Belgium (BE)

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.