Blog: CRR III 2026 — what non-resident taxpayers need to know about bank checks
Why property loans for Germans abroad became harder, which banks still finance and how to prepare optimally — from practice.
“The bank declined — without explaining why.” I 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 my 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.
- Conversion right as a knock-out criterion: since the EU Mortgage Credit Directive (2016), borrowers in non-euro countries have the right to convert their foreign-currency debt into the local currency. Many banks avoid this risk by declining the group entirely.
- 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.
Which constellations work well in 2026
✅ 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 %+).
⚠️ Difficult: 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”.
I 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 my network of 500+ banks and specialist institutions I also find the right solution for complex situations abroad — 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 make loans harder?
Can non-resident taxpayers still finance a property in Germany in 2026?
What about the UAE since 2025?
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