under the new framework, non-EU banks that provide certain core banking services to customers located in EU Member States will generally need an appropriately authorised presence within the relevant Member State, unless a specific exemption applies.
The services covered include:
- Accepting deposits and other repayable funds.
- Providing loans, including consumer credit and mortgages.
- Issuing guarantees and certain financial commitments.
The relevant rules are scheduled to apply from 11 January 2027.
Importantly, these requirements primarily regulate how banks provide services across borders. They do not introduce a general prohibition on EU residents holding bank accounts outside Europe.
Official source: Directive (EU) 2024/1619, Article 21c.
Can Americans Living in Portugal Keep Their US Bank Accounts After January 2027?
Yes, potentially. The new legislation does not automatically prohibit US citizens residing in Portugal from maintaining existing US bank accounts.
Nevertheless, American banks may review their international customer relationships and decide to restrict or discontinue certain services for customers resident in the EU.
For example, an American citizen who moved to Portugal in 2024 and continues to maintain a checking account with a US bank might receive a notification stating that the bank can no longer provide certain services to EU residents.
This could involve:
- Restrictions on opening additional accounts.
- Limitations on accessing new banking products.
- Changes to lending facilities.
- Requests to update residential addresses and tax residency information.
- In some cases, termination of the banking relationship.
These measures are not necessarily mandated individually by CRD VI. They may reflect a bank’s own interpretation of regulatory requirements, compliance costs or commercial risk policies.
Consequently, American expatriates should distinguish between what European legislation requires and what their individual bank chooses to implement.
Will Chase, Bank of America or Other US Banks Close Accounts Belonging to Expats?
There is no general EU rule requiring Chase, Bank of America, Wells Fargo or every other US bank to close accounts belonging to Americans living in Portugal.
However, banks may adopt different policies regarding customers with residential addresses outside the United States.
Some financial institutions may continue servicing existing accounts while restricting new products. Others may decide that maintaining certain cross-border banking relationships is no longer commercially viable.
If you receive a notification from your US bank referring to the new European banking rules, do not automatically assume that your account must legally be closed.
Instead, request written clarification regarding:
- Whether the bank intends to close your existing account or restrict specific services.
- The effective date of any restrictions.
- Whether your existing account falls within the transitional protection under Article 21c(5).
- Whether any exemption allows the bank to continue providing the relevant services.
- The available procedures and deadlines for transferring funds.
Important: We have not verified a publicly announced, bank-wide policy requiring Chase or other major US banks to close every account held by an EU-resident American.
Any account-specific notification should therefore be assessed individually.
Are Existing US and UK Bank Accounts Protected Under the New Law?
One of the most important aspects of CRD VI is the protection of certain pre-existing banking contracts.
Article 21c(5) provides that the new branch requirement is without prejudice to existing contracts entered into before 11 July 2026.
This provision is commonly referred to as a grandfathering clause.
Example: An American Who Opened a US Bank Account in 2018
Consider an American citizen who:
- Opened a US checking account in 2018.
- Relocated permanently to Portugal in 2025.
- Became a Portuguese tax resident.
- Continued using the US account for receiving income and paying expenses.
Because the banking contract predates 11 July 2026, the existing relationship may benefit from the transitional protection established by Article 21c(5).
This is a potentially important distinction when evaluating a bank’s claim that CRD VI requires an account to be closed.
However, the protection should not be interpreted as an unconditional right to retain an account indefinitely.
Banks may still have contractual rights to terminate banking relationships, subject to the applicable legal requirements. New services or materially amended contracts may also require separate consideration.
Our recommendation: If your bank proposes closing an account opened before 11 July 2026, ask whether it has assessed the grandfathering provision before making alternative arrangements.
What Is Reverse Solicitation, and Can It Help Expats Keep Their Accounts?
CRD VI includes another relevant exception known as reverse solicitation.
Under Article 21c(2), certain banking services can be provided by a non-EU institution when a customer located in the EU approaches that institution entirely on their own initiative.
In practical terms, the exception recognises that customers may independently seek financial services from institutions outside the European Union.
However, reverse solicitation is subject to limitations.
It does not provide a blanket authorisation for foreign banks to actively market banking products to EU residents.
It also does not necessarily protect every new banking product or service requested after the initial relationship is established.
For expatriates, reverse solicitation may be relevant where they independently request the continuation or provision of a particular banking service.
Whether the exception applies requires an assessment of the facts and the bank’s regulatory position.
It should not be treated as an automatic guarantee that an existing US or UK account can remain open.
Does the New Banking Law Also Affect British Expats Living in Portugal?
Yes. UK-based banks may also be affected because the United Kingdom is no longer an EU Member State.
Following Brexit, UK banking institutions are generally treated as third-country institutions for the purposes of relevant EU financial services regulation.
British expatriates resident in Portugal may therefore experience similar challenges to those faced by American expatriates.
For example, a British retiree living in the Algarve who maintains a UK current account for pension payments and property expenses may find that the bank reviews the services available to customers with EU residential addresses.
The consequences will depend on the banking institution, its regulatory arrangements and the contractual relationship.
CRD VI should also be distinguished from UK banks’ existing post-Brexit policies, which may independently restrict services to customers resident in Europe.
What Should Expats in Portugal Do Before January 2027?
If you currently live in Portugal and maintain accounts with banks located outside the EU, consider the following steps.
Step 1 — Review Your Existing Banking Relationships
Identify every account you maintain outside the European Union.
For each account, record:
- The financial institution and country.
- The original account opening date.
- The type of account and services used.
- The residential and tax addresses registered with the bank.
- Any recent communication about restrictions affecting overseas customers.
This information will help determine which accounts may require attention.
Step 2 — Ask Your Bank Whether Your Account Will Be Affected
Contact your bank directly and ask whether its policies for EU-resident customers will change from January 2027.
If your account was opened before 11 July 2026, specifically ask about the protection for existing contracts under Article 21c(5).
Request written confirmation of any deadline or action required.
Step 3 — Consider Maintaining an Alternative Banking Arrangement
Even where existing accounts can legally remain open, expatriates may benefit from having alternative banking arrangements.
Depending on individual circumstances, possible options include:
- Maintaining a Portuguese bank account for everyday expenses.
- Using a regulated multicurrency payment provider for international transfers.
- Investigating US financial institutions that expressly accept qualifying overseas customers.
- Maintaining separate accounts for US and European financial obligations.
When comparing providers, verify their eligibility requirements, deposit protection arrangements, currencies, fees and restrictions.
A payment institution or electronic money provider is not necessarily equivalent to a traditional deposit-taking bank.
Step 4 — Review Recurring Income and Payments
Consider whether your existing account receives or processes:
- US Social Security benefits.
- Private retirement pensions.
- Dividends or investment income.
- Rental income from US or UK properties.
- Salary or freelance payments.
- Mortgage repayments.
- Tax payments or refunds.
If the bank confirms that an account will be closed, update payment instructions with sufficient time to avoid interruptions.
Step 5 — Review Your Portuguese and Foreign Tax Reporting Obligations
Changing your banking arrangements may also require reviewing your international tax reporting obligations.
This is particularly important for US citizens, who can remain subject to US tax and financial account reporting requirements while living abroad.
Does Moving Money From a US Bank to Portugal Trigger Portuguese Tax?
Generally, no. Transferring your own existing savings from a US bank account to a Portuguese bank account does not, by itself, create taxable income in Portugal.
The tax treatment depends on the underlying nature and origin of the funds, not simply on the act of transferring them between bank accounts.
Example: Transferring $100,000 From the US to Portugal
An American citizen becomes a Portuguese tax resident in 2026.
They have $100,000 in savings accumulated before moving to Portugal.
In 2027, their US bank requests that they close their account.
They transfer the balance to a Portuguese bank.
Provided the transferred amount represents their own existing savings, the transfer itself is generally not subject to Portuguese personal income tax.
However, any interest generated by the account may need to be declared, depending on the taxpayer’s circumstances.
Likewise, income from employment, pensions, investments or business activities does not become tax-free merely because it was initially deposited into an American account.
For Portuguese tax residents, worldwide income is generally within the scope of Portuguese IRS, subject to applicable exemptions, double taxation treaties and special tax regimes.
The fundamental principle is that the movement of money and the taxation of income are two separate matters.
Do US Bank Accounts Have to Be Declared in Portugal?
Yes. Portuguese tax residents are generally required to identify foreign bank and securities accounts in their annual Portuguese personal income tax return, even when those accounts generate no income.
This obligation is established under Article 63-A of the Portuguese General Tax Law (Lei Geral Tributária) and is fulfilled through Box 11 of Annex J (Anexo J) of the annual IRS return.
For example, an American resident in Portugal who maintains:
- A checking account with Chase.
- A savings account with another American bank.
- A qualifying foreign securities account.
Will generally need to identify those accounts in Annex J, subject to the applicable ownership, beneficiary or account operating authority rules.
This disclosure obligation is separate from the taxation of interest, dividends or capital gains.
Failure to earn income from an account does not automatically eliminate the reporting requirement.
The Portuguese Tax Authority confirms that foreign accounts must be identified even where they have generated no income.
What About FBAR and FATCA Reporting for Americans Living in Portugal?
US citizens should also consider their continuing US reporting obligations.
Opening additional accounts in Portugal may create or increase obligations under:
FBAR (FinCEN Form 114)
US persons generally must file an FBAR when the aggregate value of their foreign financial accounts exceeds $10,000 at any time during the calendar year, subject to the applicable financial interest or authority requirements.
Form 8938 (FATCA reporting)
Certain US taxpayers must disclose specified foreign financial assets when their value exceeds the relevant reporting thresholds.
Those thresholds depend on filing status, residence and other circumstances.
Importantly, the FBAR and Form 8938 requirements are distinct from the Portuguese Annex J reporting obligation.
A US citizen living in Portugal may therefore have financial account reporting obligations in both countries.
These reporting rules already exist. CRD VI does not itself introduce new US FBAR or FATCA filing requirements.
What Happens if Your US Bank Closes Your Account While You Live in Portugal?
An account closure does not necessarily create an immediate tax charge, but it can cause practical difficulties.
Possible consequences include:
- The need to redirect pension and Social Security payments.
- Changes to recurring direct debits and automated transfers.
- International transfer costs and foreign exchange spreads.
- Difficulties managing US property expenses or tax payments.
- Additional financial account reporting obligations.
- Potential disruption to investment or borrowing arrangements.
Particular care should be taken when the account is linked to retirement products, investment accounts or other arrangements that may have tax consequences if liquidated.
Transferring cash from a bank account is not necessarily equivalent to selling investments or withdrawing funds from a retirement account.
Expats should therefore avoid unnecessary investment liquidations or pension withdrawals simply to comply with a bank’s administrative request.
Frequently Asked Questions: EU Banking Rules for Expats in 2027
1. Will the EU ban American bank accounts in January 2027?
No. CRD VI does not establish a general ban on American citizens living in the EU holding US bank accounts. It regulates the cross-border provision of certain banking services by non-EU institutions.
2. Do I have to close my Chase account if I live in Portugal?
Not automatically. Whether Chase will continue servicing your account depends on its policies, your contractual arrangements and the applicable regulatory framework. Request written clarification before taking action.
3. Can I keep a US bank account with a Portuguese residential address?
Potentially, yes. However, each bank applies its own eligibility and compliance policies. You should provide accurate residential and tax residency information and confirm whether the institution accepts EU-resident account holders.
4. Are bank accounts opened before July 2026 protected?
Article 21c(5) protects existing contracts entered into before 11 July 2026 from the new branch requirement. This does not eliminate a bank’s separate contractual rights or guarantee access to every future service.
5. Does the law affect Americans who are not Portuguese tax residents?
The regulatory analysis focuses on where the customer is established or situated and where the relevant banking services are provided. Portuguese tax residency is not, by itself, the decisive legal test.
6. Does the law apply to British bank accounts?
Yes, relevant UK banks are generally considered third-country institutions under EU financial services law. The impact depends on the services provided and applicable exemptions.
7. Is moving savings from the US to Portugal taxable?
Generally, transferring your own existing savings is not taxable income. However, interest, investment gains, pension withdrawals and other underlying transactions may have separate tax implications.
8. Do I need to declare my US bank accounts to the Portuguese Tax Authority?
If you are a Portuguese tax resident, you generally need to identify foreign bank and securities accounts in Box 11 of Annex J, even when they produce no income.
9. Will this law affect my US Social Security or pension income?
CRD VI does not directly change the tax treatment or entitlement rules for Social Security or private pensions. However, bank account restrictions may require you to update payment instructions.
10. What should I do if my bank tells me to close my account?
Ask for the precise legal and contractual grounds, the relevant deadline, and confirmation of whether grandfathering or another exemption has been considered. Arrange an alternative account where necessary and review any resulting international tax reporting obligations.
What Is the Position in Portugal?
The CRD VI framework is an EU directive, requiring implementation through national legislation.
Member States were required to transpose the directive by 10 January 2026, with the relevant new third-country banking requirements scheduled to apply from 11 January 2027.
According to the European Commission’s transposition monitoring information updated on 7 August 2026, Portugal was among the Member States that had not yet communicated transposition measures.
This does not necessarily mean that Portugal had adopted no relevant measures, and the national implementation position should be reviewed before making definitive conclusions about enforcement.
For expatriates, the practical consequences will also depend on how banks interpret the final regulatory framework and adjust their services.
Final Thoughts: Preparation Matters More Than Panic
The new European banking rules are an important development for international residents of Portugal, particularly those who continue to rely on financial institutions in the United States or United Kingdom.
Nevertheless, the legislation should not be interpreted as an automatic requirement to close all non-EU bank accounts.
Existing contractual protections, regulatory exceptions and individual bank policies can produce significantly different outcomes.
At GoalSeek, we recommend that expatriates review their banking arrangements, confirm their tax residency status and ensure that any restructuring of international accounts is coordinated with their Portuguese and foreign tax obligations.
Moving to Portugal does not necessarily mean giving up access to financial services in your home country. It does mean understanding how international banking regulation and cross-border taxation interact.
Need Help Understanding Your Financial and Tax Obligations in Portugal?
GoalSeek | Tax & International Advisory
GoalSeek is a Portugal-based tax advisory firm specialising in international taxation, expatriate relocation and tax compliance for individuals with financial interests across multiple jurisdictions.
We regularly assist international residents, including US and UK nationals, with:
- Portuguese tax residency assessments.
- Portuguese income tax reporting.
- Foreign bank account declarations.
- International income and investment taxation.
- US–Portugal tax coordination.
- Cross-border tax planning before and after relocation.
If you are concerned about how changes to your international banking arrangements may affect your Portuguese tax position, our team can help you assess the relevant tax implications and reporting requirements.
Contact GoalSeek: www.goalseek.pt
Please note: GoalSeek provides tax advisory and compliance services. Decisions regarding account eligibility, banking authorisations and account closures must be confirmed with the relevant financial institution. Legal disputes concerning banking contracts may require advice from a suitably qualified banking lawyer.
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