Digital Payments & Fintech · Belgium
EMI license in Belgium: e-money institution (EMI) requirements (2026)
Belgium shaded by its digital payments & fintech status
Fintech and digital payments in Belgium: licensing regime, under EU PSD2 (Directive 2015/2366) and the e-Money Directive (2009/110/EC), transposed by the Belgian Act of 11 March 2018 and codified in Book VII of the Code of Economic Law; supervised principally by the National Bank of Belgium (NBB, prudential) and the FSMA (conduct). Crypto-asset services fall under EU MiCA (Reg. 2023/1114), implemented by the Act of 11 December 2025..
Belgium operates a mature, EU-harmonised licensing regime for digital payments and fintech. Payment institutions (PIs) and electronic money institutions (EMIs) must be authorised by the National Bank of Belgium under the 2018 PSD2 Act, with the FSMA as conduct supervisor under Belgium's 'twin peaks' model. Open banking (PISP/AISP), instant payments, BNPL consumer credit and crypto-asset services are all covered by clear, in-force frameworks.
How to get an EMI license in Belgium
To provide electronic-money or payment services in Belgium you need authorisation as an Electronic Money Institution (EMI), supervised by the National Bank of Belgium (NBB), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
- Authority
- the National Bank of Belgium (NBB)
- License required
- authorisation as an Electronic Money Institution (EMI)
- Framework / law
- the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
- Minimum capital
- €350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
- Timeline
- roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
- Cost
- application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
- Passporting
- Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
EMI license in Belgium: FAQ
Yes. To provide electronic-money or payment services in Belgium you need authorisation as an Electronic Money Institution (EMI), supervised by the National Bank of Belgium (NBB), under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
The National Bank of Belgium (NBB).
Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.
Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.
Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Key points
The NBB is the prudential supervisor that authorises payment institutions and electronic money institutions; the FSMA supervises conduct. The regime stems from PSD2 transposed by the Act of 11 March 2018 (Book VII Code of Economic Law). Belgium hosts a growing number of authorised PIs.
EMIs may issue e-money and offer all payment services; PIs may only provide payment services. A 'light/limited' regime offers reduced capital and reporting requirements for low-volume firms (below EUR 1M/month payments or EUR 1.5M outstanding e-money), but without EEA passporting rights.
PSD2 introduced regulated Payment Initiation Service Providers (PISP) and Account Information Service Providers (AISP), licensed/registered via the NBB. Major Belgian banks (BNP Paribas Fortis, KBC, ING Belgium, Belfius) expose open-banking APIs largely on Berlin Group NextGenPSD2 standards.
The EU Instant Payments Regulation (adopted 13 March 2024) requires PSPs offering euro credit transfers to also send/receive SEPA instant credit transfers at no higher cost than standard transfers. Belgium's domestic CEC system and the Bancontact scheme (overseen by the NBB under PISA) support instant rails.
Buy-now-pay-later falls under regulated consumer credit in Book VII of the Code of Economic Law; providers need an FSMA licence and FPS Economy contract pre-approval. Belgium applies strict limits (repayment within ~2 months, capped charges). The EU Consumer Credit Directive II (CCD II) tightens BNPL rules, with national application due by 20 November 2026.
Belgium implemented EU MiCA via the Act of 11 December 2025 (effective 3 January 2026); crypto-asset service providers (CASPs) are authorised under the twin-peaks split between FSMA and NBB. The EBA has flagged PSD2/MiCA overlap for e-money tokens, with a transition period around 2 March 2026.
Timeline - major decisions & events
The Law of 11 December 2025 implementing MiCA took effect, designating the FSMA and NBB under a 'twin peaks' split and allowing Belgium to begin processing CASP, ART and EMT authorisation applications.
FSMA ↗Euro-area PSPs, including Belgian banks supervised by the NBB, became required to offer outgoing instant euro transfers and verification-of-payee, completing the EU IPR rollout for the eurozone.
ECB ↗The EU Digital Operational Resilience Act became applicable, imposing ICT risk-management, incident-reporting and third-party oversight obligations on payment institutions, EMIs and CASPs supervised in Belgium.
ESMA ↗The crypto-asset service provider (CASP) provisions of Regulation (EU) 2023/1114 took effect EU-wide, establishing the harmonised licensing regime later transposed into Belgian supervisory law.
ESMA ↗The Commission published proposals to merge and update the payments and e-money frameworks, signalling the next overhaul of how payment and fintech firms in Belgium will be licensed and supervised.
EUR-Lex (European Commission) ↗The access-to-account and secure-communication provisions of the Belgian PSD2 Act entered into force, operationalising open-banking access and SCA for Belgian payment service providers.
National Bank of Belgium ↗The Act on the legal status and supervision of payment institutions and e-money institutions was published and entered into force, creating PI/EMI licences, a 'light' regime, and licensing for payment-initiation and account-information services under NBB supervision.
Belgian Official Gazette (ejustice.just.fgov.be) ↗The second Payment Services Directive was enacted at EU level, introducing licensed third-party providers, SCA and stronger conduct rules that Belgium would transpose in 2018.
EUR-Lex ↗Belgium transposed PSD1, creating the original statute and NBB supervision for payment institutions and electronic money institutions, the foundation later replaced by the 2018 PSD2 Act.
National Bank of Belgium ↗Belgium - other topics
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