Market commentary · 23 May 2026

CRR III 2026: What changes for mortgages to buyers abroad?

Why the panel of lenders for Germans abroad narrowed, which banks still finance and how to prepare optimally for the bank checks, from practice. Usually the same thing is behind a bank declining without explanation: CRR III, the new EU capital regulation for banks, and its consequences for borrowers resident abroad.

What does CRR III change for mortgages for buyers abroad?

CRR III, the new EU capital regulation for banks, makes every loan cost the bank more of its own capital, and non-resident taxpayers count as higher risk. Banks that used to finance them with EU residence and euro income now restrict this group or demand more equity, not because credit standing is worse but because the risk weight has risen.

Which constellations work well in 2026

“The bank declined — without explaining why.” we hear that more often in 2026 than ever before.

Usually the same thing is behind it: CRR III, the new EU capital regulation for banks, and its consequences for borrowers resident abroad.

What CRR III is — and why it concerns you

The Capital Requirements Regulation III is the new EU framework for bank capital, phased in since 2024 and examined intensively by the banking supervisor in 2026. In short: every loan costs the bank more of its own capital than before. And not every loan equally — non-resident taxpayers count as higher risk in regulatory terms.

The concrete consequence: banks that used to finance non-residents with an EU residence and euro income without trouble are restricting this group in 2026 or demanding considerably more equity. Not because your credit standing is worse — but because the loan’s risk weight has risen.

What has changed in concrete terms — practice 2026

From our daily work with enquiries from elsewhere in Europe, the UAE and Switzerland:

  • More documents, longer assessment: what was decided in 2 weeks in 2021 takes 4–8 weeks today. Proof of income must be translated and certified, foreign payslips are often checked three times over.
  • Stricter residence logic: banks that used to accept any EU residence now require euro income as an additional condition. Anyone earning in Sweden, Denmark or Poland barely finds a German lender any more.
  • Foreign currency as a knock-out criterion: many lenders do not cover non-euro income in their credit policy at all and decline the group outright — others count it with a safety margin. That is decided in each bank’s own rulebook, not case by case.
  • UAE: easing since 2025: the EU removed the United Arab Emirates from the risk list in June 2025. That noticeably improves the situation for buyers in Germany with a UAE residence. More banks than in 2024 are willing to finance.
  • ✓ Readily financeable: EU residence + euro income (Germany, Austria, Spain, France, Netherlands, Belgium), Switzerland (cross-border-commuter rules), UAE since 2025, a high equity ratio (30 %+).
  • Narrower panel of lenders: non-euro EU countries (Sweden, Poland, Czechia), USA/Canada, Asian markets — need a specialist broker.
  • ✗ Barely possible any more at standard German banks: non-EU outside the UAE/Switzerland, combined with little equity.

How to prepare optimally

What makes the difference today: not finding the bank that says “yes” — but preparing the enquiry so that banks don’t have to say “we need more information”.

Which documents should the submission to the bank contain?

The submission contains proof of income for the last 3 years, complete property documents, a clear origin of equity with 3 months of bank statements and, for investors, a tenancy agreement or rental valuation.

We structure the submission so that all regulatory questions are answered on the first pass:

Proof of income for the last 3 years (certified translation if needed); Complete property documents incl. land-register extract, declaration of division, energy certificate; Clear origin of equity (3 months of bank statements); For investors: tenancy agreement or rental valuation.

Through our network of 650+ banks and specialist institutions we also find the right solution for cases with several international elements — usually faster than a direct bank enquiry.

Olga Nikushkina
Mortgage financing specialist · §34i · Since 2016

Frequently asked questions

What is CRR III and why does it narrow the panel of lenders?

CRR III is the new EU capital regulation for banks. It raises the risk weight for certain borrower groups — among them non-resident taxpayers. That makes each such loan more capital-intensive for the bank, which is why banks select more strictly or set higher equity requirements.

Can non-resident taxpayers still finance a property in Germany in 2026?

Yes — but the choice of banks is smaller than before 2023. With an EU residence, euro income and good credit standing it works well at specialist institutions. we know the banks that actively finance this constellation.

What about the UAE since 2025?

The EU removed the United Arab Emirates from the risk list in June 2025. That has markedly improved banks’ willingness for buyers in Germany with a UAE residence. The constellation is more financeable today than in 2024.

Request a financing analysis

A non-binding initial consultation is free — the commission is, as a rule, paid by the bank. we check 650+ banks plus all state funding programmes for your constellation.

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