Employment Documentation for New EU Bank Branches Under CRD VI
Your First Branch Offer Has to Stand Up Under Local Law. So Does Every Document Behind It.
Once the branch plan moves from authorization to hiring, the first offer letter is judged by the rules of that Member State. Head office paperwork with the country name swapped rarely survives that step, whether it started life in London, New York or Zurich: it can miss mandatory information, carry clauses that local courts will not enforce, and ignore the language and collective agreement rules the branch now has to follow.
Europe HR Solutions prepares every employment document each branch country needs, from the contracts of the people who direct the branch to the handbook every new hire receives. Drafted for local law, consistent with your group standards, and signed off before offers are made.
What each branch country needs in place
WHO WE ARE
The Documentation Partner That Knows Where Group Templates Break
A contract that works in London can fail in Frankfurt on a single clause, and a global handbook seldom holds the policies employers in Paris or Amsterdam are obliged to keep. Europe HR Solutions drafts and localizes employment documentation country by country, drawing on independent in-country HR specialists for local practice, with a senior team in Belgium keeping every branch consistent.
When Alltec Fibre launched operations in Germany, France, Spain, Italy and Sweden at the same time, we drafted and localized the contracts and built handbooks for each country’s rules and language requirements on an accelerated timeline, so new employees could be onboarded compliantly from the start. Read the Alltec Fibre story.
THE PRE-HIRE RISK
Relabeling the Group Contract Does Not Make It Local
The template that serves you well at head office was written for another legal system. Issued in a branch country, it leaves out what local law requires and keeps clauses local courts will not uphold. For a regulated employer, that exposure starts with the very first signature.
The group template, relabeled
Head office wording with the Member State filled in
- Drafted in English where the local rules call for another language
- Notice, probation and fixed-term terms copied from home
- A non-compete with no compensation where the law demands it
- Required information missing from the written terms
- No mention of the collective agreement the branch falls under
- Policies that exist at group level but not in a local, valid version
Documents built for the branch country
Prepared per Member State by Europe HR Solutions
- The language each country requires, with translations where helpful
- Notice, probation and fixed-term rules set by local statute
- Restrictive covenants drafted to the local conditions for validity
- Every item the written statement of terms must contain
- The applicable collective agreement identified and reflected
- Every policy local law obliges the branch to keep
THE DOCUMENT SET
Everything a Branch Employee Signs or Receives Before Day One
Prepared country by country ahead of the first offer, so hiring can start the moment the branch is ready to employ.
Employment contracts
Contracts under local law for every role in the branch, with pay, variable pay, working time and restrictive covenants drafted to each country's rules.
Director and key function holder contracts
Terms for the people who direct the branch that reflect their role, their base in the Member State and the time they commit to it, in line with the remuneration policy your authorization file outlines.
Written statement of terms
The information each employee must receive in writing, issued within the national deadline, which in Germany means some terms on the very first working day.
HR policies
An internal whistleblowing procedure, rules on hours, absence and behavior, employee data handling, and country-specific requirements such as French works rules once headcount has stayed at 50 or more for a year.
Employee handbook
One handbook per branch that follows group standards where local law allows and departs from them where it must, in the language employees need.
Offer and onboarding pack
Offer letters, employee privacy notices and onboarding acknowledgements, with pay information for candidates prepared wherever national pay transparency rules already apply.
THE MULTI-COUNTRY REALITY
Same Role, Same Bank, a Different Contract in Every Branch Country
EU law sets a floor for what employees must be told in writing, but each Member State builds its own rules on top: different deadlines, different languages, different clauses that hold or fail. A relationship manager hired in Dublin and one hired in Paris sign documents that share a job title and little else.
DEGermany
- Name, pay and working time confirmed in writing on the first working day, most other terms by day seven
- Post-contractual non-competes void without compensation of at least half of last pay, and capped at two years
- Written statements now allowed in text form, but a fixed-term clause needs wet ink or a qualified e-signature, or the contract becomes permanent
FRFrance
- Written contracts drafted in French, and bonus objectives set only in English have been ruled unenforceable against the employee
- Fixed-term contracts only in the cases the Labor Code lists, and never for a permanent role
- Works rules in French once headcount reaches 50 for twelve consecutive months
NLNetherlands
- A fixed-term chain turns permanent after more than three contracts or more than three years
- A non-compete in a fixed-term contract needs written reasons of compelling business interest
- Expat ruling terms reflecting the 27% maximum from January 2027 and its transitional rules
IEIreland
- A Day 5 statement of eleven core terms, then the full written statement within one month
- A written safety statement, or an approved code of practice for employers with three staff or fewer
- An employment permit in place before any non-EEA hire starts work
LULuxembourg
- A written contract handed over by the first day of work at the latest
- Fixed-term contracts capped at 24 months including no more than two renewals
- A contract with no written fixed-term clause presumed permanent
ESSpain
- Contract content notified to the public employment service within ten working days
- Permanent by default: fixed-term only for production needs or to substitute an employee, with the cause spelled out
- Banking agreement pay scales for most roles, and separate terms for the senior managers and identified staff it excludes
Each new branch country adds a language, a deadline and a document set of its own.
WHAT EUROPE HR SOLUTIONS HANDLES
Employment Documentation for Non-EU Banks, Prepared Country by Country
Each workstream is completed for every branch country and handed over as one consistent set, so your HR team and your counsel review a single pack instead of a folder of unrelated local drafts.
Contract Drafting
Contracts for every branch role, drafted or localized for the job, its seniority and how it is worked, keeping your group standards wherever the law allows.
Group Template Localization
Your existing templates reviewed against each branch country’s rules, kept wherever they work and rewritten wherever they do not, with every change explained.
Policies & Handbooks
The core policy set and a branch handbook for each jurisdiction, from absence and hours to employee data and the whistleblowing channel.
Onboarding Documentation
Offer letters, written statements of terms and privacy notices prepared in advance and ready to send the day a hire is confirmed.
Termination & Lifecycle Templates
Probation, notice and exit frameworks set up front, with termination templates drafted with care for protected employees, so the branch is covered for the full employment cycle.
Ongoing Updates
One controlled document set per country, updated whenever local law moves or group policy is revised after the branch opens.
HOW WE RUN IT
Review. Localize. Approve. Issue.
Four steps for every branch country, scheduled against your hiring dates so the paperwork is approved before any offer.
Review
Branch roles, planned start dates and your existing group templates, checked against what each Member State requires.
›Localize
Each document drafted or rewritten for local law, in the required language, with mandatory information and local clauses in place.
›Approve
Your HR team and counsel review one complete set per country, with every change from the group template marked and explained.
›Issue
Final versions ready to send and stored in one controlled place, so nobody is ever handed an outdated contract.
PART OF OUR CRD VI SERIES
The Rest of Your CRD VI Branch Setup
Market Entry HR Setup for Third-Country Branches →
The employment foundation for opening the branch — management, key function holders and local HR, built per Member State.
CRD VI · BankingSystems & Payroll Coordination for Third-Country Branches →
Multi-country payroll, employee data and HR systems, coordinated into one European operating model and reporting into one place.
QUESTIONS BANKS ASK US
CRD VI Branch Employment Documents: Your Questions Answered
1. Can we adapt our head office or group contract for the branch?
As a starting point, yes; as the final document, no. Depending on the Member State, the branch version may have to be written in the local language, include information the law lists item by item, and follow a sector collective agreement. Home-market terms on notice, probation and post-employment restrictions are frequently invalid or unenforceable once the employee works abroad. We keep what works from your template and rewrite what does not.
2. Can we keep branch contracts under English or New York law?
You can choose the governing law, but it will not remove local protections. Under Article 8 of the EU’s Rome I Regulation, a choice of law cannot deprive an employee of the mandatory protections of the country where they habitually work. A branch employee in Germany or France keeps German or French mandatory rules whatever the contract says, so the documents have to be built around them either way.
3. Which documents do we need before the first hire?
At minimum a local employment contract, the written statement of terms, an employee privacy notice and every policy local law obliges the branch to keep. Timing matters as much as content. EU law requires core terms in writing within seven days of the first working day, but Ireland requires a statement of eleven core terms within five days and Germany requires pay and working time on the first working day. In practice the full set should be finished before any offer is made.
4. We use one employee handbook worldwide. Is that a problem?
Usually, yes. A global handbook rarely contains the country-specific policies local law requires, and parts of it may conflict with local rules or be in the wrong language. In France, for example, works rules must be in French and are mandatory once headcount reaches 50 for twelve consecutive months. We build a branch handbook that keeps your group culture and adds what each country requires.
5. Do the contracts really need to be in the local language?
In some countries, yes. In France a written employment contract must be drafted in French, and an employer cannot rely against the employee on contract clauses in another language. Documents that set obligations, such as bonus objectives, must be in French too: in 2023 the Cour de cassation held English-only bonus objectives unenforceable against an employee. Narrow exceptions exist, for example for foreign employees, who can also ask for a translation of their contract. Other Member States are less strict. We prepare each set in the language that makes it enforceable, with English versions for group review.
6. What should contracts for the branch's directors include?
They need to match what your authorization file says. Article 48g of CRD VI asks for a minimum of two people based in the Member State who effectively direct the branch and give it sufficient time, and the EBA’s authorization guidelines ask for an outline of the branch’s remuneration policy. Their contracts should reflect the role, the base in the Member State, the time commitment and variable pay terms consistent with that policy.
7. Do you replace our legal counsel?
No. We prepare the documentation set and explain every departure from your group template, and your in-house or local counsel reviews and approves it. It is usually faster than briefing a local law firm in every country for standard documents, and it keeps counsel focused on the questions that genuinely need legal advice.
8. Can you prepare several branch countries in parallel?
Yes. One team runs every country against your hiring plan, using a shared structure localized per Member State, so each branch receives a complete set in time for its first offer. Single-country packages typically take two to four weeks, and multi-country packages four to six weeks or more.
Reviewed by Nadia Harris, Client Solutions Director · Last reviewed September 2026
A Branch Should Not Make Its First Offer Before Its Documents Are Ready. Start Them Now.
Know exactly what each branch employee must sign
Share where the branches will be, which roles you will hire first and when those people should start. We set out the documentation each country requires.
You receive a per-country list of contracts, statements, policies and onboarding documents, in the order they are needed.
No commitment required. You leave knowing which documents stand between your branch and its first hire.