Slovenia Enacts New Banking Act Regulating Third-Country Banks

On 25 February 2026, the new Banking Act (ZBan 4) was published in the Official Gazette of the Republic of Slovenia and entered into force on 12 March 2026. This legislation transposes Directive 2024/1619/EU (CRD VI) into Slovenian law, establishing an updated regulatory framework for the banking sector.

Key Provisions of ZBan 4

The new Banking Act introduces several significant provisions:

• Regulation of Third-Country Banks: The Act provides a comprehensive framework for the provision of banking and financial services by institutions from third countries, including the regulation of branches of these institutions operating in Slovenia.
• ESG Risk Management: It mandates systematic management of environmental, social, and governance (ESG) risks within the prudential framework, requiring banks to integrate ESG factors into their strategies, internal processes, and risk management practices.
• Crypto Asset Exposure: The Act includes provisions for the supervision of exposures to crypto assets, necessitating prior risk assessments and reporting obligations to the Bank of Slovenia.
• Governance and Supervision: It establishes stricter conditions for the appointment of members of the Governing Board of the Bank of Slovenia and introduces measures to prevent conflicts of interest, such as the "revolving doors" phenomenon.

Implications for the Banking Sector

The enactment of ZBan 4 has several implications for the banking sector:

• Compliance Requirements: Banks operating in Slovenia, including branches of third-country institutions, must ensure compliance with the new regulatory requirements, particularly concerning ESG risk management and crypto asset exposures.
• Operational Adjustments: Institutions may need to adjust their internal processes and governance structures to align with the stricter conditions and reporting obligations introduced by the Act.
• Market Entry Considerations: Third-country banks seeking to establish or continue operations in Slovenia will need to navigate the updated regulatory landscape, which may impact their market entry strategies.

For more detailed information, refer to the official announcement: New Slovenian Banking Act and new regime for banks from third countries