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title: Belgium Payments Regulation Monitor | World Payments Monitor
canonical: https://payments.gi/jurisdictions/belgium/
date_modified: 2026-10-21
publisher: Asymmetric Intelligence

# Belgium

BE schema world-payments-v1

trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 72 sourced findings · 215 sources in the cumulative register

14 Modules baseline.modules[]

72 Findings modules[].findings[]

69 Tier-1 sources run_metadata.t1_source_count

Confidence mix (sums to 14 rendered modules; click to filter)

No modules moved this cycle.

** Law made at European Economic Area level** that applies in Belgium is covered once, on the [European Economic Area](https://payments.gi/jurisdictions/european-economic-area/) page. This page covers Belgium’s own layer: implementation, national authorities, national options and local enforcement.

## Jurisdiction brief

###### Latest update · 18 October 2026

#### Lead Signal

Belgium's MiCA transitional period for pre-existing VASPs and CASPs expired on 1 July 2026, and the FSMA has confirmed that no CASP currently holds FSMA-granted MiCA authorisation. Days later, on 6 July 2026, the FSMA added six unauthorised crypto-asset service providers to its fraudulent-CASP warning list, the first enforcement action taken under the post-transitional regime. Supervision of digital-asset activity in Belgium splits along twin-peaks lines: the National Bank of Belgium leads on Asset-Referenced Tokens and E-Money Tokens, and on CASP-services conducted by entities the NBB already supervises, while the FSMA supervises all other CASPs, including conduct-of-business and the enforcement action just described. This is the defining payments-infrastructure development for Belgium this cycle: a fully legislated MiCA regime now operating with zero confirmed authorisations against a confirmed enforcement population of six.

#### Other Developments

**KBC Bank's Bolero platform launched retail Bitcoin and Ether trading** in early 2026 and submitted a full CASP notification to the FSMA, representing a bank-channel entry into retail digital-asset trading distinct from the standalone crypto-exchange model; this follows broader market movement among large Belgian banks, with Belfius and ING also having taken steps to provide retail customers crypto access, directly or via trackers. **Brussels-based Chift, a financial-data-connectivity API provider, closed a EUR 10.5 million Series A funding round** in September 2026, led by BlackFin Capital Partners, forming part of a broader EUR 1.09 billion first-half-2026 Belgian technology funding picture. **FSMA's Communication of 29 January 2026 (FSMA_2026_02)** set out procedures for notifying white papers and marketing materials for crypto-asset offers and admissions, excluding Asset-Referenced Tokens and E-Money Tokens — a procedural conduct instrument supporting the broader MiCA implementation described above.

#### Cross-Monitor Connections

The MiCA transitional-deadline expiry and the FSMA's resulting enforcement action are tracked by the financial-integrity monitor against FATF's December 2025 finding that no authority had been designated to supervise virtual asset service providers in Belgium as of that evaluation's on-site visit; the crypto monitor tracks the same licensing-and-enforcement sequence from a crypto-regulatory-regime perspective. These are three readings of one event set, not independent confirmations. The Chift funding round is likewise tracked by the financial-integrity monitor as a commercial-activity item adjacent to the AML/CFT compliance-technology perimeter.

#### Outlook

The item most likely to generate the next dateable development is KBC's CASP notification: its resolution, whether authorisation or further delay, would be the first bank-channel test of Belgium's post-transitional MiCA authorisation process. More broadly, whether any applicant — bank-channel or crypto-native — achieves FSMA CASP authorisation following the 1 July 2026 deadline remains the open structural question for Belgium's digital-money infrastructure. On the commercial side, continued fintech capital inflow exemplified by Chift suggests Belgium's broader payments-connectivity and infrastructure sector remains active independent of the authorisation bottleneck in the crypto-asset segment specifically.

_6 earlier updates not shown here._

###### Standing brief · as of 4 July 2026

_Written before the update above. Where they differ, the update is the more recent position._

#### Lead Signal

Belgium's first appearance in the World Payments Monitor carries two entangled headline stories: a new dual licensing track for crypto-assets, and an acute reputational and legal crisis at the country's dominant payments processor. The Law of 11 December 2025 transposes MiCA into Belgian law and, from January 2026, creates a mandatory licensing and authorisation framework for crypto-asset issuers and exchanges, an adjacent market-access track alongside Belgium's existing PI/EMI regime, under which the National Bank of Belgium authorises and registers payment institutions and electronic money institutions under the Law of 11 March 2018. Supervision of the new track splits on a twin-peaks basis: the NBB is competent for asset-referenced tokens and e-money tokens, treating the latter as e-money, while the FSMA supervises CASP authorisation, conduct, and other crypto-asset white papers; a transitional regime for pre-existing CASPs runs to 1 July 2026. Belgium's crypto-asset market access has therefore moved, within a single legislative act, into a formally licensed second track sitting beside conventional payments licensing.

The second and more acute strand this cycle is Worldline. The Brussels Public Prosecutor's Office is investigating Worldline's Belgian unit following June 2025 press reports -- the 'Dirty Payments' exposé -- alleging continued high-risk merchant processing; the reporting is associated with a one-day share-price collapse of more than 40%. Worldline has disclosed that high-risk merchant volumes represent 1.5% of acquiring volumes within its Merchant Services business. The exposure sits alongside Visa's updated Acquirer Monitoring Program, which raises chargeback-rate thresholds and enforcement stakes for acquirers and applies to Worldline's scheme membership. Together, the prosecutorial investigation and the scheme-monitoring tightening constitute the most acute near-term risk to Belgium's payments market structure.

#### Other Developments

Belgium's core PI/EMI regime remains the standard EEA PSD2/EMD2 model, with full inbound and outbound EEA passporting and a lighter 'limited' waiver track available below EUR1 million in payment volume or EUR1.5 million in e-money outstanding, though without passporting rights. Safeguarding of client and e-money funds runs through Articles 42 and 194 of the Law of 11 March 2018, transposing PSD2 Article 10, requiring segregation in a distinct client account held at an EU credit institution; an NBB circular permits an equivalent-safeguarding discharge where funds are instead protected by an EU-authorised intermediary PSP in an outsourced payout chain. Belgium also bans merchant surcharging outright for any payment instrument under Article VII.30 §3 of the Code of Economic Law, exceeding the EU Interchange Fee Regulation baseline.

Operational resilience is a rising theme. DORA has applied to Belgian financial entities, including payment and e-money institutions, since 17 January 2025, with the NBB and FSMA as competent authorities and NBB's TIBER-BE programme requiring threat-led penetration testing every three years for significant entities. A 2025 NBB survey of 132 financial entities found policy documents and procedures still under development in several areas, with some entities yet to complete ICT-asset-to-critical-function dependency mapping. Against that gap, a revised SWIFT oversight framework introduces legally enforceable governance requirements, and SWIFT is expected to be formally designated a systemic provider under Belgian law in 2026, with the NBB retaining its lead-overseer role; the NBB is also the sole CSDR competent authority for Belgian-law Euroclear Bank entities, whose Swiss cash-correspondent links, previously stressed during the Credit Suisse turbulence, are now assessed as stable.

On anti-money-laundering, the FATF's December 2025 Mutual Evaluation found Belgium's AML/CFT/CPF system technically largely aligned with FATF standards but identified continuing effectiveness gaps, particularly on virtual-asset rules. Amid criticism that past NBB Sanctions Committee fines -- in the EUR50,000 to EUR350,000 range -- were insufficient deterrents, the NBB and FSMA are reported to be moving toward a 2026 policy of publicly naming non-compliant banks; the NBB Sanctions Committee previously fined BNP Paribas Fortis EUR15 million in 2023 for 'egregious' AML failings between 2014 and 2019. This AML strand is carried into WPM via the Sentinel.gi feed and is not independently re-analysed here.

Consumer protections firmed further: a 19 March 2026 Brussels Commercial Court ruling ordered a bank to reimburse EUR40,960.56 to a business owner victimised by cyber fraud, confirming that Belgium's 'reimburse-first, litigate-later' model under Articles VII.43-VII.44 of the Code of Economic Law extends into a business-to-business context. On instant payments, Belgium remains a founding-wave market for Wero, launched domestically on 19 November 2024 on SEPA Instant Credit Transfer rails; e-commerce acceptance began from November 2025/January 2026, with point-of-sale acceptance planned for later in 2026. The NBB and Eurosystem continue preparatory work on digital euro issuance, following the ECB Governing Council's launch of the preparatory phase on 18 October 2023.

Belgium continues to run its Twin Peaks supervisory model -- NBB for prudential matters, FSMA for conduct -- in place since 1 April 2011, atop a private fintech layer reported at over 200 active firms. Bancontact remains the dominant domestic debit scheme, present on over 94% of debit cards in circulation and directly overseen by the NBB alongside Mastercard Europe, Maestro and MCMS. On commercial activity, Worldline has sold its Ingenico-derived POS terminal business to Apollo Funds and is selling its Mobility & e-Transactions Services business to Magellan Partners, with deal values undisclosed. The European Payments Initiative raised EUR450 million from shareholders including Worldline and Nexi to fund the Wero rollout, and a consortium of European banks including Belgium's KBC has announced plans for a MiCA-compliant euro stablecoin targeted for the second half of 2026; French wealthtech TwoWay separately secured a EUR1.5 million pre-seed round led by Belgium-based VC firm Welovefounders.

#### Cross-Monitor Connections

Worldline's prosecutorial exposure carries a flagged cross-reference to FIM: the underlying allegations concern processing linked to high-risk merchant categories, a subject outside WPM's scheme-compliance and market-structure remit. WPM's role is limited to tracking the regulatory, scheme-membership and litigation consequences for Belgium's payments infrastructure; assessment of illicit-finance use of payment rails is a FIM matter. Belgium's AML/CFT standing position throughout this brief is sourced from the Sentinel.gi feed rather than original WPM research.

#### Outlook

Three forward markers define Belgium's near-term trajectory. The MiCA transitional regime for pre-existing crypto-asset service providers closes on 1 July 2026, at which point the dual-authorisation landscape becomes fully live. Worldline's prosecutorial and scheme-monitoring exposure remains unresolved, and the investigation's trajectory will determine whether this stays a company-specific episode or becomes a broader acquiring-sector supervisory response. Wero's planned 2026 point-of-sale rollout and the bank-consortium's targeted second-half-2026 euro stablecoin launch will test whether Belgium's instant-payments and stablecoin ambitions convert from preparatory activity into scaled market presence within the year.

trust tier: ai_unverified

_Standing brief, as of 4 July 2026._

#### Regulatory Status

Belgium operates a mature, twin-peaks payments regulatory architecture: the National Bank of Belgium handles prudential authorisation and oversight -- including PI/EMI licensing under the Law of 11 March 2018, DORA supervision, and lead-overseer responsibility for SWIFT -- while the FSMA covers conduct, consumer protection, and crypto-asset service provider authorisation under the Law of 11 December 2025 implementing MiCA. That MiCA law creates a new mandatory licensing track for crypto-asset issuers and exchanges from January 2026, splitting supervision on a twin-peaks basis between NBB (asset-referenced tokens and e-money tokens) and FSMA (CASP authorisation and conduct), with a transitional regime for pre-existing CASPs running to 1 July 2026. Belgium's payments market structure is currently under acute stress from Worldline's 'Dirty Payments' exposure: a Brussels Public Prosecutor's Office investigation into the country's dominant acquirer is running alongside Visa scheme-monitoring pressure, following a 2025 media exposé associated with a share-price collapse of more than 40%. Against this, Belgium's operational-resilience and consumer-protection baselines remain robust: DORA has applied since 17 January 2025 with NBB's TIBER-BE testing regime, a March 2026 Brussels Commercial Court ruling reinforced 'reimburse-first' fraud protection into a B2B context, and Belgium remains a founding-wave market for the Wero instant-payment wallet alongside continuing Eurosystem digital-euro preparatory work. AML/CFT supervision, sourced via the Sentinel.gi feed, shows a system technically aligned with FATF standards but moving toward a tougher 2026 public-disclosure enforcement posture after criticism of historically modest fines, including the EUR15 million NBB sanction against BNP Paribas Fortis in 2023.

#### Outlook

Belgium's near-term regulatory trajectory is defined by three converging tracks: the MiCA/CASP transitional regime closing on 1 July 2026, the unresolved Worldline prosecutorial and scheme-monitoring exposure, and continued deepening of instant-payments and digital-euro infrastructure. Belgium's overall risk profile is assessed as elevated and tightening on the litigation/enforcement axis while remaining stable on market-access and institutional-structure axes.

###### Latest update · 14 September 2026

#### Regulatory Status

Belgium's payments regulatory environment this cycle is shaped entirely by EU-wide developments applying via the National Bank of Belgium and FSMA's standard supervisory channels, with no Belgium-specific divergence identified. The PSD3/Payment Services Regulation package cleared national-representative text approval on 22 April 2026 and is moving toward formal EU adoption later in 2026; once transposed, this will fold Belgian Electronic Money Institutions into a reauthorised Payment Institution category. The draft PSR also extends Verification-of-Payee obligations to all credit transfers, beyond the current Instant Payments Regulation scope, a development with direct settlement-and-access implications for Belgian PSPs' fraud-liability exposure.

#### Outlook

Formal EU adoption of PSD3/PSR later in 2026 is the milestone to watch for Belgium; national transposition following that adoption will determine the concrete timeline for EMI reauthorisation and Verification-of-Payee infrastructure build-out for Belgian-supervised payment entities.

_1 earlier update not shown here._

###### Standing brief · as of 11 August 2026

_Written before the update above. Where they differ, the update is the more recent position._

#### Regulatory Status

Belgium's payments regulatory posture this cycle is defined by the PSD3/PSR package reaching final EU adoption stage, with direct structural consequences for the National Bank of Belgium-supervised electronic money institution and payment institution population. The package will repeal PSD2 and EMD2, incorporate EMIs as a PI sub-category requiring reauthorisation, default payment institutions to Method B for own-funds calculation, and introduce a new discretionary central-bank safeguarding option. Separately, the National Bank of Belgium has taken an active preparatory posture toward PSR/PSD3/FiDA implementation and endorses EU open-banking guidelines, positioning Belgium as an early mover in the open-finance transition rather than a reactive adopter. An April 2026 EU-wide instant-payments reporting checkpoint also touched Belgium's supervisory apparatus, though the July 2027 non-eurozone send-deadline this checkpoint precedes does not directly target Belgium given its existing TIPS integration.

#### Outlook

The near-term markers for Belgium are the PSR's Official Journal publication, expected summer 2026, which will fix the application dates for verification-of-payee and the thirty-month non-bank reauthorisation clock, and any National Bank of Belgium implementation guidance published once the compromise text is formally adopted. No Belgium-specific enforcement or supervisory action was identified this cycle; the jurisdiction's regulatory-direction assessment is tightening, driven by the reform pipeline rather than by enforcement activity.

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### W1a Licensing, Authorisation & Market Access Confirmed confirmed 2026-07-04

Belgian payment/e-money institutions remain authorised under PSD2/EMD2 via the NBB (prudential) and FSMA (conduct/open-banking); PSD3/PSR text approved by national representatives 22 April 2026, formal adoption expected later in 2026, ahead of national transposition that will fold EMIs into a reauthorised PI category under PSD3.

Horizon · 2027-Q4 (±half_year) PSD3/PSR anticipated entry into force with transitional licensing provisions_proposed · TT3_

Standing sub-brief · as of 4 July 2026 165 words · last cycle 2026-09-21

#### Licensing, Authorisation & Market Access

Belgium runs the standard EEA PSD2/EMD2 licensing model. The National Bank of Belgium authorises and registers payment institutions and electronic money institutions under the Law of 11 March 2018, with full inbound and outbound EEA passporting; a lighter 'limited' waiver regime applies below EUR1 million in payment volume or EUR1.5 million in e-money outstanding, without passporting rights. From January 2026, the Law of 11 December 2025 adds a mandatory licensing and authorisation framework for crypto-asset issuers and exchanges, an adjacent market-access track running alongside the conventional PI/EMI regime -- creating a dual-authorisation landscape for firms whose products span e-money and tokenised value. No sub-national or federalised nesting applies to Belgium's unitary PI/EMI licensing regime.

#### Outlook

The MiCA/CASP track and the PI/EMI regime will operate as parallel authorisation tracks through 2026, with the transitional CASP regime closing on 1 July 2026; firms bridging both e-money and crypto-asset activity should expect continued dual-track compliance obligations rather than convergence in the near term.

Periodic update · new data 2026-09-21

#### Licensing, Authorisation & Market Access

Belgium's crypto-asset market-access framework has crystallised this cycle from statutory allocation into active enforcement. The Belgian Law of 11 December 2025, in force from 3 January 2026, implements MiCA domestically and allocates authorisation and supervision of crypto-asset service providers (CASPs) between two authorities: the FSMA, which holds general conduct authority over CASP authorisation, and the National Bank of Belgium, which takes prudential responsibility specifically for CASPs that are already subject to prudential supervision on other grounds. This twin-peaks allocation defines Belgium's standing market-access model for crypto-asset activity going forward, carrying both bank/PSP-adjacent prudential oversight (via the NBB, for the subset of already-supervised entities) and a broader non-bank conduct-authorisation track (via the FSMA) within a single authorisation regime.

The transitional arrangement that allowed providers operating under Belgium's prior national regime to continue without full MiCA-CASP authorisation expired on 1 July 2026. The FSMA's response was immediate and public: it named six unauthorised crypto-asset service providers still active in the Belgian market after the transitional deadline passed. This is the first concrete market-access enforcement output tied to the new authorisation perimeter, and it establishes that the transitional-expiry date functioned as an operative compliance deadline rather than a purely administrative marker -- providers that did not secure authorisation in time faced immediate public exposure.

The market-access significance here is twofold. First, the authorisation perimeter itself is now clearly defined and dual-tracked between a conduct regulator and a prudential regulator, which is a materially different structure from a single-authority licensing model and has implications for how new entrants sequence their authorisation applications depending on whether they fall within NBB's prudential-supervision scope. Second, the FSMA's willingness to name unauthorised providers publicly, immediately following the transitional deadline, signals an active rather than passive enforcement posture toward the authorisation boundary -- a signal relevant to any operator considering whether informal or partial compliance postures are viable in this market.

#### Outlook

Watch for whether the FSMA's naming tempo against unauthorised CASPs continues beyond this initial post-deadline action, which would indicate a sustained active-enforcement posture toward the authorisation perimeter rather than a one-time clearing exercise. Also watch for how new-entrant applications are sequenced between the FSMA and NBB tracks as the twin-peaks model completes its first full operating cycle.

**3 earlier distinct update(s)**

Periodic update · new data 2026-09-14

#### 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.

Periodic update · new data 2026-09-08

#### 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.

Periodic update · new data 2026-08-26

#### 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.

**Sources and findings (6)**

1. T1 [https://www.nbb.be/doc/cp/eng/2022/application_guide_payment_institutions.pdf](https://www.nbb.be/doc/cp/eng/2022/application_guide_payment_institutions.pdf) retrieved 2026-07-04
2. T1 [https://www.nbb.be/doc/cp/eng/2022/application_guide_payment_institutions.pdf](https://www.nbb.be/doc/cp/eng/2022/application_guide_payment_institutions.pdf) retrieved 2026-07-04
3. T1 [https://www.eba.europa.eu/risk-and-data-analysis/data/registers/payment-institutions-register](https://www.eba.europa.eu/risk-and-data-analysis/data/registers/payment-institutions-register) retrieved 2026-07-04
4. T3 [https://paymentscompliance.com/premium-content/research_report/belgium-practical-guide-licensing-requirements-payment-institutions](https://paymentscompliance.com/premium-content/research_report/belgium-practical-guide-licensing-requirements-payment-institutions) retrieved 2026-07-04
5. T3 [https://regulatorycounsel.co.uk/payment-institutions/belgium](https://regulatorycounsel.co.uk/payment-institutions/belgium) retrieved 2026-07-04
6. T1 [https://www.ictrechtswijzer.be/en/crypto-assets-in-belgium-an-analysis-of-the-law-of-december-11-2025-and-the-implementation-of-mica/](https://www.ictrechtswijzer.be/en/crypto-assets-in-belgium-an-analysis-of-the-law-of-december-11-2025-and-the-implementation-of-mica/) retrieved 2026-07-04

### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-04

Safeguarding requirements remain largely PSD2-aligned; PSD3 adds an option for PIs to safeguard customer funds directly at a central bank (at that bank's discretion), mitigating fund-concentration risk.

Standing sub-brief · as of 4 July 2026 190 words · last cycle 2026-09-08

#### Conduct, Safeguarding & Promotions

Safeguarding of client and e-money funds is governed by Articles 42 and 194 of the Law of 11 March 2018, transposing PSD2 Article 10, requiring segregation of funds in a distinct client account, global or individualised, held at an EU credit institution. An NBB circular permits an equivalent-safeguarding discharge where funds are instead protected by an EU-authorised intermediary payment service provider in an outsourced payout chain. On the conduct side, Belgium bans merchant surcharging outright for any payment instrument under Article VII.30 §3 of the Code of Economic Law -- covering debit and credit cards as well as SEPA credit transfers and direct debits -- exceeding the baseline set by the EU Interchange Fee Regulation. Conduct-of-business rules otherwise sit in Book VII of the Code of Economic Law, enforced by the FPS Economy, with the FSMA also active on rules of conduct and unlawful or unauthorised offers.

#### Outlook

The safeguarding and surcharge-ban baseline is stable and unlikely to shift materially in the near term; the main watch item is whether NBB's equivalent-safeguarding discharge is invoked more widely as outsourced payout structures spread among non-bank PI/EMI providers.

Periodic update · new data 2026-09-08

#### Conduct, Safeguarding & Financial Promotions

The FSMA issued a public warning on 20 August 2026 against dubious WhatsApp investment-solicitation groups targeting Belgian consumers.

A further FSMA warning on 10 August 2026 flagged fraudulent trading platforms using fabricated press articles to lend false legitimacy.

#### Outlook

Neither warning reflects a rule change; both illustrate a steady consumer-fraud risk backdrop for platforms operating in Belgium, consistent with routine FSMA enforcement cadence rather than a shift in the regulatory perimeter.

**1 earlier distinct update(s)**

Periodic update · new data 2026-08-26

#### 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.

**Sources and findings (6)**

1. T2 [https://www.twobirds.com/-/media/new-website-content/pdfs/2023/js_safeguarding_030223.pdf](https://www.twobirds.com/-/media/new-website-content/pdfs/2023/js_safeguarding_030223.pdf) retrieved 2026-07-04
2. T2 [https://www.twobirds.com/-/media/new-website-content/pdfs/2023/js_safeguarding_030223.pdf](https://www.twobirds.com/-/media/new-website-content/pdfs/2023/js_safeguarding_030223.pdf) retrieved 2026-07-04
3. T3 [https://paymentscompliance.com/premium-content/research_report/belgium-practical-guide-licensing-requirements-payment-institutions](https://paymentscompliance.com/premium-content/research_report/belgium-practical-guide-licensing-requirements-payment-institutions) retrieved 2026-07-04
4. T3 [https://mathieudesmet.blog/en/surcharges-psd2/](https://mathieudesmet.blog/en/surcharges-psd2/) retrieved 2026-07-04
5. T1 [https://en.wikipedia.org/wiki/Financial_Services_and_Markets_Authority_(Belgium)](https://en.wikipedia.org/wiki/Financial_Services_and_Markets_Authority_(Belgium)) retrieved 2026-07-04
6. T1 [https://www.fsma.be/en/warnings-list-companies-operating-unlawfully-belgium](https://www.fsma.be/en/warnings-list-companies-operating-unlawfully-belgium) retrieved 2026-07-04

### W2 Stablecoins & Digital Money Confirmed confirmed 2026-07-04

Belgium's MiCA transitional period for pre-existing VASPs/CASPs expired 1 July 2026; FSMA confirms zero FSMA-granted MiCA authorisations and has added six unauthorised firms to its fraudulent-CASP list since 6 July 2026.

Horizon · 2026-Q3 (±half_year) Bank-consortium MiCA-compliant euro stablecoin launch_proposed · TT3_

Horizon · 2026-07-01 (±quarter) MiCA transitional CASP regime ends_in_force_pending · TT1_

Horizon · 2026-Q3 (±half_year) Bank-consortium MiCA-compliant euro stablecoin launch_proposed · TT3_

Standing sub-brief · as of 4 July 2026 139 words · last cycle 2026-10-18

#### Stablecoins & Digital Money

The Law of 11 December 2025 establishes Belgium's post-MiCA supervisory architecture on a twin-peaks basis: the National Bank of Belgium is competent for asset-referenced tokens and e-money tokens, treating the latter as e-money, while the FSMA supervises crypto-asset service provider authorisation, conduct, and other crypto-asset white papers. A transitional regime for firms already operating as CASPs runs to 1 July 2026. Separately, a consortium of European banks including Belgium's KBC has announced plans for a MiCA-compliant euro stablecoin targeted for the second half of 2026, though no Belgium-specific significant ART or EMT designation by the NBB has yet been published.

#### Outlook

The transitional CASP regime's close on 1 July 2026 is the defining near-term milestone; expect FSMA authorisation decisions and possible NBB significant-token designations to follow, alongside progress reports on the bank-consortium's targeted stablecoin launch.

Periodic update · new data 2026-10-18

#### Stablecoins & Digital Money

Belgium's MiCA transitional period for pre-existing virtual-asset-service-provider registrations — covering both domestically registered and foreign-registered firms passporting into the Belgian market — expired on 1 July 2026. As of that deadline, the FSMA has confirmed that no crypto-asset service provider holds FSMA-granted MiCA authorisation. Within days, on or around 6 July 2026, the FSMA added six unauthorised crypto-asset service providers to its fraudulent-CASP warning list, marking the first enforcement action taken since the transitional period closed.

Supervisory responsibility for digital-asset activity in Belgium runs along twin-peaks lines established by the Law of 11 December 2025 implementing MiCA, which entered into force on 3 January 2026. The National Bank of Belgium holds lead supervisory competence for Asset-Referenced Tokens and E-Money Tokens, and additionally for CASP-services conducted by entities the NBB already supervises for other purposes (such as credit institutions). The FSMA supervises all other CASPs, including conduct-of-business matters and marketing, and it is the FSMA that exercised the July 2026 enforcement action. A related procedural instrument, FSMA Communication 2026_02 of 29 January 2026, sets out the specific notification procedures for crypto-asset white papers and marketing materials for offers and admissions, excluding ARTs and EMTs specifically — supporting the broader authorisation and disclosure framework now being tested against the zero-authorisation reality.

The practical effect for payments-sector participants is that Belgium now has a fully legislated and operationally supervised stablecoin/digital-money framework, but one with no confirmed authorised participant as of the most recent deadline, and an active enforcement posture against unauthorised activity in the interim. This combination — complete legal architecture, zero confirmed authorisations, active enforcement against non-compliant operators — is the structural fact to carry forward for Belgium's digital-money regulatory posture.

#### Outlook

Whether any applicant achieves FSMA CASP authorisation following the 1 July 2026 deadline is the central item to track, since it would be the first instance of the authorisation framework actually producing an authorised participant rather than only enforcement against unauthorised ones. KBC Bank's full CASP notification via its Bolero platform, tracked under Commercial Intelligence below, is the most concrete authorisation-track application currently identifiable and would be a useful bank-channel test case if it resolves.

**2 earlier distinct update(s)**

Periodic update · new data 2026-10-11

#### 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.

Periodic update · new data 2026-09-08

#### 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.

**Sources and findings (5)**

1. T1 [https://www.fsma.be/en/crypto-asset-service-provider-casp](https://www.fsma.be/en/crypto-asset-service-provider-casp) retrieved 2026-07-04
2. T1 [https://www.ictrechtswijzer.be/en/crypto-assets-in-belgium-an-analysis-of-the-law-of-december-11-2025-and-the-implementation-of-mica/](https://www.ictrechtswijzer.be/en/crypto-assets-in-belgium-an-analysis-of-the-law-of-december-11-2025-and-the-implementation-of-mica/) retrieved 2026-07-04
3. T1 [https://www.fsma.be/en/crypto-asset-service-provider-casp](https://www.fsma.be/en/crypto-asset-service-provider-casp) retrieved 2026-07-04
4. T3 [https://www.o2k.tech/blog/update-mica-benelux](https://www.o2k.tech/blog/update-mica-benelux) retrieved 2026-07-04
5. T3 [https://www.plasma.to/learn/tools/stablecoin-regulation-map/belgium](https://www.plasma.to/learn/tools/stablecoin-regulation-map/belgium) retrieved 2026-07-04

### W3 Operational Resilience & Critical Infra Confirmed confirmed 2026-07-04

Belgium's domestic clearing system (CEC) completed the core Instant Payments Regulation build-out in 2025: mandatory receipt of instant SEPA credit transfers from 9 January 2025 and mandatory sending from 9 October 2025, with Verification-of-Payee (VoP) functionality for both instant and standard credit transfers introduced centrally by CEC on the same October date. NBB's 2026 oversight priority is monitoring compliance with the SIPS Regulation and related IPR recommendations rather than fresh build-out.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/belgium/)

Horizon · 2026 (±year) SWIFT expected formal systemic-provider designation under Belgian law_proposed · TT1_

Standing sub-brief · as of 4 July 2026 134 words · last cycle 2026-09-28

#### Operational Resilience & Critical Infrastructure

DORA has applied to Belgian financial entities, including payment and e-money institutions, since 17 January 2025, with the NBB and FSMA as competent authorities; the NBB's TIBER-BE programme requires threat-led penetration testing every three years for significant entities. A 2025 NBB survey of 132 financial entities found policy documents and procedures still under development in several areas, with some entities yet to complete ICT-asset-to-critical-function dependency mapping. A revised SWIFT oversight framework introduces legally enforceable governance requirements, with SWIFT expected to be formally designated a systemic provider under Belgian law in 2026 and the NBB retaining its lead-overseer role.

#### Outlook

Expect the formal SWIFT systemic-provider designation to crystallise during 2026, and continued NBB supervisory follow-up on the compliance gaps identified in the 2025 DORA survey, particularly around ICT-asset dependency mapping.

Periodic update · new data 2026-09-28

#### Operational Resilience & Critical Infrastructure

Belgium's payments infrastructure completed a significant structural upgrade during 2025 under the SEPA Instant Payments Regulation. The National Bank of Belgium confirms that CEC (Centre for Exchange and Clearing) direct and indirect participants were required to be able to receive instant SEPA credit transfers from 9 January 2025, with the corresponding obligation to send instant transfers taking effect from 9 October 2025. This two-stage mandate -- receive-side first, send-side second -- reflects the standard SEPA Instant Payments Regulation implementation sequencing applied across the euro area, and Belgium's clearing infrastructure has now completed both stages.

On the same 9 October 2025 date that the send-side mandate took effect, CEC introduced centrally-provided Verification of Payee, checking IBAN and account-holder name for both instant and standard credit transfers. Centralising this verification at the clearing-infrastructure level, rather than leaving it to individual participant banks, indicates a systemic approach to closing the account-mismatch fraud vector across the entire scheme membership simultaneously, rather than a patchwork of participant-level implementations.

Having completed the build-out, the National Bank of Belgium has named monitoring of implementation of an action plan for SIPS Regulation compliance as its stated 2026 oversight priority, describing this as a multi-year process. This indicates that Belgium's operational-resilience regulatory attention has now shifted from infrastructure construction to ongoing compliance assurance and monitoring, consistent with a mature systemically important payment system moving into steady-state supervision.

#### Outlook

The multi-year SIPS Regulation compliance action plan that the National Bank of Belgium is now monitoring is the key operational-resilience thread to track going forward, as is whether any further verification-of-payee or fraud-prevention layers are added on top of the centrally-provided service introduced in October 2025.

**1 earlier distinct update(s)**

Periodic update · new data 2026-09-21

#### 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.

**Sources and findings (5)**

1. T3 [https://practiceguides.chambers.com/practice-guides/cybersecurity-2026/belgium/trends-and-developments](https://practiceguides.chambers.com/practice-guides/cybersecurity-2026/belgium/trends-and-developments) retrieved 2026-07-04
2. T3 [https://practiceguides.chambers.com/practice-guides/cybersecurity-2026/belgium/trends-and-developments](https://practiceguides.chambers.com/practice-guides/cybersecurity-2026/belgium/trends-and-developments) retrieved 2026-07-04
3. T3 [https://www.timelex.eu/en/blog/navigating-dora-requirements-preparation-and-impact](https://www.timelex.eu/en/blog/navigating-dora-requirements-preparation-and-impact) retrieved 2026-07-04
4. T1 [https://www.nbb.be/en/media/21109](https://www.nbb.be/en/media/21109) retrieved 2026-07-04
5. T1 [https://financialforum.be/en/bfw-digitaal/the-2025-financial-and-market-infrastructures-and-payment-services-report](https://financialforum.be/en/bfw-digitaal/the-2025-financial-and-market-infrastructures-and-payment-services-report) retrieved 2026-07-04

### W4 Scheme & Network Compliance Confirmed confirmed 2026-07-04

Bancontact (Bancontact Pay/Payconiq) is Belgium's dominant domestic debit scheme, overseen directly by NBB alongside Mastercard Europe, Maestro and MCMS. Belgium bans merchant card surcharging outright, exceeding the EU IFR baseline.

Standing sub-brief · as of 4 July 2026 106 words · last cycle 2026-07-04

#### Scheme & Network Compliance

Bancontact (Bancontact Pay/Payconiq) is Belgium's dominant domestic debit scheme, present on over 94% of debit cards in circulation, and is directly overseen by the NBB alongside Mastercard Europe, Maestro and MCMS. Visa's updated Acquirer Monitoring Program raises chargeback-rate thresholds and enforcement stakes for acquirers generally, a change applicable to Belgian-headquartered acquirer Worldline's scheme membership specifically amid its ongoing high-risk-merchant scrutiny. No Belgium-specific interchange-fee derogation under the EU Interchange Fee Regulation has been identified.

#### Outlook

Watch for scheme-level consequences at Worldline as VAMP enforcement escalates; a material chargeback or high-risk-merchant breach finding could trigger scheme-membership conditions beyond the current prosecutorial and reputational exposure.

no periodic updates on record for this sub-brief

** Sources and findings (5)**

1. T1 [https://www.nbb.be/en/financial-supervision-and-resolution/oversight-payment-systems-and-financial-market-infrastructures](https://www.nbb.be/en/financial-supervision-and-resolution/oversight-payment-systems-and-financial-market-infrastructures) retrieved 2026-07-04
2. T3 [https://www.ppro.com/payment-methods/bancontact/](https://www.ppro.com/payment-methods/bancontact/) retrieved 2026-07-04
3. T2 [https://www.bancontact.com/en/news/2-5-billion-payments-with-bancontact-and-payconiq-in-2024-2-5-billion-times-thank-you-for-your-trust-in-us](https://www.bancontact.com/en/news/2-5-billion-payments-with-bancontact-and-payconiq-in-2024-2-5-billion-times-thank-you-for-your-trust-in-us) retrieved 2026-07-04
4. T3 [https://mathieudesmet.blog/en/surcharges-psd2/](https://mathieudesmet.blog/en/surcharges-psd2/) retrieved 2026-07-04
5. T3 [https://businessofpayments.com/2025/07/30/newsletter-july-2025/](https://businessofpayments.com/2025/07/30/newsletter-july-2025/) retrieved 2026-07-04

### W5 Payment Corridor Dynamics Confirmed confirmed 2026-07-04

Belgium is a founding-wave market for Wero, running on SEPA Instant rails, and is fully integrated into SEPA/SEPA Instant, TARGET2-BE, and the Eurosystem's digital-euro preparatory work.

Standing sub-brief · as of 4 July 2026 120 words · last cycle 2026-07-04

#### Payment Corridor Dynamics

Wero, the pan-European instant-payment wallet built on SEPA Instant Credit Transfer rails, launched in Belgium on 19 November 2024, with Belgium as a founding-wave market. The National Bank of Belgium and the Eurosystem are exploring digital euro issuance in consultation with the National Retail Payments Committee, following the ECB Governing Council's launch of the preparatory phase on 18 October 2023. Belgium's cross-border settlement links, including Euroclear Bank's Swiss cash-correspondent connections previously stressed during the Credit Suisse turbulence, are now assessed as stable under risk-mitigating measures.

#### Outlook

Wero's corridor role should deepen through 2026 as point-of-sale acceptance rolls out; the digital-euro preparatory phase continues without a fixed issuance date, keeping this a multi-year rather than near-term corridor development.

no periodic updates on record for this sub-brief

** Sources and findings (4)**

1. T3 [https://en.wikipedia.org/wiki/Wero_(payment)](https://en.wikipedia.org/wiki/Wero_(payment)) retrieved 2026-07-04
2. T2 [https://worldline.com/en/home/main-navigation/resources/blogs/2026/wero-unlocking-pan-european-digital-commerce](https://worldline.com/en/home/main-navigation/resources/blogs/2026/wero-unlocking-pan-european-digital-commerce) retrieved 2026-07-04
3. T1 [https://www.bis.org/cpmi/publ/d105.pdf](https://www.bis.org/cpmi/publ/d105.pdf) retrieved 2026-07-04
4. T1 [https://www.nbb.be/en/payments-and-securities/digital-euro](https://www.nbb.be/en/payments-and-securities/digital-euro) retrieved 2026-07-04

### W6 Industry Structure & Commercial Probable confirmed 2026-07-04

Belgium's payments market blends institutional depth (NBB/FSMA twin-peaks, Euroclear, Bancontact Payconiq Company) with a growing private fintech layer of 200+ firms, coordinated informally via FinTech Belgium.

Standing sub-brief · as of 4 July 2026 114 words · last cycle 2026-07-04

#### Industry Structure & Commercial Dynamics

Since 1 April 2011, Belgian financial-sector supervision has followed the Twin Peaks model: the National Bank of Belgium handles prudential supervision and the FSMA handles conduct and consumer protection. Belgium's fintech landscape includes over 200 active firms spanning payments, regtech, SME finance and digital infrastructure, informally coordinated via the FinTech Belgium association. This blends institutional depth -- NBB/FSMA twin-peaks supervision, Euroclear, and the Bancontact Payconiq Company -- with a growing private fintech layer.

#### Outlook

The twin-peaks structure is stable and not expected to change; the fintech ecosystem's trajectory depends substantially on how the MiCA/CASP licensing track and the Worldline episode reshape investor and provider confidence over the coming year.

no periodic updates on record for this sub-brief

** Sources and findings (4)**

1. T3 [https://thefintechtimes.com/belgium-and-its-fintech-and-wider-digital-landscape-in-2026/](https://thefintechtimes.com/belgium-and-its-fintech-and-wider-digital-landscape-in-2026/) retrieved 2026-07-04
2. T3 [https://intrepidventures.net/europes-largest-payment-processor-worldline-faces-a-reckoning/](https://intrepidventures.net/europes-largest-payment-processor-worldline-faces-a-reckoning/) retrieved 2026-07-04
3. T3 [https://www.fintechbelgium.be/](https://www.fintechbelgium.be/) retrieved 2026-07-04
4. T1 [https://www.nbb.be/en/financial-supervision-and-resolution/oversight-payment-systems-and-financial-market-infrastructures](https://www.nbb.be/en/financial-supervision-and-resolution/oversight-payment-systems-and-financial-market-infrastructures) retrieved 2026-07-04

### W7 Legal & Litigation Confirmed confirmed 2026-07-04

Belgian financial-services litigation runs through a specialised Commercial Court cease-and-desist track alongside the NBB/FSMA Sanctions Committee administrative-fine process; recent activity includes a major AML fine against BNP Paribas Fortis and an active Brussels Public Prosecutor investigation into Worldline's Belgian acquiring unit.

Standing sub-brief · as of 4 July 2026 120 words · last cycle 2026-07-04

#### Legal & Litigation

The NBB Sanctions Committee fined BNP Paribas Fortis EUR15 million in 2023 for 'egregious' anti-money-laundering failings between 2014 and 2019, including inadequate customer due diligence. More acutely, the Brussels Public Prosecutor's Office is investigating Worldline's Belgian unit following June 2025 press reports -- the 'Dirty Payments' exposé -- alleging continued high-risk merchant processing; the reporting was associated with a one-day share-price collapse of more than 40%. Belgian financial-services litigation otherwise runs through a specialised Commercial Court track alongside the NBB/FSMA Sanctions Committee's administrative-fine process.

#### Outlook

The Worldline investigation is the pivotal near-term litigation event for Belgium's payments sector; its outcome, and whether NBB/FSMA pursue any parallel administrative action, will shape scheme-membership and licensing risk well beyond 2026.

no periodic updates on record for this sub-brief

** Sources and findings (5)**

1. T3 [https://amlnetwork.org/aml-news/belgium-plans-to-name-and-shame-more-banks-for-serious-aml-breaches-in-2026-crackdown/](https://amlnetwork.org/aml-news/belgium-plans-to-name-and-shame-more-banks-for-serious-aml-breaches-in-2026-crackdown/) retrieved 2026-07-04
2. T3 [https://intrepidventures.net/europes-largest-payment-processor-worldline-faces-a-reckoning/](https://intrepidventures.net/europes-largest-payment-processor-worldline-faces-a-reckoning/) retrieved 2026-07-04
3. T3 [https://fintelegram.com/dirty-payments-exposed-worldlines-gateway-from-growth-engine-to-fraud-pipeline-shares-crater-41/](https://fintelegram.com/dirty-payments-exposed-worldlines-gateway-from-growth-engine-to-fraud-pipeline-shares-crater-41/) retrieved 2026-07-04
4. T3 [https://www.lexology.com/library/detail.aspx?g=8ed6867b-05e9-4e26-b986-3c2df32a1d33](https://www.lexology.com/library/detail.aspx?g=8ed6867b-05e9-4e26-b986-3c2df32a1d33) retrieved 2026-07-04
5. T1 [https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-belgium-2025.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/mer-belgium-2025.html) retrieved 2026-07-04

### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-04

Merchant acquiring in Belgium is dominated by Worldline, operating under Visa/Mastercard scheme monitoring regimes for chargeback and high-risk-merchant control; the sector is currently under acute regulatory and prosecutorial scrutiny over high-risk-merchant onboarding practices.

Standing sub-brief · as of 4 July 2026 103 words · last cycle 2026-07-04

#### Merchant Acquiring & Risk

Merchant acquiring in Belgium is dominated by Worldline, whose Belgian activities fall under NBB oversight and Visa/Mastercard scheme monitoring regimes for chargeback and high-risk-merchant control. Worldline has disclosed that high-risk merchant volumes represent 1.5% of acquiring volumes within its Merchant Services business, a figure offered in response to the 'Dirty Payments' allegations. The acquiring sector is currently under acute regulatory and prosecutorial scrutiny over high-risk-merchant onboarding practices.

#### Outlook

Expect continued scrutiny of Worldline's merchant-risk controls as the prosecutorial investigation proceeds; any further scheme-level findings on chargeback or high-risk-merchant exposure would extend acute conditions into 2026 underwriting and onboarding practice.

no periodic updates on record for this sub-brief

** Sources and findings (4)**

1. T2 [https://investors.worldline.com/content/dam/investors-worldline-com/assets/documents/regulated-information/dept-and-rating/s-p-final-worldline-faq-2-july-2025.pdf](https://investors.worldline.com/content/dam/investors-worldline-com/assets/documents/regulated-information/dept-and-rating/s-p-final-worldline-faq-2-july-2025.pdf) retrieved 2026-07-04
2. T3 [https://businessofpayments.com/2025/07/30/newsletter-july-2025/](https://businessofpayments.com/2025/07/30/newsletter-july-2025/) retrieved 2026-07-04
3. T2 [https://worldline.com/content/dam/worldline/global/documents/white-papers/white-paper-acquiring-en.pdf](https://worldline.com/content/dam/worldline/global/documents/white-papers/white-paper-acquiring-en.pdf) retrieved 2026-07-04
4. T3 [https://intrepidventures.net/europes-largest-payment-processor-worldline-faces-a-reckoning/](https://intrepidventures.net/europes-largest-payment-processor-worldline-faces-a-reckoning/) retrieved 2026-07-04

### W9 Product Innovation & Market Development limited signal Probable confirmed 2026-07-04

Belgium is a lead market for pan-European instant-payment innovation via Wero, sits inside the Eurosystem digital-euro preparatory phase, and hosts an active fintech innovation scene recognised via the Digital Finance Awards Belgium.

Horizon · 2026 (±year) Wero point-of-sale acceptance launch in Belgium_in_force_pending · TT3_

Standing sub-brief · as of 4 July 2026 74 words · last cycle 2026-09-28

#### Product Innovation & Market Development

Wero's e-commerce acceptance in Belgium began from November 2025/January 2026, with point-of-sale acceptance planned for later in 2026. Belgium sits inside the Eurosystem's digital-euro preparatory phase and hosts an active fintech innovation scene recognised via the Digital Finance Awards Belgium.

#### Outlook

Point-of-sale Wero acceptance during 2026 is the key product-development milestone to track; its rollout pace will indicate how quickly Belgium's instant-payments infrastructure converts from e-commerce-only to omnichannel acceptance.

Periodic update · new data 2026-09-28

#### Product Innovation & Market Development

Five Belgian banks -- ING Belgium, Argenta, Bank van Breda, Beobank, Crelan, and vdk bank -- joined the European Payments Initiative in July 2025, enabling the Wero pan-European instant-payment wallet for their customers. This expands Belgium's domestic account-to-account product landscape with a wallet-layer offering built on top of the underlying SEPA instant-payment clearing infrastructure that CEC completed building out over the same period.

The Wero expansion into Belgium is best understood as a product-layer development distinct from, but dependent upon, the infrastructure-layer instant-payments build-out: Wero relies on the same instant-transfer rails that CEC participants became obligated to support in 2025, and its bank-by-bank rollout pattern -- five named banks joining EPI in a single month -- suggests a coordinated onboarding wave rather than a gradual, uncoordinated adoption curve.

Sourcing for this development is a secondary reference rather than a direct primary-source confirmation from EPI or the participating banks themselves, so the specific onboarding date and bank list should be treated with appropriately calibrated confidence pending further corroboration.

#### Outlook

Whether additional Belgian banks join EPI and enable Wero beyond the five named this cycle is the primary development to track for continued account-to-account product expansion in the Belgian market. The interaction between Wero's wallet-layer user experience and the underlying mandatory instant-payment and Verification-of-Payee infrastructure completed in 2025 is also worth monitoring as adoption grows.

**2 earlier distinct update(s)**

Periodic update · new data 2026-09-08

#### 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.

Periodic update · new data 2026-08-26

#### 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.

**Sources and findings (4)**

1. T3 [https://banking.vision/en/development-wero-2025-2026/](https://banking.vision/en/development-wero-2025-2026/) retrieved 2026-07-04
2. T3 [https://en.wikipedia.org/wiki/Wero_(payment)](https://en.wikipedia.org/wiki/Wero_(payment)) retrieved 2026-07-04
3. T3 [https://www.fintechbelgium.be/news/press-release-the-digital-finance-awards-belgium-2026-celebrates-the-best-and-brightest-in-digital-finance](https://www.fintechbelgium.be/news/press-release-the-digital-finance-awards-belgium-2026-celebrates-the-best-and-brightest-in-digital-finance) retrieved 2026-07-04
4. T1 [https://www.nbb.be/en/payments-and-securities/digital-euro](https://www.nbb.be/en/payments-and-securities/digital-euro) retrieved 2026-07-04

### W10 Consumer Protection & APP Fraud Confirmed confirmed 2026-07-04

Consumer protection for unauthorised/fraudulent payments runs on a 'reimburse-first, litigate-later' model under Articles VII.43-VII.44 CEL, with a EUR50 liability cap for lost/stolen instruments; a March 2026 Brussels Commercial Court ruling reinforced the reimbursement obligation even in a B2B context.

Standing sub-brief · as of 4 July 2026 94 words · last cycle 2026-07-04

#### Consumer Protection & APP Fraud

A 19 March 2026 Brussels Commercial Court ruling ordered a bank to reimburse EUR40,960.56 to a business owner victimised by cyber fraud, confirming that Belgium's 'reimburse-first, litigate-later' protection under Articles VII.43-VII.44 of the Code of Economic Law extends into a business-to-business context, not merely retail. The underlying regime otherwise carries a EUR50 liability cap for lost or stolen payment instruments.

#### Outlook

The March 2026 ruling strengthens reimbursement certainty for Belgian payment-fraud victims, including businesses; expect claimants and their counsel to cite it as precedent in future B2B fraud-reimbursement disputes.

no periodic updates on record for this sub-brief

** Sources and findings (5)**

1. T3 [https://www.ictrechtswijzer.be/en/refund-from-the-bank-for-a-fraudulent-wire-transfer/](https://www.ictrechtswijzer.be/en/refund-from-the-bank-for-a-fraudulent-wire-transfer/) retrieved 2026-07-04
2. T3 [https://www.ictrechtswijzer.be/en/refund-from-the-bank-for-a-fraudulent-wire-transfer/](https://www.ictrechtswijzer.be/en/refund-from-the-bank-for-a-fraudulent-wire-transfer/) retrieved 2026-07-04
3. T3 [https://www.lexology.com/library/detail.aspx?g=3e5d6512-78dc-448f-bda0-9258c73ce00f](https://www.lexology.com/library/detail.aspx?g=3e5d6512-78dc-448f-bda0-9258c73ce00f) retrieved 2026-07-04
4. T3 [https://iclg.com/practice-areas/consumer-protection-laws-and-regulations/belgium/](https://iclg.com/practice-areas/consumer-protection-laws-and-regulations/belgium/) retrieved 2026-07-04
5. T3 [https://iclg.com/practice-areas/consumer-protection-laws-and-regulations/belgium/](https://iclg.com/practice-areas/consumer-protection-laws-and-regulations/belgium/) retrieved 2026-07-04

### W11 AML/CFT & Financial Crime [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/belgium/#sec-dom-D7) Confirmed confirmed 2026-07-04

Sentinel.gi payments-context position: Belgium's AML/CFT regime is assessed by FATF (Dec 2025) as largely aligned with FATF standards but with continuing effectiveness gaps, particularly on virtual-asset rules; a 2026 policy shift toward public 'name and shame' disclosure of non-compliant banks is under way.

Standing sub-brief · as of 4 July 2026 128 words · last cycle 2026-07-04

#### AML/CFT & Financial Crime

Sentinel.gi-fed position: the FATF's December 2025 Mutual Evaluation found Belgium's AML/CFT/CPF system technically largely aligned with FATF Recommendations, but identified continuing effectiveness gaps, particularly on virtual-asset rules. Amid criticism that past NBB Sanctions Committee fines -- in the EUR50,000 to EUR350,000 range -- were insufficient deterrents, the NBB and FSMA are reported to be moving toward a 2026 policy of publicly naming non-compliant banks. This intelligence is carried into WPM via the Sentinel.gi feed; illicit-finance analysis is not performed within WPM and readers should consult Sentinel.gi directly for underlying financial-crime assessment.

#### Outlook

The 2026 name-and-shame policy shift is the item to track; its implementation would mark a material change in Belgium's AML/CFT enforcement posture relative to the fine-only approach criticised as an insufficient deterrent.

no periodic updates on record for this sub-brief

** Sources and findings (10)**

1. T3 [https://ezine.eversheds-sutherland.com/global-aml-guide/belgium](https://ezine.eversheds-sutherland.com/global-aml-guide/belgium) Applies beyond this jurisdiction (FATF) retrieved 2026-07-04
2. T? FIM (sentinel.gi) per-JID baseline profile — Belgium — Belgium's AML/CFT/CPF regime rests on the AML/CFT Law, CTIF-CFI (FIU), and Twin Peaks supervision (NBB/FSMA). The FATF's December 2025 mutual evaluation found the system technically largely aligned with FATF standards but effectiveness-deficient, placing Belgium in enhanced follow-up with a three-year Key Recommended Actions roadmap.
3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-006) — Gap: sourcing-thinness
4. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-002) — Enforcement: Belgian Federal Prosecutor's Office / Federal Court — Seven-member ISIS crypto-financing and CBRN-precursor procurement network
5. T2 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: EU listing
6. T2 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-004) — Sanctions: national licence-change
7. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: Euroclear Bank SA (in consultation with Belgian/EU authorities) — Holders of frozen Russian foreign-currency bonds
8. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: enforcement-absence
9. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: capacity-deficit
10. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: legal-gap

### W12 Correspondent Banking, Settlement & Access Confirmed confirmed 2026-07-04

Belgian legislation entered into force during the reporting year strengthening the NBB's statutory oversight powers over financial-messaging service providers such as Swift, to be exercised in cooperation with other G10 central banks, reinforcing Belgium's correspondent-banking and settlement-infrastructure supervisory perimeter.

Standing sub-brief · as of 4 July 2026 110 words · last cycle 2026-09-14

#### Correspondent Banking, Settlement & Access

Euroclear Bank, a Belgian-domiciled international central securities depository and licensed credit institution, provides custody and settlement services for international bonds; the National Bank of Belgium is the sole CSDR competent authority for Belgian-law Euroclear entities and lead overseer of SWIFT. This structural position rests on a bank-versus-non-bank access asymmetry: systemically important settlement infrastructure access sits with regulated credit institutions, while non-bank PI/EMI providers depend on correspondent and intermediary arrangements for cross-border reach.

#### Outlook

Correspondent-access asymmetry between bank and non-bank payment providers remains Belgium's structural settlement-access issue; no near-term change is indicated, though SWIFT's expected 2026 systemic-provider designation will reinforce NBB's oversight leverage over this infrastructure.

Periodic update · new data 2026-09-14

#### Correspondent Banking, Settlement & Access

The draft Payment Services Regulation extends Verification-of-Payee obligations to all credit transfers, a materially broader scope than the current Instant Payments Regulation, which limits the Verification-of-Payee requirement to instant credit transfers. This extension reallocates fraud-liability risk further onto payment service providers, since a PSP that fails to perform the now-mandatory payee-name verification check on a standard (non-instant) credit transfer would bear a greater share of liability exposure for resulting fraud than under the current, narrower Instant Payments Regulation regime. For Belgian PSPs operating under NBB and FSMA supervision, this signals a coming infrastructure requirement to extend payee-verification capability across the full range of credit-transfer types they process, not solely instant transfers, ahead of the PSR's eventual formal adoption and national transposition.

This development sits within the broader PSD3/PSR reform package moving through EU adoption this cycle, and it should be read as one specific, analytically distinct component of that package, the component with the most direct settlement-and-access-layer consequence for how Belgian PSPs build out their transaction-processing infrastructure, rather than as the totality of the reform.

#### Outlook

The scope and precise mechanics of the Verification-of-Payee extension will firm up as PSD3/PSR proceeds toward formal EU adoption later in 2026; Belgian PSPs should expect the infrastructure implications of extending payee-verification beyond instant transfers to become concrete once the regulation text is finalised and national transposition begins.

**2 earlier distinct update(s)**

Periodic update · new data 2026-09-08

#### 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.

Periodic update · new data 2026-08-26

#### 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.

**Sources and findings (5)**

1. T1 [https://en.wikipedia.org/wiki/Euroclear_Belgium](https://en.wikipedia.org/wiki/Euroclear_Belgium) Applies beyond this jurisdiction (IMF) retrieved 2026-07-04
2. T1 [https://www.imf.org/-/media/files/publications/cr/2023/english/1belea2023012.pdf](https://www.imf.org/-/media/files/publications/cr/2023/english/1belea2023012.pdf) Applies beyond this jurisdiction (IMF) retrieved 2026-07-04
3. T1 [https://www.nbb.be/en/financial-supervision-and-resolution/oversight-payment-systems-and-financial-market-infrastructures](https://www.nbb.be/en/financial-supervision-and-resolution/oversight-payment-systems-and-financial-market-infrastructures) Applies beyond this jurisdiction (IMF) retrieved 2026-07-04
4. T1 [https://www.nbb.be/doc/ts/publications/fmi-and-paymentservices/2024/fmi-report2024.pdf](https://www.nbb.be/doc/ts/publications/fmi-and-paymentservices/2024/fmi-report2024.pdf) Applies beyond this jurisdiction (IMF) retrieved 2026-07-04
5. T1 [https://www.nbb.be/nl/media/21101](https://www.nbb.be/nl/media/21101) Applies beyond this jurisdiction (IMF) retrieved 2026-07-04

### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-04

Belgian-linked commercial activity in the trailing 12 months is dominated by processor restructuring at Worldline amid the 'Dirty Payments' fallout, continued Wero/bank-consortium investment, and modest early-stage VC activity from Belgian investors.

Standing sub-brief · as of 4 July 2026 172 words · last cycle 2026-10-18

#### Commercial Intelligence

Worldline sold its Ingenico-derived POS terminal business to Apollo Funds and is selling its Mobility & e-Transactions Services business to Magellan Partners; deal value was not publicly disclosed in either transaction, part of a portfolio restructuring amid 'Dirty Payments' fallout and regulatory scrutiny. The European Payments Initiative raised EUR450 million from shareholders including Worldline and Nexi to fund the Wero rollout, adding five new Belgian banks to the distribution network. A consortium of European banks including Belgium's KBC announced a MiCA-compliant euro stablecoin product targeted for the second half of 2026. French wealthtech TwoWay separately secured a EUR1.5 million pre-seed round led by Belgium-based VC firm Welovefounders, one of a thin set of private-company commercial signals surfaced this cycle relative to the breadth of Belgium's 200-plus-firm fintech sector.

#### Outlook

Commercial activity through the remainder of 2026 will likely stay dominated by Worldline's restructuring trajectory and the Wero/EPI investment cycle; watch for confirmation of the bank-consortium stablecoin's targeted second-half launch and for any further disclosed deal value on the Worldline disposals.

Periodic update · new data 2026-10-18

#### Commercial Intelligence & Fintech

Three discrete commercial events mark Belgium's fintech and digital-asset landscape this cycle. KBC Bank's Bolero platform launched retail Bitcoin and Ether trading for retail investors and submitted a full CASP notification to the FSMA, representing the first Belgian bank to extend direct crypto trading access to retail customers through an established banking channel rather than a standalone exchange. This sits within a broader pattern: three large Belgian banks — Belfius, ING, and KBC — have each taken steps to let retail customers access crypto, whether directly or via tracker products, indicating that bank-channel crypto access has become a competitive feature among Belgium's major retail banks rather than a niche offering.

Separately, Brussels-based Chift, a financial-data-connectivity API provider, closed a EUR 10.5 million Series A funding round in September 2026, led by BlackFin Capital Partners. The amount was publicly disclosed. This round forms part of a broader EUR 1.09 billion first-half-2026 Belgian technology funding environment, illustrating continued investor appetite for Belgian financial-infrastructure and connectivity-layer businesses specifically. Belgian crypto market-maker Keyrock continues to be tracked at a Series C-plus valuation profile exceeding $1 billion, a separate signal of capital depth in Belgium's crypto-infrastructure segment specifically, distinct from the retail-banking crypto-access trend described above.

Taken together, these events describe two parallel tracks of commercial activity: incumbent-bank expansion into retail crypto access (KBC, alongside Belfius and ING), and continued venture capital investment into Belgian fintech infrastructure and crypto-native firms (Chift, Keyrock). Neither track is itself a regulatory development, but both occur against the backdrop of the zero-authorisation CASP landscape described under Stablecoins & Digital Money above.

#### Outlook

KBC's CASP notification is the item most likely to generate the next dateable regulatory-adjacent development for this module, since its resolution would be the first authorisation outcome for a bank-channel retail crypto product under Belgium's post-transitional MiCA regime. Continued fintech funding activity, exemplified by Chift, is a market-structure signal to keep tracking independent of the authorisation question specifically.

**2 earlier distinct update(s)**

Periodic update · new data 2026-10-11

#### 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.

Periodic update · new data 2026-09-08

#### 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.

**Sources and findings (4)**

1. T3 [https://www.digitaltransactions.net/magazine_articles/how-to-fix-worldline/](https://www.digitaltransactions.net/magazine_articles/how-to-fix-worldline/) retrieved 2026-07-04
2. T3 [https://www.fintechfutures.com/venture-capital-funding/icymi-fintech-funding-round-up-franq-xmo-twoway-and-more](https://www.fintechfutures.com/venture-capital-funding/icymi-fintech-funding-round-up-franq-xmo-twoway-and-more) retrieved 2026-07-04
3. T3 [https://businessofpayments.com/2025/07/30/newsletter-july-2025/](https://businessofpayments.com/2025/07/30/newsletter-july-2025/) retrieved 2026-07-04
4. T3 [https://www.plasma.to/learn/tools/stablecoin-regulation-map/belgium](https://www.plasma.to/learn/tools/stablecoin-regulation-map/belgium) retrieved 2026-07-04

** No modules match.**

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## Editorial metadata

Provenance only. Nothing below gates publication or affects the render.

Editorial metadata for Belgium| Field | Value |
|---|---|
| `trust.lawyer_review.status` | never_reviewed |
| `trust.lawyer_review.reviewer` | no reviewer on record |
| ` trust.content_source` | ai_generated |

## Provenance and declared absence

**Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is.

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**Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning.

**Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "stablecoin": "emerging-regime"}}}`.

**Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band.

**Orphan deltas:** 2 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card.

**Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 72 finding(s), 215 source(s) in the cumulative register.

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