EMI license in Belgium: e-money institution (EMI) requirements (2026)

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.

The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.

Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.

Yes — an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).

The Act of 11 March 2018 governs authorisation, prudential supervision and passporting for PIs and ELMIs; the National Bank of Belgium is the competent licensing authority and publishes application guides. Initial capital for PIs ranges €20k–€125k depending on services (€350k for ELMIs under EU rules).

Payment institutions may provide the PSD2 payment services list (except issuing e-money); electronic money institutions may additionally issue e-money and provide all payment services. A lighter 'limited/registered' PI regime exists for small operators below de minimis thresholds.

PSD2 was transposed via the 2018 Act; account-servicing PSPs must provide free, consent-based API access to AISPs and PISPs registered/authorised by the NBB. The NBB issued a 2022 communication on removing obstacles to open banking and extending access to credit-card accounts.

Directly applicable EU Regulation 2024/886 obliges all euro-area PSPs to receive SCT Inst from 9 January 2025 and send SCT Inst from 9 October 2025, with mandatory Verification-of-Payee (IBAN-name matching) and abolition of the €100,000 cap; Belgian banks (BNP Paribas Fortis, KBC, ING, Belfius, etc.) are in scope.

Belgium goes beyond the EU baseline: interest-free deferred-payment schemes are only exempt from the consumer-credit regime if repaid within two months and fees do not exceed €5.67/month; other BNPL structures fall under the Code of Economic Law's consumer credit rules (licensing, creditworthiness assessment, etc.). CCD2 will further tighten this from 2026.

The EU PSD3 Directive and directly-applicable Payment Services Regulation (PSR) reached provisional political agreement in November 2025, with publication expected in 2026 and PSD3 transposition due ~18 months later; the PI and EMI regimes will be merged and APP-fraud liability rules tightened, requiring Belgian statutory amendments to the 2018 Act in 2027-2028.