Licensing and intellectual property
EMI License in Belgium: E-Money and Payment Institutions
Hero
We prepare, submit and follow your e-money or payment institution file through each statutory stage at the National Bank of Belgium.
- Authority: National Bank of Belgium (Art. 12; Art. 169)
- E-money capital: EUR 350,000, fully paid up (Art. 173)
- Payment institution capital: EUR 20,000, 50,000 or 125,000 by service (Art. 17)
- Legal form: NV/SA, cooperative, SE or SCE, never a BV/SRL (Arts. 16, 172)
E-money and payment institution licences in Belgium, in brief
This page is for a founder or a foreign group that wants to hold an e-money or payment institution licence in Belgium. The National Bank of Belgium authorises both under the Law of 11 March 2018, consolidated to 24 December 2025 (Art. 12; Art. 169). The FSMA only gives an opinion on the integrity of proposed managers.
The page covers payment and e-money institutions only. Investment firms answer to another regulator. Crypto-asset services have their own route: see a MiCA licence in Belgium. We prepare the file, the National Bank decides, and we promise no authorisation.
What's included
Choosing the regime and the service numbers
We work through the criteria of the Law with you: payment services 1 to 8 of Annex I.A, e-money issuance, account-information-only registration, or a limited regime.
The Belgian company that has to exist first
The applicant must be an NV/SA, cooperative company, SE or SCE. We prepare the financial plan and coordinate the notary, publication and KBO/BCE registration.
The authorisation file
We organise your papers around the statutory list: Art. 10 for payment institutions (20 items) and Art. 168 section 1 for e-money institutions (11 items).
Submission and the National Bank's questions
We submit the file to the National Bank and handle its questions. The FSMA integrity opinion on proposed managers runs inside the same file.
After authorisation
We describe what follows: the passport notification for other Member States and the ongoing obligations. These are duties of the institution, not results we deliver.
Where our work stops
We are not the National Bank and decide nothing. We promise no authorisation, no timeline and no bank account. We are not the notary, give no advice on which regime or form suits you, and supply no ready licence.
Two neighbouring services sit on their own pages: registering a trade mark for Belgium and a Belgian patent.
Which licence and which regime
Whichever licence applies, a Belgian institution must be an NV/SA, a cooperative company, an SE or an SCE, never a BV/SRL. The cards set out the criteria, and the Law decides which one fits.
Payment institution
Authorisation for payment services 1 to 8 of Annex I.A. Initial capital is EUR 20,000, EUR 50,000 or EUR 125,000 depending on the service (Art. 17).
E-money institution
Authorisation to issue e-money, with EUR 350,000 of initial capital (Art. 173). It may also provide the payment services of Annex I.A (Art. 191 section 1).
Account-information-only provider
Registration, not authorisation. A Belgian legal person that provides only service 8 registers with the National Bank before it starts (Arts. 89 to 91).
Limited payment institution
Registration for services 1 to 5 where the monthly average of payment transactions stays at or below EUR 1,000,000. No passport. If the ceiling is exceeded, apply for authorisation within 30 calendar days (Arts. 81, 87).
Limited e-money institution
Registration where average e-money outstanding stays at or below EUR 1,500,000, with a EUR 150 cap on the amount loaded on the e-money medium. No passport (Arts. 199, 203).
Full institutions notify the National Bank to use a passport (Arts. 59, 65, 186 to 189). Limited ones have none.
- Initial capital
- EUR 20,000, EUR 50,000 or EUR 125,000 (Art. 17)
- Passport
- By notification (Arts. 59, 65)
- Initial capital
- EUR 350,000 (Art. 173)
- Passport
- By notification (Arts. 186 to 189)
- Ceiling
- Monthly average of transactions at or below EUR 1,000,000 (Art. 81)
- Passport
- None
- Ceiling
- E-money outstanding at or below EUR 1,500,000; EUR 150 load cap (Arts. 199, 203)
- Passport
- None
How the process works
Durations appear only where the Law sets one. Steps 1 to 5 have none, and we draw no total.
Decide the regime and the service numbers
Payment services 1 to 8, e-money issuance, account-information registration or a limited regime. No statutory period.
Choose the vehicle and confirm the capital
An NV/SA, cooperative company, SE or SCE, with the capital of the licence fully paid up. No statutory period.
Incorporate the company
Financial plan, notary, blocked account, publication and KBO/BCE registration. A non-EU founder who will manage the company also needs the professional card. No published timing.
Send the National Bank's information form
It asks for company name, seat, enterprise number, legal form, scope and a detailed description of activities. Incomplete forms are not processed.
Build the file
on the Art. 10 or Art. 168 list: programme of activities, three-year financial plan, proof of capital, safeguarding, management and control. How long a file takes to become complete is not published.
Submit and answer questions
The FSMA integrity opinion on proposed managers runs inside the file: 14 days, at most one month, silence counting as positive (Art. 11; Art. 168).
The National Bank decides
Three months from a complete file and twelve months at the latest from the application. The decision names the services granted (Art. 12; Art. 169).
Start and notify
Start activity within 12 months or risk strike-off (Art. 118). Passport decisions take up to three months after a complete file (Arts. 61, 67).
- Decide the regime and service numbersNot published
- Choose the vehicle, confirm capitalNot published
- Incorporate the companyNot published
- Send the National Bank's information formNot published
- Build the fileNot published
- Submit; FSMA integrity opinion14 days, at most 1 month, silence is positive (Art. 11; Art. 168)
- The National Bank decides3 months from a complete file, 12 months at the latest from the application (Art. 12; Art. 169)
- Start and notifyStart within 12 months or strike-off (Art. 118); passport decision up to 3 months after a complete file (Arts. 61, 67)
Not sure which regime and which service numbers apply?
Tell us what you plan to offer and we map it to the articles of the Law.
Documents you will need
The list follows the statute. The National Bank's own form is the authority.
- Identification of founders and directors, who must be natural persons.
- Identification of at least two effective managers.
- A financial plan for three years.
- Proof of the fully paid-up capital.
- Proof of the seat address.
- Fit-and-proper material for each qualifying shareholder and manager.
- The identity of the auditor or auditors.
- The articles of association.
- A power of attorney where founders cannot attend, with apostille and translation as needed.
- A professional card where a non-EU founder will manage the company.
Belgian requirements, capital and state costs
Every figure below is a statutory amount or a state charge, with its source.
| Requirement | Payment institution | E-money institution | Source |
|---|---|---|---|
| Legal form | Cooperative company, NV/SA, SE or SCE; never a BV/SRL | Same four forms | Law of 11 March 2018, Arts. 16, 172 |
| Initial capital | EUR 20,000, 50,000 or 125,000 by service, fully paid up | EUR 350,000, fully paid up | Art. 17; Art. 173 |
| Existing company | Art. 17, second paragraph | Capital alone at least EUR 140,000 | Art. 17; Art. 173 paragraph 2 |
| Own funds floor | Never below the Art. 17 amount; method set by National Bank regulation | Never below the Art. 173 amount; method set by regulation | Art. 33; Art. 182 |
| Directors and managers | Natural persons; at least two effective managers | Natural persons; at least two effective managers | Art. 20; Art. 175 |
| Central administration | In Belgium | No counterpart located | Art. 23 |
| Decision period | 3 months from a complete file, 12 months at the latest | Same | Art. 12; Art. 169 |
| NV/SA vehicle | Capital EUR 61,500; cash contributions to a blocked account at an EEA credit institution | Same | Companies and Associations Code, Arts. 7:2, 7:12 |
What a Belgian institution must have, by article. Own-funds calculation is left to National Bank regulation.
| What the state charges | Amount | Source | Year |
|---|---|---|---|
| KBO/BCE registration through a business counter | EUR 111.50 per establishment unit | FPS Economy | 2026 |
| Moniteur belge, incorporation, electronic filing | EUR 236.50 excl. VAT, EUR 286.17 incl. VAT | Moniteur belge tariff | Filings from 1 March 2026 |
| Notary, NV/SA incorporation | Quoted by the notary; no fixed tariff traced | None | None |
| Experts appointed by the National Bank | Borne by the institution; amount not published | Arts. 103 section 5, 208 section 5 | None |
| National Bank application fee or annual contribution | None found on the National Bank's lists page; not established | None | None |
State charges for 2026. Our own fee is on request, and no total is stated.
Problems we solve
"A ready-made BV/SRL will not do"
Arts. 16 and 172 list four forms and a BV/SRL is not one. The vehicle is a Belgian public limited company or another listed form. We state no conversion route.
"Apply, or buy an existing institution?"
A buyer notifies the National Bank before reaching 20, 30 or 50 percent, with up to three months to wait. Activity must start within 12 months. See our ready-made companies service for what a ready-made BV/SRL can and cannot be.
"How many institutions are licensed?"
The National Bank lists 3 Belgian-law e-money institutions at 30 September 2026, none new since 23 July 2019, and 31 payment institutions at 21 September 2026, one authorised in the last twelve months. Other Member States' institutions sit on separate lists.
"Will a bank hold the safeguarded funds?"
Arts. 42 and 194 name a credit institution or a central bank for the segregated route, and Art. 7:12 CSA an EEA credit institution for the NV/SA account. Whether an e-money account is accepted is open. We promise no account.
"The small regime and the passport"
Limited institutions carry no passport, and both National Bank lists read none on 30 September 2026. The Law also holds exemptions for some activities (Arts. 6, 7, 164, 165), so you may not need a licence at all.
"Where do the managers live, and where is the company?"
Managers are natural persons, at least two, and payment institutions need central administration in Belgium (Art. 23). The statute is silent on residence. We cover a company seat in Brussels.
Want the file checked against the statutory list?
Send us your plan and the company structure, and we check both against the articles.
Why work with us
Julien Marchal, tax, VAT and licensing lead, prepares the application files. From our practice: we fix the regime first, check the vehicle second, build the file on the statutory list, and coordinate the notary, the business counter and the National Bank. We hold no licence ourselves.
Related services
- Crypto-asset servicesThe separate route for crypto-asset service providers.
- A director for the companyNatural-person management and substance.
- BankingThe account the company needs.
Frequently Asked Questions
Can I use a BV/SRL, or buy a ready-made company, to hold an EMI or payment institution licence in Belgium?
No. Articles 16 and 172 of the Law of 11 March 2018 limit Belgian institutions to the cooperative company, the NV/SA, the European company (SE) or the European cooperative company (SCE), in force from 19 July 2021. A ready-made BV/SRL is therefore not a usable vehicle, and this page states no conversion route.
Do I have to live in Belgium, or be in Belgium, to hold a payment or e-money licence?
The Law requires natural-person directors and effective management by at least two natural persons (Art. 20; Art. 175) and, for payment institutions, central administration in Belgium (Art. 23). It does not say where the managers live, and whether the National Bank expects residency has not been verified.
How long does the National Bank of Belgium take to decide?
Three months from the filing of a complete file and at the latest twelve months from the application (Art. 12; Art. 169). How long a file takes to become complete is not published. The institution must start activity within 12 months of authorisation or risk strike-off (Art. 118).
What does it cost, and does the National Bank charge an application fee?
State lines: KBO/BCE registration is EUR 111.50 per establishment unit (2026) and Moniteur belge publication of an incorporation is EUR 236.50 excluding VAT (filings from 1 March 2026). The notary quotes the fee for an NV/SA. No National Bank application fee was found, which is not the same as none. Our own fees are on request.
Can I buy an existing Belgian EMI instead of applying?
The statute sets the buyer's checklist: prior written notification to the National Bank at 20, 30 or 50 percent (Arts. 25 to 29; Art. 183), up to three months, with silence meaning approval, and strike-off if activity does not start within 12 months. We do not broker or supply a licence.
Is there a lighter regime for a small business, and can it operate in other EU countries?
Limited institutions are registered, not authorised: a monthly payment average not above EUR 1,000,000, or e-money outstanding not above EUR 1,500,000 with a EUR 150 load cap. They carry no European passport, and exceeding the ceiling means applying for authorisation within 30 calendar days. Both limited lists read none on 30 September 2026.
What is the minimum capital for an electronic money institution in Belgium?
EUR 350,000, fully paid up at authorisation (Art. 173, paragraph 1; Directive 2009/110/EC Art. 4). For an existing company, capital alone must be at least EUR 140,000, with share premium, reserves and retained earnings counting towards the rest (Art. 173, paragraph 2).
What is the minimum capital for a payment institution in Belgium, and does it depend on the service?
Yes: EUR 20,000 for money remittance only, EUR 50,000 for payment initiation only and EUR 125,000 for any of services 1 to 5, fully paid up (Art. 17). By our arithmetic, not a National Bank statement, an NV/SA also needs EUR 61,500 (Art. 7:2 CSA), so that figure binds a remittance-only company.
Who licenses an electronic money institution in Belgium, the National Bank or the FSMA?
The National Bank of Belgium authorises and supervises (Art. 12; Art. 169). The FSMA does not license these institutions: it gives the National Bank an opinion on the integrity of proposed managers within 14 days and at most one month, silence counting as positive, and it supervises crypto-asset providers under MiCA.
What is the difference between an EMI and a payment institution?
E-money issuance is a separate licence with its own EUR 350,000 capital floor; a payment institution provides the payment services of Annex I.A, points 1 to 8. An e-money institution may also provide those payment services (Art. 191 section 1). Neither may take deposits.
Do the directors have to be individuals, and how many managers do I need?
Yes. Directors, effective managers and heads of control functions must be natural persons, and effective management is entrusted to at least two natural persons. Professional integrity and expertise are required permanently (Art. 20 sections 1 and 2; Art. 175 sections 1 and 2).
What does safeguarding of client funds require?
Client funds must be identifiable at all times. If still held at the end of the business day, they go to a separate client account with a credit institution or a central bank, are invested in qualifying low-risk assets, or are covered by insurance or a comparable guarantee (Art. 42; Art. 194), with a special privilege on insolvency.
Is an EMI a bank?
No. An e-money institution may not take deposits, and funds received for e-money must be exchanged for e-money without delay (Art. 193 sections 1 and 2). A payment institution may not take deposits either (Art. 45). That ban is the line between these institutions and a bank.
Do I need a separate licence if I touch crypto-assets?
Since 3 January 2026 a Belgian payment institution may provide crypto-asset services with an authorisation under Art. 63 of Regulation 2023/1114 (Art. 44 section 1/1), and an e-money institution may issue e-money tokens (Art. 192/1). Limited institutions may not (Arts. 87 section 1, 203 section 1/1). The crypto page covers the detail.
Where can I check that a Belgian institution is licensed?
The National Bank publishes four public lists: authorised e-money institutions, authorised payment institutions, limited payment institutions and limited e-money institutions, each with a situation date. The EBA keeps the EU register. Institutions from other Member States operating in Belgium sit on separate National Bank lists.
Ready to start your licensing plan?
Send us the services, the owners and the planned seat, and we prepare the licensing plan.