Security law differs
A floating charge or equivalent exists in most jurisdictions but covers different assets and ranks differently in bankruptcy. Share pledges are treated differently across the Nordics, Benelux and Eastern European legal systems, and pledges over movables are in practice only relevant in some countries.
A cross-border facility therefore normally has to be paired with local security documents in each jurisdiction — and a clear intercreditor agreement.
Currency and natural hedge
Companies with revenue in NOK, DKK, EUR, PLN or CZK are wise to match at least part of their debt to the same currency. This provides a natural hedge that is cheaper than continually buying FX protection.
The banking landscape by region
The Nordics are dominated by Nordea, SEB, Danske Bank, DNB and OP-Pohjola, with pan-Nordic reach but different risk appetites per segment. In Benelux the heaviest counterparties are ING, KBC, BNP Paribas Fortis, ABN AMRO and Rabobank, typically EUR-focused and with dedicated mid-market divisions. In Eastern Europe depth sits with Erste, Raiffeisen, KBC/ČSOB, PKO and OTP — where local credit culture differs materially between Prague, Warsaw and Bucharest.
A structured process that allows offers to be compared in parallel across the three regions normally delivers better terms than relying on a single relationship.
- Security documentation needs to be local — even under a common facility agreement.
- Currency matching between revenue and debt creates a natural hedge.
- An intercreditor agreement must be in place before drawdown.
- Benchmark banks across the Nordics, Benelux and Eastern Europe in parallel for the best terms.
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