If you are American or British and live in Portugal, you may have heard that new European Union banking rules could force your bank back home to close your account. With changes taking effect in January 2027, some overseas banks are already reviewing their relationships with customers who live in Europe.
For anyone relying on a US or UK bank account to receive a pension, transfer money to Portugal or provide financial evidence for a residency application, this raises understandable concerns.
The important thing to understand is that the new rules do not automatically require your bank to close your account. However, they may make it more difficult for certain banks outside the EU to continue providing services to customers living in Portugal.
The key dates you need to know
The changes come from the EU's sixth Capital Requirements Directive, commonly called CRD VI. The relevant provision is Article 21c of Directive 2013/36/EU, introduced by Directive (EU) 2024/1619.
There are four important dates:
- 9 July 2024: CRD VI entered into force following its publication in the EU Official Journal in June 2024.
- 10 January 2026: The deadline for EU Member States to adopt and publish national legislation implementing the directive.
- 11 July 2026: The important cut-off date for existing contracts. Certain contracts entered into before this date benefit from protection under Article 21c(5).
- 11 January 2027: The new requirements governing the provision of core banking services by banks outside the EU begin to apply.
The deadline attracting the most attention is 11 January 2027, but it is important not to confuse the legal implementation date with the date an individual bank might decide to change its services or close an account.
Banks can make commercial decisions before that date. Equally, some customers may be able to continue using existing accounts after it.
What does the new EU banking rule actually say?
Article 21c addresses the provision of banking services by financial institutions established outside the European Union.
These are described as third-country undertakings. They include relevant banks based in the United States and the United Kingdom.
Under the new framework, a bank established outside the EU that wants to provide certain core banking services to customers established or situated in an EU Member State generally needs an appropriately authorised branch in that Member State. Services can also be provided through an appropriately authorised EU subsidiary, subject to the applicable rules.
The core banking services covered include:
- Accepting deposits and other repayable funds.
- Providing loans, including mortgages and consumer credit.
- Providing guarantees and financial commitments.
For example, an American bank serving someone who now lives in Portugal may need to assess whether continuing that banking relationship is permitted under the new requirements.
Establishing and operating a licensed banking branch in another country involves significant regulatory obligations and costs. Some banks may therefore decide that continuing certain services for customers living in Portugal is not commercially worthwhile.
That is where the possibility of account closures comes from. It is a potential consequence of how individual banks respond to the legislation, not an instruction requiring every foreign bank account to be closed.
You can read the legislation in the official text of Directive (EU) 2024/1619 on EUR-Lex.
Does this affect existing bank accounts?
Article 21c(5) contains an important protection for existing contracts.
It states that the new requirements apply without prejudice to existing contracts entered into before 11 July 2026, preserving clients' acquired rights.
Article 21c(5) protects acquired rights under existing contracts entered into before 11 July 2026. An account opened before that date may therefore benefit from protection for its existing contractual arrangements, but that protection does not necessarily extend to new products, new contracts or later changes, and it does not stop a bank from lawfully ending the relationship.
However, this does not mean the bank must maintain your account indefinitely.
A bank may still close an account for commercial or compliance reasons, provided it acts in accordance with the applicable law and account terms. Changes to existing arrangements may also require a separate assessment.
According to the 21 October 2026 report by The Connexion, Chase indicated that it considers the grandfathering provision relevant to commercial banking clients rather than consumers. Personal banking customers should therefore not rely on this provision as a guarantee that their accounts will remain open.
Accounts or loans opened on or after 11 July 2026 do not benefit from that same protection for pre-existing contracts.
The practical advice: If you already have an account, do not assume it will close. But do not assume it is guaranteed to remain open either. Ask your bank to confirm its position in writing.
Are there exceptions to the rules?
Yes. Article 21c provides several exceptions, although they should not be treated as blanket exemptions for anyone living abroad.
- Reverse solicitation: In certain circumstances, a customer who approaches a foreign bank entirely on their own initiative may receive services without triggering the branch requirement. This exception is narrowly defined and cannot simply be used by banks to market additional products to EU residents.
- Interbank and intragroup transactions: Certain transactions between financial institutions or entities within the same corporate group are exempt.
- Investment services: Services covered by the EU's MiFID investment framework, along with related ancillary services, are generally outside this particular requirement.
This means that an investment or brokerage account is not necessarily affected in the same way as an ordinary current or savings account. Cash accounts used for related investment services may also fall outside the restriction.
However, investment providers can have their own policies about serving customers who live overseas. Americans in particular should confirm whether their brokerage or retirement account provider accepts customers resident in Portugal.
CRD VI is a directive rather than a directly applicable regulation. Individual EU countries implement its requirements through national legislation, and further guidance may influence how particular situations are treated.
In March 2026, the European Commission listed Portugal among the Member States that had not yet fully transposed the directive. The details of how the rules will operate in Portugal may therefore still be settled. The date of 11 January 2027 remains the application date established by the directive. See the European Commission's announcement of 27 March 2026.
Who could be affected if they live in Portugal?
The central issue is where you live or receive the banking service, not which passport you hold.
An American or British citizen living in Portugal can fall within the scope of the new rules. An EU citizen living in the United States is not automatically covered simply because they hold an EU passport.
| Your situation | What it means |
|---|---|
| American living in Portugal with a US bank account | Potentially affected. Ask whether your US bank will continue serving Portugal residents after January 2027 and whether your existing account can remain open. |
| Briton living in Portugal with a UK bank account | Potentially affected. UK banks are treated as third-country banks following Brexit, so similar considerations apply. |
| American or Briton planning to move to Portugal | Check your bank's non-resident policy before relocating. A change of residence may change which banking services are available. |
| Resident of Portugal with a Portuguese bank account | Not affected by this particular restriction on third-country banking services. Your Portuguese bank remains subject to its normal regulatory requirements. |
| Person with a US or UK investment or brokerage account | Investment services are generally outside Article 21c, but the provider may apply its own overseas-resident restrictions. |
| Person visiting Portugal or owning property here without being resident | Simply visiting or owning property does not automatically put you in the same position as a Portugal resident. Your location when receiving services and the nature of those services can still matter. |
The new rules do not prohibit Portugal residents from holding accounts abroad, and they do not introduce new tax reporting requirements. Existing Portuguese, US and UK tax and reporting obligations continue to apply separately.
Are American banks already closing accounts?
There have been reports from American customers living in Europe who have received communications from their US banks about changes to the services available to overseas residents.
The Connexion reported on 21 October 2026 that Chase customers living in France began receiving letters on 1 October 2026 informing them that their accounts would be closed in December 2026. According to the report, Chase confirmed that its primary deposit products, including checking and savings accounts, were affected, along with credit cards attached to those accounts.
Importantly, the report specifically concerns Chase customers living in France. It has not been established whether the same account closure arrangements apply to Chase customers living in Portugal or elsewhere in Europe.
Expat advisers in countries including France and Germany have also reported concerns about US banks reviewing accounts held by residents of European countries.
However, an important distinction needs to be made:
We have not verified a publicly announced, bank-wide Chase policy requiring all customers living in Europe to close their accounts.
Bank letters can contain different instructions. Some may request updated residency information or verification documents, while others may give an account closure date. Read any communication carefully and confirm in writing whether your account is affected and, if so, when it will close. Do not assume that a deadline for providing information is necessarily the closure date.
If you receive a letter, contact your bank and ask:
- Is my specific account scheduled to close?
- Is the deadline for address verification or for account closure?
- What is the actual closure date, if one has been set?
- Can I maintain my existing account as a resident of Portugal?
- Will deposits, transfers, cards and online banking continue to operate?
Request written confirmation rather than relying only on a telephone conversation.
Different banks may interpret their obligations and make different commercial decisions. Even two customers of the same bank may have different outcomes depending on the type of account, when it was opened and their circumstances.
What about British bank accounts after Brexit?
For British residents of Portugal, the situation is particularly relevant because UK banks have already been dealing with restrictions on providing services to EU residents since Brexit.
When the United Kingdom left the EU's financial services passporting arrangements, some British banks decided to withdraw services from customers living in certain EU countries.
Some UK banking providers notified overseas customers of account closures following Brexit, including customers resident in Portugal. Other providers also reviewed or restricted certain services for EU-resident customers.
Those earlier decisions were related to Brexit rather than the new CRD VI requirements. However, they demonstrate that banks sometimes respond to cross-border regulatory obligations by limiting the countries in which they serve customers.
From January 2027, British banks face the same new Article 21c framework as other third-country banks.
If you are British and living in Portugal, check your UK bank's current policy even if you have successfully maintained your account since Brexit.
Pay particular attention if you use a UK account for:
- Receiving your UK State Pension or private pension.
- Receiving rental income from property in Britain.
- Paying a UK mortgage, insurance or household bills.
- Maintaining UK credit cards and direct debits.
- Transferring money to Portugal for living expenses.
You may be able to retain your UK account, but eligibility should be confirmed with your bank rather than assumed.
What happens to your pension or Social Security payments?
One of the biggest concerns for retirees in Portugal is what would happen if their US or UK bank account closed while pension payments were still being deposited into it.
The good news is that both American Social Security and the UK State Pension can be paid directly into qualifying bank accounts in Portugal.
US Social Security payments into a Portuguese bank account
The US Social Security Administration operates an International Direct Deposit programme that includes Portugal.
This allows eligible beneficiaries to receive their US Social Security benefits directly into a Portuguese bank account, with payments converted into euros.
To arrange this, the relevant document is Form SSA-1199-PE, Direct Deposit Sign-Up Form (Portugal).
You can obtain the form directly from the US Social Security Administration.
The process involves providing the required personal and Portuguese bank account information. The form also includes a section for the receiving bank to complete.
Completed forms can be submitted through the Federal Benefits Unit at the US Embassy in Lisbon. The Social Security Administration's international operations office can also assist with international payment arrangements.
Do not close your existing US account until you have confirmed that Social Security payments are arriving successfully in the new Portuguese account. This is also the advice given on the SSA form.
If you receive a private pension or withdrawals from a 401(k) or IRA, contact the relevant provider separately. Some providers have restrictions or procedures for payments to overseas residents.
It may also be useful to keep an eligible US account for obligations such as credit cards, mortgages, taxes or insurance, where your bank permits this.
UK State Pension payments into a Portuguese bank account
British retirees also have options.
According to the UK government, the UK State Pension can be paid into either:
- A bank or building society account in the United Kingdom.
- A bank account in the country where you live, including Portugal.
When paid into a Portuguese account, the State Pension can be converted into euros. Exchange rates and applicable conversion charges affect the amount received.
You can find the official guidance at GOV.UK: State Pension if you retire abroad.
If you wish to change your payment arrangements, contact the International Pension Centre and provide the required banking details.
As with US Social Security, arrange the change before closing your existing account and confirm that payments are reaching the new destination.
For workplace and private UK pensions, the available payment options depend on the individual pension scheme or provider. Confirm whether payments can be sent directly to Portugal and whether any additional documentation or charges apply.
If you are planning to retire in Portugal, you may also find our guide to retirement income in Portugal useful.
What does this mean for D7 and D8 visa applications?
The new banking rules are particularly important for Americans and Britons preparing to move to Portugal.
Applicants for the Portugal D7 visa, commonly used by retirees and people with qualifying passive income, must demonstrate that they have sufficient financial resources to support themselves.
Similarly, applicants for the Portugal D8 visa, used by qualifying remote workers and digital nomads, must provide evidence of their income and financial circumstances.
The digital nomad visa is widely known as the D8, but some consular checklists, including those used by the Portuguese Consulate General in London, list it under a different visa code. Always follow the checklist issued by your own consulate.
Portuguese consulates and, where relevant, AIMA examine documentation relating to income and means of subsistence. Portuguese bank account requirements vary by visa category and consulate. Some D7 checklists expressly request a statement from a Portuguese bank account, while digital nomad (D8) checklists may accept financial evidence from accounts held elsewhere. Follow the current checklist issued by your consulate.
The exact financial evidence required can vary according to the visa category, consulate and individual circumstances.
For a detailed explanation, see our guide to the financial requirements for moving to Portugal.
Why your home country bank account still matters
Even when applicants open a Portuguese bank account, they may continue relying on an account in their home country.
For example, a D7 applicant from the United States might receive Social Security and pension income into an American account and then transfer money to Portugal.
A British applicant might receive rental or pension income into a UK account while preparing a D7 application.
A D8 applicant might use a US or UK account to receive employment income from an overseas employer.
If that account is restricted or closed unexpectedly, several problems can arise:
- Access to funds needed for a visa application could be temporarily interrupted.
- Salary, pension or rental income payments may need to be redirected.
- Bank statements and financial documentation may become harder to obtain.
- Transfers to a Portuguese bank account may be delayed.
- Applicants may need to provide updated financial evidence to a consulate or AIMA.
None of these issues necessarily prevents someone from qualifying for a Portuguese visa. However, they can create avoidable administrative complications, particularly when an appointment or document submission deadline is approaching.
Why opening a Portuguese bank account early makes sense
For most people preparing to relocate, establishing Portuguese banking arrangements early is a sensible precaution regardless of the new EU rules.
Opening an account generally requires a Portuguese tax identification number, known as a NIF, along with the identification, address and financial documents requested by the bank.
If you have not obtained a NIF yet, see our guide to Portuguese NIF numbers.
Be aware that Portuguese banks have also become more demanding when opening accounts for some non-resident customers. Requirements can vary between banks and according to nationality, residence and financial circumstances.
We explain some of these developments in our article on Portuguese banks increasing requirements for non-resident accounts.
It is therefore worth allowing time for account opening, document checks and international money transfers rather than leaving everything until your visa appointment.
Our recommendation is to get your NIF and Portuguese banking arrangements organised as early as practical, while keeping your home country account operational for as long as you legitimately need it.
Can you keep your bank account by using a US or UK address?
Some people living overseas continue to use a family member's address or another address in their home country for correspondence.
There is an important distinction between keeping a legitimate mailing address and telling a bank that you reside somewhere you no longer live.
If you have moved permanently to Portugal, providing an American or British address as your residential address simply to maintain an account may breach the bank's terms and conditions.
It can also create problems involving customer identification, tax residency declarations and regulatory compliance.
Banks may ask customers to confirm their actual country of residence and provide documentary evidence.
Do not misrepresent where you live to avoid a bank's overseas-resident restrictions.
Instead, explain your circumstances to the bank, ask whether you can retain the account as a Portugal resident, and request details of any permitted alternatives.
Checklist: What to do if you already live in Portugal
If you are an American or British resident of Portugal and still use a bank account back home, we recommend taking the following steps.
- Check for letters or messages from your bank. Review your post, email and secure online banking messages for requests to verify your address or information about overseas customers.
- Contact your bank in writing. Ask whether it intends to continue providing services to residents of Portugal after 11 January 2027 and whether any earlier changes are planned. Confirm the position for your specific account.
- Clarify any deadline. If you have received a letter, establish whether the stated date is for providing documents, updating your address or closing the account. Request the actual closure date in writing if closure is planned.
- List everything connected to the account. Include pensions, Social Security, salary payments, rental income, direct debits, subscriptions, mortgages, credit cards, insurance and tax payments.
- Make sure you have a suitable Portuguese bank account. Check that it can receive the payments you need and that you can access your money without depending entirely on your overseas account.
- Redirect income payments if necessary. If your existing bank is withdrawing services, arrange US Social Security or UK State Pension payments into Portugal where appropriate. Contact private pension and employment income providers separately.
- Consider additional payment options. Multi-currency services such as Wise and Revolut are commonly used by expats for international transfers and currency management. Check each provider's terms, regulatory status, account features and eligibility before relying on it as a replacement for your existing bank.
- Keep access to essential home country services where possible. If your bank allows you to maintain a US or UK account or card as an overseas resident, this may be useful for obligations that are difficult to manage from a Portuguese account.
- Keep copies of your financial records. Download relevant statements and payment confirmations while you still have access to the account, particularly if you may need them for tax purposes or Portuguese residency procedures.
There is no need to rush into closing a perfectly functioning bank account simply because you have heard about CRD VI. The aim is to establish your options and avoid being surprised by a bank's decision.
Checklist: What to do if you are moving to Portugal soon
If you have not relocated yet, you are in a good position to organise your banking before it becomes more complicated.
- Obtain your Portuguese NIF. This is normally one of the first steps towards opening a Portuguese bank account. You can read about our Portuguese NIF assistance service.
- Arrange a Portuguese bank account early. Depending on your circumstances and the bank's requirements, this may be possible before arriving in Portugal. Our Portuguese bank account opening service explains how we can assist.
- Ask your current bank about its overseas-resident policy. Before updating your address, find out whether the bank serves customers in Portugal and whether it expects to make changes in 2027. You should still report your residence accurately as required by the bank.
- Plan how your income will reach Portugal. Determine whether pensions, salary or other income can continue to be deposited into your existing account or whether new arrangements will be necessary.
- Schedule major transfers carefully. If you are moving funds to support a D7 or D8 application, allow time for bank verification, international transfer processing and obtaining suitable account statements.
- Do not leave changes until your visa appointment. Banking arrangements can involve document reviews and additional checks. Having your financial evidence ready early can help avoid unnecessary difficulties.
Common Questions About the New EU Banking Rules
Will my US bank account be closed because I live in Portugal?
Not automatically. Article 21c changes how banks outside the EU can provide certain services to people in Portugal from 11 January 2027, but each bank decides how to respond. Ask your bank for written confirmation about your particular account.
Does the new rule affect British bank accounts too?
Yes. Since Brexit, UK banks are treated as third-country banks for this purpose. British residents of Portugal should check their bank's policy just as American residents should.
Can I keep a US or UK bank account after moving to Portugal?
Yes, the EU rule does not ban Portugal residents from owning foreign bank accounts. Whether a particular bank will continue servicing your account depends on its legal arrangements, product terms and account policy.
Is an account opened before 11 July 2026 safe?
An account opened before 11 July 2026 may benefit from protection for existing contractual arrangements under Article 21c(5), but this is not a guarantee. Protection may not cover new products or later changes, and banks can lawfully end relationships. Chase has reportedly indicated that it considers the provision relevant to commercial clients rather than consumers.
Will CRD VI affect my US Social Security or UK State Pension?
The rule does not cancel your pension entitlement. US Social Security can be paid into an eligible Portuguese bank account through international direct deposit, and the UK State Pension can also be paid to a bank in Portugal. Arrange changes early to avoid payment disruption.
Do I need a Portuguese bank account for a D7 or D8 visa?
Requirements vary by visa category and consulate. Some D7 checklists expressly ask for a statement from a Portuguese bank account, while digital nomad (D8) checklists may accept financial evidence from accounts held elsewhere. Follow the current checklist issued by your consulate.
Does changing my bank address to a US or UK address avoid the rule?
Do not declare an address as your residence if you no longer live there. Keeping a legitimate correspondence address is different from misrepresenting your place of residence, which can breach bank terms and create compliance or tax problems.
How Visas.pt can help
At Visas.pt, we help Americans, Britons and other international clients prepare for their move to Portugal, including obtaining a Portuguese NIF and arranging a Portuguese bank account. Whether you are preparing a D7 or D8 visa application or simply want to establish Portuguese banking arrangements before relocating, our team can assist with the relevant procedures and documentation. Starting early can help ensure your financial arrangements are in place when you need them.
Final thoughts
The arrival of CRD VI does not mean every American or British resident of Portugal will lose access to their bank account back home.
What it does mean is that banks outside the EU face new requirements when providing certain services to customers in EU countries from January 2027.
Some banks may continue serving existing customers. Others may introduce restrictions or decide to end particular banking relationships.
For residents of Portugal, particularly retirees and those preparing visa applications, the most sensible approach is straightforward: confirm your home bank's policy, organise reliable Portuguese banking arrangements, and plan any changes to income payments before they become urgent.
You do not need to make assumptions about what your bank will do. You need to ask the right questions and be prepared for the answer.
Disclaimer: This article provides general information only and does not constitute legal, tax or financial advice. Banking policies and national implementation of EU rules may change. Check your circumstances with your bank and a suitably qualified adviser before making financial decisions.