Belgium

Licensing, Authorisation & Market Access

The PSD3/PSR package reached its final EU legislative stage this cycle. The proposed texts were put before national representatives for approval on 22 April 2026, following provisional political agreement reached in November 2025, and on 23 April 2026 the Council of the European Union issued an "I" Item Note carrying final compromise texts and inviting COREPER approval — a sequence indicating imminent formal adoption. The package will repeal both the second Payment Services Directive (PSD2) and the second Electronic Money Directive (EMD2), replacing the current two-instrument architecture with a single framework: a revised Payment Services Directive (PSD3) governing authorisation and supervision, and a directly applicable Payment Services Regulation (PSR) governing conduct-of-business rules.

For Belgium's National Bank of Belgium-supervised electronic money institutions, the structural consequence is significant: PSD3 incorporates EMIs as a sub-category of payment institutions rather than preserving them as a separate authorisation class, and it requires EMIs to seek reauthorisation as payment institutions. This restructures the authorisation route that Belgian EMIs currently use. Trilogue agreement sets the transition mechanism: existing non-bank payment service providers across the EU, Belgium included, will have thirty months from the point at which the new regime takes effect to reobtain their licences under the unified framework, rather than continuing indefinitely under legacy PSD2/EMD2 authorisations.

The prudential dimension of this licensing reset is the own-funds calculation methodology. PSD3 promotes Method B as the default own-funds calculation method for payment institutions, confining Methods A and C to low-volume, high-value business models that require specific national competent authority validation; the European Banking Authority is expected to issue regulatory technical standards detailing the qualifying criteria. This bank-versus-non-bank distinction matters directly here: the reform is aimed at the non-bank payment institution and EMI population specifically, since bank-supervised payment activity already sits under a separate prudential regime and is not subject to the same own-funds recalculation.

Read against the broader reform, the licensing-and-market-access picture for Belgium this cycle is one of structural reset rather than incremental adjustment: a single EMI/PI authorisation category, a defaulted own-funds methodology, and a fixed reauthorisation clock together mean that Belgium's non-bank payment sector faces a genuine re-entry event once the thirty-month window opens, distinct from routine licence renewal. Bank-supervised payment activity in Belgium is not subject to this reauthorisation mechanism, since PSD3's reauthorisation requirement is targeted at the existing non-bank PI/EMI population specifically. No Belgium-specific enforcement or supervisory action was identified this cycle beyond this EU-level legislative timeline.

Outlook

The marker to watch is the PSR's Official Journal publication, expected summer 2026, which will fix the exact clock for the thirty-month non-bank reauthorisation window and the broader application timeline. Belgian EMIs and payment institutions should expect the National Bank of Belgium to issue implementation guidance once the compromise text is formally adopted; no such guidance was identified this cycle, which is itself consistent with the package still being at the final-adoption rather than implementation stage.

Conduct, Safeguarding & Financial Promotions

PSD3's safeguarding regime for customer funds remains largely aligned with the existing PSD2 baseline, but it introduces one structurally new option: payment institutions may safeguard customer funds directly at a central bank, at that bank's discretion, specifically to mitigate the concentration risk that arises when customer funds are safeguarded through a limited number of commercial-bank accounts. This is an additional mechanism layered onto the existing PSD2-aligned safeguarding toolkit rather than a replacement of it, and its availability in practice depends on individual central banks' willingness to offer the facility, which PSD3 leaves discretionary rather than mandatory.

For Belgian payment institutions and electronic money institutions supervised by the National Bank of Belgium, this creates a new, non-bank-specific safeguarding pathway that did not previously exist: a non-bank PI or EMI could, subject to the National Bank of Belgium's discretion, hold safeguarded customer funds at the central bank itself rather than exclusively through commercial-bank safeguarding accounts or approved investment routes. This distinction is squarely a non-bank-PI/EMI conduct-and-safeguarding matter; bank-supervised payment activity is not affected in the same way, since banks are not subject to the PSD2/PSD3 safeguarding regime in the first place.

No Belgium-specific conduct or financial-promotions enforcement development, and no update to the safeguarding baseline beyond this new central-bank option, was identified this cycle.

Outlook

The practical question for the next cycle is whether the National Bank of Belgium indicates any willingness to offer the discretionary central-bank safeguarding facility to Belgian PIs and EMIs once PSD3 is formally adopted; no such signal was identified this cycle. Absent that signal, the safeguarding baseline for Belgian non-bank payment institutions should be treated as PSD2-aligned and unchanged in practice, even though the legal option for a new mechanism now exists in the adopted text.

Product Innovation & Market Development

Two developments define this cycle's product-innovation picture for Belgium. First, April 2026 reporting marked the transition from implementation to assessment ahead of the July 2027 deadline by which non-eurozone banks and non-bank payment service providers must be able to send instant payments under the EU Instant Payments Regulation. Belgium, as a eurozone member already integrated into the TARGET Instant Payment Settlement system, is not itself the primary target population for that specific deadline, but the April 2026 checkpoint is an EU-wide reporting and assessment milestone that Belgium's supervisory apparatus participates in regardless.

Second, and more directly attributable to Belgium specifically, the National Bank of Belgium has taken an active preparatory posture toward the open-banking and open-finance transition: it endorses the EU's open-banking guidelines, has already adopted PSD2, and is preparing to implement the forthcoming Payment Services Regulation, PSD3, and the Financial Data Access (FiDA) Regulation. This combination — endorsement of guidelines, existing PSD2 adoption, and active preparation for three forthcoming instruments simultaneously — indicates that Belgian payments-market development this cycle is being actively steered toward open finance by the national supervisor rather than merely responding to EU-level deadlines as they arrive.

Outlook

The marker to watch is whether the National Bank of Belgium publishes concrete implementation guidance or a timeline for FiDA and PSD3/PSR readiness now that the legislative package has reached final adoption stage; no such published guidance was identified this cycle. On instant payments, the next checkpoint of note is progress toward the July 2027 non-eurozone send-deadline, though this affects Belgium only as an EU-wide reporting participant rather than as a directly targeted jurisdiction.

Correspondent Banking, Settlement & Access

The defining development for correspondent banking and settlement access this cycle is the planned expansion of verification-of-payee checks to all wire transfers under PSD3/PSR, extending beyond the subset of bank-transfer types that currently require such checks under the Instant Payments Regulation. This is a structural tightening of the settlement and fraud-check layer that sits ahead of both bank and non-bank payment service providers' correspondent and settlement relationships, since verification-of-payee failures are precisely the kind of friction point that concentrates around correspondent and cross-border settlement chains.

The timeline attached to this expansion is still provisional: the PSR is expected to be published in the Official Journal in summer 2026, entering into force twenty days later, with most provisions — including the payee-verification regime — applying twenty-one months after that, placing live application at approximately early 2028, and the associated liability-shift regime for fraud losses following roughly three months after that. Because this analytical spine sits on Tier 3 sourcing rather than a confirmed Official Journal date, the estimated dates carry half-year uncertainty and should be treated as provisional rather than fixed.

The bank-versus-non-bank access asymmetry that structures this module is directly relevant here: an expanded verification-of-payee obligation applying to all wire transfers will fall on both bank and non-bank payment service providers, but banks already possess more mature correspondent and settlement infrastructure through which to absorb a verification-of-payee build-out, while non-bank PSPs — the same population facing the PSD3 reauthorisation and Method-B own-funds changes — face this settlement-layer requirement concurrently with a licensing and prudential reset, compounding implementation load for that population specifically.

Outlook

The Official Journal publication of the PSR is the marker that will convert the current half-year-uncertainty estimates into fixed dates for both the payee-verification application point and the subsequent liability-shift provisions. Once published, Belgian banks and non-bank PSPs alike will have a fixed clock against which to build verification-of-payee infrastructure; until then, this module's dates remain provisional estimates derived from Tier 3 commentary rather than confirmed primary-source dates.