Chloe Barrowman

On July 7, 2026, Claudia Buch, chair of the European Central Bank’s (ECB) Supervisory Board, addressed a letter to the CEOs of all significant institutions (SIs) supervised under the Single Supervisory Mechanism (SSM), calling for immediate and proactive measures to address the escalating cybersecurity threats enabled by frontier artificial intelligence (AI) models.

AO A&O Shearman More A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world.

Why action is needed now From January 11, 2027, non-EEA banks will be prohibited from providing core banking services in the EEA unless they establish an authorized branch in each relevant member state, or an exemption applies. See our note on the new licensing requirements under Article 21c of the EU’s sixth capital requirements Directive (Directive 2024/1619, CRD VI) for further discussion of the scope of the restriction, the exemptions and implications.