What has changed regarding the appointment of bank board members under CRD VI?

CRD VI, Directive (EU) 2024/1619, was to be implemented by January 10, 2026. Little has changed with regard to the substantive requirements for suitability and reliability. However, there have been significant changes to the procedure, and in practice, that is the more important aspect.

In Austria, credit institutions must conduct and document their own fitness assessment before making an appointment; if a prerequisite is no longer met at a later date, the person must be removed from office (Section 5(1a) and (1b) and Section 28a(6a) and (6b) of the Austrian Banking Act (BWG)). In practice, this was already the case; now it is enshrined in law. The most significant change in practical terms is another: At large institutions, the suitability application for managing directors and supervisory board chairs must be submitted as soon as there is a clear intention to appoint them (Section 73(7) of the Austrian Banking Act (BWG)).

In Germany, the BRUBEG – enacted by the Bundestag at the end of January 2026 – implements the directive in the KWG. Under this regulation, the appointment of a managing director at large credit institutions must be reported no later than 30 business days before the start of the term of office. Any subsequent change in reliability, professional competence, or availability must be reported immediately.

Different wording, but the same effect: The point in time at which an appointment becomes visible to regulators is moved up. Anyone who relies on clarifying outstanding issues after the decision has been made is working against the spirit of the regulatory framework.

For recruitment practice, this means two things. The documentation is prepared during the search, not afterward. And the point at which it makes sense to involve a recruitment consultancy is moved up by several weeks.

Groups with subsidiaries in both countries should work through the timeline together. The deadlines are structured differently and cannot be directly converted into one another.