Financial licensing - Belgium
Payment Institution Licence in Belgium
We scope which NBB authorisation you need, prepare and file it, and coordinate the Belgian company behind it.
- 31 payment institutions on the NBB's own list (situation 04-09-2026)
- Capital from EUR 20,000 to EUR 350,000, by activity
- NBB decision: 3 months from a complete file, 12 months maximum
- EU-wide passporting once authorised
Getting Authorised as a Payment or E-Money Institution in Belgium
Belgium licenses payment institutions and electronic money institutions through the National Bank of Belgium (NBB), under the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions. We scope which authorisation your business needs, prepare and file the NBB application, and coordinate the Belgian company the licence sits on top of.
The FSMA is a different regulator for a different activity: investment services under the Law of 25 October 2016, and the general MiCA crypto-asset regime at Company Registration Belgium: Crypto Licence in Belgium (MiCA CASP). One exception ties the two together: the NBB, not the FSMA, keeps supervising a payment or e-money institution that wants to add crypto-asset services.
What We Handle for Your NBB Licence Application
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Scoping the Regime and the Route
We work out whether your business needs authorisation as a payment institution, as an electronic money institution, or neither, because the activity is crypto-asset services and belongs with a different regulator.
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Fixing the Service Numbers and the Capital Tier
The capital floor under Art. 17 depends on exactly which payment services you provide, from EUR 20,000 for money remittance alone to EUR 125,000 for the core services. We fix the numbers before you file.
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Coordinating the Belgian Vehicle and Seat
A BV/SRL or an NV/SA has to exist, capitalised to at least the applicable floor and fully paid up, with a registered seat in Belgium, before the NBB has anything to authorise.
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Building the Governance and AML/CFT Framework
We help assemble the effective leadership, internal control, risk and compliance functions, and the AML/CFT framework with CTIF-CFI reporting that the NBB's fit-and-proper review expects.
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Preparing the Authorisation File
The programme of operations by service number, the business plan, the governance description, fit-and-proper documentation, and the description of the safeguarding measures required under Art. 42.
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Submitting and Coordinating Passporting
We submit to the NBB, answer its questions until the file is complete, and coordinate the passporting notifications once you are authorised to operate across the rest of the EU.
Which Regulator Is Yours: NBB, FSMA or the Crypto Exception
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The National Bank of Belgium
Authorises and supervises payment institutions and electronic money institutions under the Law of 11 March 2018, alongside credit institutions, insurers and stockbroking firms. This is the regulator for this page.
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The FSMA
Licenses investment services and portfolio management under the Law of 25 October 2016, and runs the general MiCA crypto-asset regime. Neither is this page's subject.
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The One Exception
A payment or electronic money institution that wants to add crypto-asset services stays with the NBB, not the FSMA, under the Law of 11 December 2025.
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Not Sure Which Regime Fits Your Model?
Tell us what your business does and we will confirm which authorisation, if any, applies before you prepare a file.
How the NBB Authorisation Process Works
- Decide the regime and the route. Confirm whether the business provides payment services, issues electronic money, or performs crypto-asset services instead, which route to a different regulator. Days, not a filing.
- Fix the service numbers and the capital tier. Money remittance alone needs EUR 20,000; payment initiation alone EUR 50,000; any of services 1 to 5 EUR 125,000; electronic-money issuance EUR 350,000 (Art. 17; EMD2 Art. 4).
- Incorporate or confirm the Belgian vehicle. A BV/SRL or NV/SA with a registered seat in Belgium, capitalised to the applicable floor and fully paid up. The deed itself takes 5 to 10 working days once the file and the account exist; the bank, not the notary, sets the pace.
- Register in the KBO/BCE. Obtain the enterprise number through a business counter, the same number that will appear on the NBB's own list once you are authorised. Same day to a few days.
- Build the governance and AML/CFT framework. Effective leadership meeting the NBB's fit-and-proper expectations, internal control, risk and compliance functions, and AML/CFT reporting to CTIF-CFI. Weeks.
- Prepare the authorisation file. The programme of operations, the business plan, the governance description, fit-and-proper documentation, and the Art. 42 safeguarding description Art. 10 requires. Weeks to months.
- Submit to the NBB and answer its questions until the file is complete. The statutory clock runs 3 months from a complete file, 12 months maximum from the application (Art. 12).
- Authorisation and passporting. Entry on the NBB's public list by enterprise number, entry date and service numbers held, then the passporting notifications for branches, agents or free provision of services in other Member States.
- Ongoing duties. Own funds may never fall below the Art. 17 floor; an electronic money institution holds at least 2 percent of average outstanding e-money. Safeguarding and annual accounts filing continue for as long as the licence runs.
Documents You Will Need to Apply
The list below follows Art. 10 and Art. 12 and general supervisory practice; the National Bank has not published its own document checklist for this file, and nothing here fills that gap with a guess.
- Identification for every founder, director and effective leader.
- The financial plan required for a BV/SRL (Art. 5:4 CSA).
- Proof of the registered seat in Belgium.
- A professional card for a non-EU founder who will run the company.
- The programme of operations, set out by payment service number.
- The business plan behind the application.
- A description of governance and internal control.
- Fit-and-proper documentation on every effective leader and shareholder.
- The AML/CFT framework, including CTIF-CFI reporting arrangements.
- The description of the Art. 42 safeguarding measures for client funds.
Not Sure Which Service Numbers or Regime Apply to You?
Tell us which payment services or electronic-money activity your business performs, and we will confirm the regime, the capital tier and the next step.
Capital and State Costs
Every commercial page in this market quotes a capital figure. Few name the article behind it. The first table prints each figure next to the exact provision and the service point it applies to; our own fee for preparing and filing the application never appears on this page.
| Activity | Minimum initial capital | Basis |
|---|---|---|
| Money remittance only (service 6) | EUR 20,000 | Art. 17, 1 of the Law of 11 March 2018 |
| Payment initiation only (service 7) | EUR 50,000 | Art. 17, 2 of the Law of 11 March 2018 |
| Any of services 1 to 5 | EUR 125,000 | Art. 17, 3 of the Law of 11 March 2018 |
| Electronic-money issuance | EUR 350,000 | Directive 2009/110/EC, Art. 4 (EU floor; the Belgian article was not retrieved this pass) |
Nobody in either SERP publishes what Belgium itself charges to put the applicant company on the register. The second table does, with the one line item that is stated as missing rather than guessed.
| What the state charges | Amount | Note |
|---|---|---|
| KBO/BCE registration, per establishment unit | EUR 111.50 | Tariff in force 2026 |
| Fixed notarial fee, BV/SRL incorporation only | EUR 217 plus EUR 298 | Vast ereloon, from 1 January 2024, tied to Art. 2:22/1 CSA. Not valid for an NV/SA incorporation |
| Moniteur belge, incorporation, electronic filing | EUR 236.50 excl. VAT, EUR 286.17 incl. | Tariff for filings from 1 March 2026 |
| BV/SRL route, total before any NBB step | About EUR 863 excl. VAT | Notarial plus Moniteur plus KBO. The NV/SA notarial fee is not fixed and is not totalled |
| NBB application or annual supervisory fee | Not published | No source reached in this research names one; this is a gap, not a zero |
Problems We Solve
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The Regulator's Own Page Tells You Nothing
The NBB page ranking first for this search is a navigation hub: a contact block and links, no figure, no procedure, no timeline. This page fills the gap with the article numbers the regulator's own page omits.
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Which of the Eight Payment Services Do I Need?
The NBB tags each of its 31 authorised institutions with the service numbers it holds. We print all eight and help you find your own product in the list before you fix a capital tier.
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Everyone Quotes the Same Capital Figures, Why Trust Yours?
Our figures sit next to the article that states them and the service point each applies to, not as a bare number the way most commercial pages in this market print it.
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What Does the State Actually Charge, Apart From Our Fee?
The second table above answers it: notarial, Moniteur belge and KBO/BCE tariffs for the vehicle, and the one missing line, the NBB's own fee, stated as missing rather than guessed.
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Should I Apply, or Buy an Existing Licensed Company?
Several listings in this market sell an already-licensed company rather than an application. Check the NBB list, entry date and service numbers held, and read what changes hands when you take over a Belgian shelf company before you pay.
Why Work With Us
From our practice. Aurelie Lambert leads tax, licensing and compliance: ten years, the last seven on Belgian files, in French, English and Dutch. She prepares the NBB application file for a payment or e-money institution licence and coordinates the company, the seat and the governance behind it, the same file-preparation discipline she applies on the sibling crypto-licence service.
Related Services
Frequently Asked Questions
Who licenses a payment institution in Belgium, the National Bank or the FSMA?
The National Bank of Belgium (NBB) authorises and supervises payment institutions and electronic money institutions under the Law of 11 March 2018. The FSMA is not the regulator for this activity, with one exception: the NBB keeps supervising a payment or e-money institution that wants to add crypto-asset services, rather than handing it to the FSMA.
What is the minimum capital for a payment institution in Belgium?
EUR 20,000 where the institution provides only money remittance, EUR 50,000 where it provides only payment initiation, and EUR 125,000 where it provides any of payment services 1 to 5 of Annex I.A. The capital must be fully paid up as a condition of authorisation, under Art. 17 of the Law of 11 March 2018.
What is the minimum capital for an electronic money institution in Belgium?
EUR 350,000, sourced to Directive 2009/110/EC Art. 4. The corresponding Belgian article, Art. 173 of the Law of 11 March 2018, was not retrieved from the consolidated text in this research pass, so the figure is cited to the EU directive rather than the Belgian article until that is confirmed directly.
What is the difference between a payment institution and an electronic money institution?
A payment institution executes payment transactions on behalf of its users. An electronic money institution also issues electronic money, a separate activity with its own EUR 350,000 capital floor and its own continuing own-funds rule: the higher of 2 percent of average outstanding electronic money or the initial-capital figure.
Which activities count as payment services in Belgium?
Eight numbered services: placing and withdrawing cash on a payment account, executing payment transactions, issuing payment instruments or acquiring payment transactions, money remittance, payment initiation, and account information services, plus a related credit service tied to three of them, exactly as the National Bank's own authorised-institutions list enumerates them.
How long does the National Bank take to decide on an application?
Three months from a complete file, and at most twelve months from the date the application is lodged, under Art. 12 of the Law of 11 March 2018. How long a file takes to become complete before that clock starts is not published by any source we have reached.
What does safeguarding of client funds mean and does it apply to my model?
The application must describe the measures taken to protect users' funds, under Art. 10, which refers to Art. 42. For an electronic money institution, safeguarding funds received for electronic money issued is a distinct condition under EMD2 Art. 7. The exact permitted methods are not stated here because that text was not retrieved this pass.
Can a Belgian payment institution operate in the rest of the EU without a second licence?
Yes, in principle, through EU passporting: the NBB already structures each institution's branches, agents and free provision of services on its own public list. The notification procedure and its clocks are not stated here because they were not verified in this research pass.
Is there a lighter regime for a small payment institution in Belgium?
Yes. A limited payment institution and a limited electronic money institution status exist, registration rather than full authorisation, under Book II Title II Chapter II of the Law of 11 March 2018 and the Royal Decree of 3 June 2018. The euro thresholds that define it, and whether it can passport, are not published and are not stated here.
Where can I check that a Belgian payment provider is actually licensed?
The National Bank's own public list names every authorised Belgian payment institution by enterprise number, entry date and the service numbers it holds, 31 institutions as of 4 September 2026. The same list is the due-diligence route for anyone considering buying an existing licensed company rather than applying.
Do I need a crypto licence as well if I touch crypto-assets?
Not necessarily as a separate licensing track. The National Bank, not the FSMA, keeps supervising a payment or electronic money institution that adds crypto-asset services, under the Law of 11 December 2025. The scoping conversation settles which file you actually need before you prepare anything.
What kind of Belgian company do I need before I can apply?
A BV/SRL, which needs no minimum capital but sufficient own funds and a financial plan, or an NV/SA, which needs EUR 61,500. Either way you need a registered seat in Belgium and an enterprise number in the KBO/BCE before the National Bank has anything to authorise.
Ready to Apply for a Payment or E-Money Institution Licence?
Tell us which payment services or electronic-money activity you plan to offer. We will scope the regime, the capital tier and the file it takes.