Digital Payments & Fintech - Belgium

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.