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Fintech & payments regulation in Belgium (2026)

Fintech and digital payments in Belgium: licensing regime.

Belgium operates a fully in-force, EU-harmonised licensing regime for payment institutions (PIs) and electronic money institutions (ELMIs/EMIs), administered by the National Bank of Belgium under the Act of 11 March 2018. Open banking is live under PSD2 (with NBB TPP registration), SEPA instant payments obligations apply since January/October 2025, and BNPL is tightly constrained by the Belgian Code of Economic Law. The upcoming EU PSD3/PSR package (provisional agreement Nov 2025; expected OJ publication in 2026) will refresh this framework once adopted.

Last verified Official sources first · MethodologyCompare Belgium with other countriesAlso in français

Legal framework

Act of 11 March 2018 on the legal status and supervision of payment institutions and electronic money institutions (transposing PSD2/EMD2), supervised by the National Bank of Belgium (NBB); FSMA oversees conduct-of-business. EU-level rules (SEPA Instant Payments Regulation 2024/886) apply directly, with PSD3/PSR reforms progressing at EU level in 2026.

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).

What an EMI license in Belgium covers

  • Issuing electronic money and maintaining payment accounts
  • Executing payment transactions: credit transfers, direct debits and card payments
  • Issuing and/or acquiring payment instruments
  • Money remittance
  • Payment initiation services (PIS)
  • Account information services (AIS)

Step by step: getting an EMI license in Belgium

  1. Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).

  2. Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.

  3. Deposit and evidence the €350,000 initial capital.

  4. Submit the application to the national competent authority.

  5. The authority has three months from a complete application to grant or refuse.

  6. On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.

Documents required in Belgium

  • 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
  • AML/CFT policy and appointment of a compliance officer
  • Safeguarding arrangements for client funds (segregated account or insurance)
  • Security policy, incident management and ICT resilience procedures
  • Fit-and-proper documentation for directors and qualifying shareholders
  • Description of any outsourcing, agents or distributors
  • Professional indemnity insurance where you provide PIS or AIS

Ongoing obligations in Belgium

  • Maintain own funds under the applicable calculation method (A, B or C)
  • Safeguard client funds at all times, segregated or insured
  • Apply strong customer authentication (SCA) under PSD2
  • Run continuous AML/CFT monitoring and reporting
  • Report major operational and security incidents to the regulator
  • Submit annual audited accounts and periodic regulatory reporting

Key points: digital payments & fintech in Belgium

  1. Primary licensing statute & supervisor

    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).

    nbb.be nbb.be

  2. Two-tier PI/EMI distinction

    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.

    nbb.be regulatorycounsel.co.uk

  3. Open banking under PSD2

    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.

    twobirds.com nbb.be

  4. Instant payments (EU IPR 2024/886)

    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.

    ecb.europa.eu ey.com

  5. BNPL: strict national treatment

    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.

    nortonrosefulbright.com fintechbelgium.be

  6. PSD3/PSR reform on the horizon

    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.

    nortonrosefulbright.com legal.pwc.de

EMI license in Belgium: FAQ

Do you need a license to run an e-money business in Belgium?

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).

Which authority issues EMI licenses in Belgium?

The National Bank of Belgium (NBB).

How much does an EMI license cost in Belgium?

Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.

How long does it take to get an EMI license in Belgium?

Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.

What documents do you need for an EMI license in Belgium?

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.

What is the application process for an EMI license in Belgium?

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.

Does an Belgium EMI license work in other EU/EEA countries?

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

Timeline of decisions

  1. Law · official
    Instant Payments Regulation: obligation to send SEPA instant credit transfers

    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

  2. Law · official
    DORA applies to Belgian payment and fintech firms

    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

  3. Law · official
    European Commission proposes PSD3 and Payment Services Regulation

    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)

  4. Law · official
    PSD2 secure-access and strong customer authentication rules take effect

    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

  5. Law · official
    Belgium transposes PSD2 via the Law of 11 March 2018

    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)

  6. Law · official
    EU adopts PSD2 (Directive 2015/2366)

    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

  7. Law · official
    Belgium's first payment-institution framework (Law of 21 December 2009)

    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

Sources

  1. nbb.be/en/activities/financial-supervision-and-resolution/cross-cutting-and-
  2. nbb.be/doc/cp/eng/2022/application_guide_payment_institutions.pdf
  3. nbb.be/doc/cp/eng/2019/20190612_nbb_2019_12_annex.pdf
  4. twobirds.com/en/insights/2022/belgium/nbb-communication-on-open-banking
  5. ecb.europa.eu/paym/retail/instant_payments/html/instant_payments_regulation.en.html
  6. ey.com/en_be/insights/financial-services/emeia/eu-instant-payments-regulatio
  7. nortonrosefulbright.com/en-be/knowledge/publications/397bf640/buy-now-pay-later-regulation-ar
  8. fintechbelgium.be/news/bnpl-solutions-soon-impacted-by-a-new-consumer-credit-directive
  9. nortonrosefulbright.com/en/knowledge/publications/cedd39c6/psd3-and-psr-from-provisional-agre
  10. eubelius.com/en/news/provision-of-payment-services-under-the-belgian-psd2-act
  11. regulatorycounsel.co.uk/payment-institutions/belgium
  12. legal.pwc.de/content/services/regcore-client-alert/pwc-client-alert-eus-new-paymen

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Orientation, not legal advice: verify against the primary sources linked above. Last verified 6 Aug 2026. Methodology & how to cite · State of Technology Regulation 2026