Belgium

Licensing, Authorisation & Market Access

PSD3 and the accompanying Payment Services Regulation cleared national-representative text approval on 22 April 2026, with formal EU adoption expected later in 2026. This is a supranational, directly-consequential development for Belgium's payments-licensing perimeter: once national transposition follows formal adoption, Electronic Money Institutions currently licensed under the PSD2 framework will be folded into a reauthorised Payment Institution category, ending the separate EMI licensing track. This is a structural consolidation of the licensing regime rather than a change to any single institution's status, and it applies equally to bank and non-bank payment entities operating in Belgium under the joint supervisory structure of the National Bank of Belgium and the FSMA. The distinction between bank-affiliated PSPs and non-bank Payment Institutions and Electronic Money Institutions remains analytically significant here: the reauthorisation exercise will fall specifically on the non-bank EMI population, which will need to navigate a new authorisation category rather than simply continuing under its existing licence.

The reform's progress this cycle is textual and procedural rather than final: national-representative approval of the text is a meaningful step toward formal EU adoption, but the national transposition process, and with it the concrete EMI-to-PI reauthorisation mechanics for Belgian institutions specifically, has not yet begun. No Belgium-specific transposition timeline or draft implementing measure was identified this cycle.

Outlook

Formal EU adoption of PSD3/PSR, expected later in 2026, is the next concrete milestone to watch; it will start the clock on national transposition and determine the specific timeline by which Belgian EMIs must complete reauthorisation as Payment Institutions under the new package.

Licensing, Authorisation & Market Access

Belgium's payment and e-money institution population held steady this cycle: the National Bank of Belgium's FY2026 report confirms 48 active institutions, a figure the NBB describes as having remained stable versus the prior year. This population sits within the non-bank payment institution and e-money institution register, distinct from bank-PSP prudential supervision tracked separately.

The NBB expects new PI/EMI licence and registration requests to remain low in 2026, citing a market wait-and-see stance pending PSD3/PSR.

That EU-level clarity has itself slipped: a Council of the EU 'I' Item Note dated 17/23 April 2026 invited COREPER to approve final compromise texts, and commentary now anticipates PSD3/PSR entry into force by late 2027 with transitional licensing provisions, later than the earlier-projected 2026 timeline.

Limited-network exclusion notifications stabilised, dropping from 12 to 11 and reversing the 2023 uptick.

Outlook

The PSD3/PSR slip delays compliance planning windows and re-authorisation obligations for all EU and Belgian PI/EMI operators, and is likely to keep Belgium's licensing and registration pipeline subdued for several more quarters even as the existing 48-institution base holds firm.

Licensing, Authorisation & Market Access

The PSD3/PSR package reached its final EU legislative stage this cycle. The proposed texts were put before national representatives for approval on 22 April 2026, following provisional political agreement reached in November 2025, and on 23 April 2026 the Council of the European Union issued an "I" Item Note carrying final compromise texts and inviting COREPER approval — a sequence indicating imminent formal adoption. The package will repeal both the second Payment Services Directive (PSD2) and the second Electronic Money Directive (EMD2), replacing the current two-instrument architecture with a single framework: a revised Payment Services Directive (PSD3) governing authorisation and supervision, and a directly applicable Payment Services Regulation (PSR) governing conduct-of-business rules.

For Belgium's National Bank of Belgium-supervised electronic money institutions, the structural consequence is significant: PSD3 incorporates EMIs as a sub-category of payment institutions rather than preserving them as a separate authorisation class, and it requires EMIs to seek reauthorisation as payment institutions. This restructures the authorisation route that Belgian EMIs currently use. Trilogue agreement sets the transition mechanism: existing non-bank payment service providers across the EU, Belgium included, will have thirty months from the point at which the new regime takes effect to reobtain their licences under the unified framework, rather than continuing indefinitely under legacy PSD2/EMD2 authorisations.

The prudential dimension of this licensing reset is the own-funds calculation methodology. PSD3 promotes Method B as the default own-funds calculation method for payment institutions, confining Methods A and C to low-volume, high-value business models that require specific national competent authority validation; the European Banking Authority is expected to issue regulatory technical standards detailing the qualifying criteria. This bank-versus-non-bank distinction matters directly here: the reform is aimed at the non-bank payment institution and EMI population specifically, since bank-supervised payment activity already sits under a separate prudential regime and is not subject to the same own-funds recalculation.

Read against the broader reform, the licensing-and-market-access picture for Belgium this cycle is one of structural reset rather than incremental adjustment: a single EMI/PI authorisation category, a defaulted own-funds methodology, and a fixed reauthorisation clock together mean that Belgium's non-bank payment sector faces a genuine re-entry event once the thirty-month window opens, distinct from routine licence renewal. Bank-supervised payment activity in Belgium is not subject to this reauthorisation mechanism, since PSD3's reauthorisation requirement is targeted at the existing non-bank PI/EMI population specifically. No Belgium-specific enforcement or supervisory action was identified this cycle beyond this EU-level legislative timeline.

Outlook

The marker to watch is the PSR's Official Journal publication, expected summer 2026, which will fix the exact clock for the thirty-month non-bank reauthorisation window and the broader application timeline. Belgian EMIs and payment institutions should expect the National Bank of Belgium to issue implementation guidance once the compromise text is formally adopted; no such guidance was identified this cycle, which is itself consistent with the package still being at the final-adoption rather than implementation stage.

Conduct, Safeguarding & Financial Promotions

PSD3's safeguarding regime for customer funds remains largely aligned with the existing PSD2 baseline, but it introduces one structurally new option: payment institutions may safeguard customer funds directly at a central bank, at that bank's discretion, specifically to mitigate the concentration risk that arises when customer funds are safeguarded through a limited number of commercial-bank accounts. This is an additional mechanism layered onto the existing PSD2-aligned safeguarding toolkit rather than a replacement of it, and its availability in practice depends on individual central banks' willingness to offer the facility, which PSD3 leaves discretionary rather than mandatory.

For Belgian payment institutions and electronic money institutions supervised by the National Bank of Belgium, this creates a new, non-bank-specific safeguarding pathway that did not previously exist: a non-bank PI or EMI could, subject to the National Bank of Belgium's discretion, hold safeguarded customer funds at the central bank itself rather than exclusively through commercial-bank safeguarding accounts or approved investment routes. This distinction is squarely a non-bank-PI/EMI conduct-and-safeguarding matter; bank-supervised payment activity is not affected in the same way, since banks are not subject to the PSD2/PSD3 safeguarding regime in the first place.

No Belgium-specific conduct or financial-promotions enforcement development, and no update to the safeguarding baseline beyond this new central-bank option, was identified this cycle.

Outlook

The practical question for the next cycle is whether the National Bank of Belgium indicates any willingness to offer the discretionary central-bank safeguarding facility to Belgian PIs and EMIs once PSD3 is formally adopted; no such signal was identified this cycle. Absent that signal, the safeguarding baseline for Belgian non-bank payment institutions should be treated as PSD2-aligned and unchanged in practice, even though the legal option for a new mechanism now exists in the adopted text.

Stablecoins & Digital Money

Belgium's digital-money regulatory framework reached full operability this period while its authorised-participant count remained at zero. The FSMA has confirmed directly that no crypto-asset service provider holds an authorisation granted by the FSMA under Belgium's MiCA implementing Law of 11 December 2025. Belgium's MiCA transitional regime expired on 1 July 2026, and within days, on 6 July 2026, the FSMA added six unauthorised firms to its fraudulent-CASP list for offering crypto-asset services without the required authorisation. The authorisation requirement itself is set out in Article 63 of MiCAR as implemented through the Belgian Law of 11 December 2025, and it applies to any entity providing crypto-asset services in Belgium absent a valid EEA passport from another Member State.

From a payments-market-structure perspective, this is a distinctive configuration: the legal perimeter for crypto-asset and digital-money services is complete and enforced, yet no domestic market participant has yet cleared the authorisation bar. For any firm assessing market entry into Belgium's digital-money space, this means the regulatory requirements are fully known and stable, but there is no existing precedent of a successful domestic authorisation to benchmark against. The enforcement action against six named unauthorised firms demonstrates that the FSMA is actively policing the boundary of this perimeter even in the absence of authorised participants, which is a relevant data point for any firm weighing the cost and risk of continuing to operate, or beginning to operate, without first securing authorisation.

Outlook

The central question for Belgium's stablecoin and digital-money market is whether and when the FSMA grants its first domestic CASP authorisation. Until that happens, market participants and prospective entrants alike are operating in a regulatory environment that is fully defined on paper but untested in practice at the point of actual authorisation.

Stablecoins & Digital Money

The National Bank of Belgium confirmed its role as prudential authority under MiCA for banks, EMIs, ART/EMT issuers and certain CASPs, including powers to suspend offers or issue warnings.

The European Commission launched a targeted public consultation on 20 May 2026 comparing supervisory frameworks relevant to stablecoins and CASPs.

The Eurosystem concluded the digital-euro preparation phase and moved into a technical-readiness, market-engagement and legislative-process-support phase, with the NBB participating; the ECB named pilot-participant providers in July 2026.

Outlook

The digital-euro phase transition and the EC's stablecoin/CASP consultation together point toward accelerating institutional entrenchment of both CBDC and stablecoin oversight architecture touching Belgium; any AML or illicit-finance angle on these instruments belongs to the adjacent crypto-focused monitor rather than to this module's own analysis.

Operational Resilience & Critical Infrastructure

Belgium has completed the phased compliance schedule under the EU Instant Payments Regulation for its domestic account-to-account clearing infrastructure. Direct and indirect participants in the Centre for Exchange and Clearing (CEC) have been required to receive instant payments since 9 January 2025 and to send instant payments since 9 October 2025, with Verification of Payee (VoP) functionality also required from that October 2025 date. With all three milestones now behind the relevant compliance dates, Belgian payment infrastructure has moved from a build-out phase to a steady-state operational phase under the Regulation, shifting the operational-resilience question from implementation risk to ongoing performance and monitoring.

Separately, the National Bank of Belgium's published 2026 oversight priorities explicitly name monitoring of the Mastercard Clearing and Exchange (MCE) systemically important payment system's compliance action plan as a standing, multi-year workstream. This signals that operational-resilience oversight of Belgium's critical payment-system infrastructure is treated by the NBB as an ongoing supervisory commitment rather than a point-in-time compliance check, consistent with the broader European critical-infrastructure oversight trend around systemically important payment systems.

Read together, these two developments describe a Belgian payment-infrastructure environment that has cleared its major near-term compliance milestones (instant payments send/receive/VoP) while entering a longer-horizon supervisory-monitoring phase (the MCE SIPS action plan) for its most systemically significant processing infrastructure. Both developments concern bank/PSP-connected clearing and settlement infrastructure specifically, distinct from any non-bank PI/EMI-specific resilience requirements.

Outlook

The operational-resilience watch items for the coming cycles are how CEC participants perform under full Instant Payments Regulation compliance in steady-state operation, and how the NBB's multi-year monitoring of the MCE SIPS-compliance action plan progresses and whether it surfaces any further named workstreams or milestones.

Product Innovation & Market Development

bunq launched Belgian IBANs together with Wero payments, adding an instant account-to-account rail option for internationally mobile residents.

Outlook

The launch adds competitive depth to Belgium's account-to-account rail landscape and signals continued neobank expansion into instant-payment-linked IBAN products; underlying source-quote fields remain unverified pending re-fetch of the originating article.

Product Innovation & Market Development

Two developments define this cycle's product-innovation picture for Belgium. First, April 2026 reporting marked the transition from implementation to assessment ahead of the July 2027 deadline by which non-eurozone banks and non-bank payment service providers must be able to send instant payments under the EU Instant Payments Regulation. Belgium, as a eurozone member already integrated into the TARGET Instant Payment Settlement system, is not itself the primary target population for that specific deadline, but the April 2026 checkpoint is an EU-wide reporting and assessment milestone that Belgium's supervisory apparatus participates in regardless.

Second, and more directly attributable to Belgium specifically, the National Bank of Belgium has taken an active preparatory posture toward the open-banking and open-finance transition: it endorses the EU's open-banking guidelines, has already adopted PSD2, and is preparing to implement the forthcoming Payment Services Regulation, PSD3, and the Financial Data Access (FiDA) Regulation. This combination — endorsement of guidelines, existing PSD2 adoption, and active preparation for three forthcoming instruments simultaneously — indicates that Belgian payments-market development this cycle is being actively steered toward open finance by the national supervisor rather than merely responding to EU-level deadlines as they arrive.

Outlook

The marker to watch is whether the National Bank of Belgium publishes concrete implementation guidance or a timeline for FiDA and PSD3/PSR readiness now that the legislative package has reached final adoption stage; no such published guidance was identified this cycle. On instant payments, the next checkpoint of note is progress toward the July 2027 non-eurozone send-deadline, though this affects Belgium only as an EU-wide reporting participant rather than as a directly targeted jurisdiction.

Correspondent Banking, Settlement & Access

New Belgian legislation has entered into force strengthening the National Bank of Belgium's statutory oversight powers over financial-messaging service providers such as Swift, exercised in cooperation with other G10 central banks.

This reinforces Belgium's correspondent-banking and settlement-infrastructure supervisory perimeter and sharpens the module's underlying asymmetry, in which banks retain direct scheme and messaging access while non-bank payment and e-money institutions depend on intermediated relationships.

The new oversight regime touches the messaging layer that both bank and non-bank payment institutions rely on for cross-border settlement, though non-banks continue to access that layer only through intermediated bank relationships rather than directly.

Outlook

New Belgian legislation strengthening NBB oversight of financial-messaging providers is consistent with a broader tightening of correspondent-banking and settlement-infrastructure supervision across G10 central-bank cooperation, and is the highest-confidence development of the cycle.

Correspondent Banking, Settlement & Access

The defining development for correspondent banking and settlement access this cycle is the planned expansion of verification-of-payee checks to all wire transfers under PSD3/PSR, extending beyond the subset of bank-transfer types that currently require such checks under the Instant Payments Regulation. This is a structural tightening of the settlement and fraud-check layer that sits ahead of both bank and non-bank payment service providers' correspondent and settlement relationships, since verification-of-payee failures are precisely the kind of friction point that concentrates around correspondent and cross-border settlement chains.

The timeline attached to this expansion is still provisional: the PSR is expected to be published in the Official Journal in summer 2026, entering into force twenty days later, with most provisions — including the payee-verification regime — applying twenty-one months after that, placing live application at approximately early 2028, and the associated liability-shift regime for fraud losses following roughly three months after that. Because this analytical spine sits on Tier 3 sourcing rather than a confirmed Official Journal date, the estimated dates carry half-year uncertainty and should be treated as provisional rather than fixed.

The bank-versus-non-bank access asymmetry that structures this module is directly relevant here: an expanded verification-of-payee obligation applying to all wire transfers will fall on both bank and non-bank payment service providers, but banks already possess more mature correspondent and settlement infrastructure through which to absorb a verification-of-payee build-out, while non-bank PSPs — the same population facing the PSD3 reauthorisation and Method-B own-funds changes — face this settlement-layer requirement concurrently with a licensing and prudential reset, compounding implementation load for that population specifically.

Outlook

The Official Journal publication of the PSR is the marker that will convert the current half-year-uncertainty estimates into fixed dates for both the payee-verification application point and the subsequent liability-shift provisions. Once published, Belgian banks and non-bank PSPs alike will have a fixed clock against which to build verification-of-payee infrastructure; until then, this module's dates remain provisional estimates derived from Tier 3 commentary rather than confirmed primary-source dates.

Commercial Intelligence & Fintech

Belgian companies raised EUR497.1 million across 74 disclosed funding rounds in the first half of 2026, an increase of 40 percent on the same period in 2025. Fintech was the leading sector by capital raised, accounting for EUR135.3 million of the total, with Keyrock's Series C round among the notable contributors to that figure. This data comes from an industry-data aggregator and has not been cross-checked against individual company filings, so the specific figures should be treated as a reported industry estimate rather than an independently verified consolidated total.

This is a discrete commercial-funding event rather than a structural market-trend assessment: it describes what was raised and by whom within a defined half-year window, rather than characterising a longer-run pattern in Belgian fintech investment. Keyrock's round size itself was not separately disclosed within the aggregator's reported figures, so the amount attributable specifically to Keyrock within the broader EUR135.3 million fintech total is not publicly disclosed in the sources available this period.

The strength of this funding data sits alongside, but is analytically separate from, the current state of Belgium's crypto-asset authorisation landscape, where no domestic CASP has yet been authorised under the country's MiCA implementing law. Investor appetite for Belgian fintech, as reflected in the H1 2026 figures, has evidently not been dependent on the existence of a settled domestic crypto-asset authorisation track record.

Outlook

Whether Belgian fintech funding momentum continues into the second half of 2026 at a comparable pace to the reported 40 percent year-on-year increase is the principal data point to track for this module going forward.

Commercial Intelligence

bunq bundled a new Belgian IBAN product with Wero payment support, part of its continued multi-country account expansion; the deal value was not publicly disclosed.

Outlook

The Belgian IBAN plus Wero bundle is a discrete competitive event for market-share tracking of challenger banks in Belgium, distinct from any structural M&A trend; the underlying source URL registered an egress timeout this cycle and quoted text could not be corroborated.