New Slovenian Banking Act and new regime for banks from third countries

1. General

The new Banking Act (ZBan 4) was published in the Official Gazette of the Republic of Slovenia on 25 February 2026 and will enter into force on 12 March 2026, with certain provisions applying at later dates.

ZBan 4 transposes Directive 2024/1619/EU (CRD VI) into Slovenian law and establishes an updated and comprehensive regulatory framework in several key areas, including:

• the provision of banking and financial services from third countries and the regulation of branches of third country institutions;
• systematic management of environmental, social and governance (ESG) risks within the prudential framework;
• requirements for the integration of ESG factors into strategies, internal processes and risk management;
• supervision of exposures to crypto assets;
• rules governing significant transactions;
• ensuring the integrity of supervisors (prevention of “revolving doors”); and
• stricter conditions for the appointment of members of the Governing Board of the Bank of Slovenia.

The new Banking Act also introduces changes in the areas of ancillary services, additional ECB powers, shareholder agreements and supervisory competences.

2. Third countries – new regime as of 11 January 2027

As of 11 January 2027, a revised regime for the provision of banking and financial services by banks and other financial institutions from third countries in Slovenia will apply, in line with Directive 2024/2619/EU (CRD VI).

Key elements of the new framework include:

• The requirement to establish a branch for the provision of banking and financial services in Slovenia remains in force.
• New exemptions are introduced, allowing the provision of certain services:
  • at the explicit request of the client;
  • to other credit institutions; and
  • to group companies.
• The new Banking Act provides for a transitional arrangement (grandfathering): the obligation to establish a branch does not apply to the provision of services related to contracts concluded before 11 January 2027. This represents a longer transition period than the one set out in CRD VI.