NBB payment statistics — Belgium’s MCC declaration

A Belgian card issuer owes the National Bank a monthly file by the 20th — a deadline that appears in no European regulation, because Belgium sets it itself. Payment statistics in Belgium sit in two layers. Regulation (EU) No 1409/2013 (ECB/2013/43), as amended by Regulation (EU) 2020/2011 (ECB/2020/59), fixes what the National Bank of Belgium must send the ECB and when. The NBB then decides what declarers send it — and the breakdown of card payments by merchant category code runs monthly, by the 20th. This piece separates the two layers, names the nine tables, sets out the derogation test, and shows where firms get the perimeter wrong.

1. Two layers, two sets of deadlines

Almost every confusion here comes from reading the European dates as if they bound a reporting firm. They do not. Article 6(1) of Regulation (EU) No 1409/2013 sets the dates on which national central banks transmit to the ECB; Article 6(2) then requires each NCB to establish clear reporting deadlines for its own declarers so that it can meet those European dates.

The European timetable is therefore your ceiling, and the national deadline always sits earlier. Belgium’s declarer deadlines are published in the NBB’s own declaration documentation on the reporting portal, and for the card-payments breakdown that deadline is monthly — more frequent than anything the European regulation requires.

2. Who is in the reporting population

Article 2, as amended, makes the actual reporting population payment service providers, including electronic money issuers, and payment system operators. Article 3(1) requires each reporting agent to report to the NCB of the member state in which it is resident — either directly, or through the relevant national competent authority under local cooperation arrangements. The reporting must meet the minimum standards for transmission, accuracy, conceptual compliance and revisions set out in Annex IV.

Two consequences matter for a firm structured across borders. Residence decides the collector, not where the customers are: a Belgian-resident institution reports to the NBB about transactions effected in Belgium or abroad. And the ECB’s Executive Board maintains a list of PSPs and payment system operators subject to the regulation, built on national lists of supervised entities; where the latest accessible electronic version is wrong, Article 5(3) shields an entity that relied on it in good faith from ECB sanctions — a narrow shield that does not extend to national enforcement.

3. The nine tables, and who reports which

Annex III structures the collection as nine tables. Tables 1 to 6 and 9 are reported by PSPs; Tables 7 and 8 by payment system operators. Tables 4 and 5 exist in two versions and you report one of each.

Tables 1, 2, 3 and 7 are stock data at end of period — positions on the last working day. Tables 4, 5, 6, 8 and 9 are flows accumulated across the period. Mixing the conventions inside one extraction is the commonest reason a submission reconciles internally and still fails the NCB’s checks.

The Article 6(1) transmission dates explain the shape of the national calendar: quarterly Table 9 by close of business on the last working day of the second month after the quarter; the semi-annual tables for January–June by the last working day of November and for July–December by the last working day of May; the annual Tables 4b and 5b by the last working day of May. Under Article 8a this began with Q1 2022 data by end-May 2022 and H1 2022 data by end-November 2022.

4. The Belgian card-payments declaration, by merchant category code

Belgium collects the merchant-category-code breakdown as a standing monthly declaration, not as an annex to a quarterly return. The NBB’s declaration sheet is precise about the perimeter:

• Who declares. Legal persons established in Belgium that issue payment cards or pursue payment-transaction acquiring activities, except those granted a derogation in the payment-statistics context.
• What issuers report. The breakdown of amounts by merchant category code for all transactions effected in Belgium or abroad using cards they have issued.
• What acquirers report. The breakdown by merchant category code for all transactions acquired in Belgium or abroad in the course of their activities.
• When. Monthly, no later than the 20th of the month following the reporting period — the March declaration is due by 20 April.
• Legal basis. Regulation (EC) No 184/2005 on Community statistics concerning balance of payments, international trade in services and foreign direct investment, together with the payments-statistics regulation as amended by ECB/2020/59.

The declaration is completed online through the NBB’s reporting portal, identifying either on the Belgian federal identity platform CSAM or with a valid electronic certificate. One footnote in the NBB sheet carries disproportionate weight: CSAM is accessible only to resident companies and users. A group administering Belgian reporting from another member state therefore needs the certificate path — a lead-time item, not a configuration step.

Inside the portal the declaration can be keyed manually or imported as XML or CSV. The NBB publishes a dedicated MCC manual as the detailed specification and answers questions through its external-statistics desk. The sheet states plainly that the declaration is a legal obligation and that failing it can expose the firm to sanctions.

Worked example — the issuer that extracted domestic data only. A Belgian e-money institution launches cards and builds its first MCC declaration from a domestic settlement file. Rule: the issuer limb covers all transactions effected in Belgium or abroad with cards it issued. What the analyst does: rebuilds the extraction from issuing authorisation and clearing records, keys the breakdown on the MCC in the transaction message, and reconciles the monthly total against the volume that will later appear in Tables 4a and 9. Outcome: cross-border card usage — usually the majority of spend for a digital card programme — is captured, and the figure ties to the quarterly and semi-annual returns instead of contradicting them.

5. Derogations: granted, not assumed

Article 4 lets NCBs grant derogations, guided by proportionality, and the test is not a size test. A derogation may be granted to payment institutions meeting Article 32(1) and (2) of Directive (EU) 2015/2366, to electronic money institutions meeting Article 9(1) and (2) of Directive 2009/110/EC, and to other PSPs meeting both — regardless of whether the entity has been waived or exempted from prudential requirements under national law.

On top of that, Article 4(3) applies a market-share test: the total value contributed by all PSPs that could benefit from the derogation must not exceed 5% at national level for each of the listed services — credit transfers sent, direct debits sent, card-based payment transactions sent and received, cash withdrawals with card-based instruments, e-money payment transactions sent, cheques sent, money remittances sent, other payment services sent, payment initiation services, and other services outside PSD2 sent — with the cumulative total across those services also capped at 5%. For account information services the equivalent test is that the total number of clients does not exceed 5% nationally. And the NCB may only grant the derogation where the reporting burden would be disproportionate to the size of the agent.

Three details decide how a firm should behave:

• A derogation is not silence. Article 4(4) requires derogated agents to report Tables 4b and 5b — a reduced but real return, including fraud data.
• It is reviewed annually. The NCB verifies the conditions each year, based on the 12 months immediately preceding the reference period of the assessment, and grants or withdraws with effect from the start of the second successive calendar year. You therefore get a year of notice in both directions.
• It is published. The ECB publishes a list of entities granted derogations, and the NBB publishes its own list of exempted institutions, revised annually. Whether you are exempt is a matter of record, not of judgement.

Worked example — the firm that assumed it was too small. A Belgian payment institution with modest volumes concludes it is out of scope and files nothing for two periods. Rule: derogations are granted by the NCB after a conditions test, appear on published lists, and still require Tables 4b and 5b. What the compliance officer does: checks the exempted-institutions list for the firm’s own name and, finding it absent, opens the portal enrolment and files the outstanding periods. Outcome: a late filing rather than an unreported one — and since a derogation granted later takes effect from the start of the second successive calendar year, the interim periods were always owed.

6. The fraud tables are a reconciliation problem

Tables 5a and 5b ask for the number and value of fraudulent transactions by payment service, initiation channel, payment scheme, fraud origin and authentication method, with the reasons for non-SCA where SCA was not applied. That is the same conceptual territory as the fraud data reported under the PSD2 framework, collected by a different authority on a different cadence.

The reconciliation duty is implicit but unavoidable: a supervisor comparing the two datasets expects the same underlying events. Firms that build each return from a different source — fraud-operations case data for one, ledger-level chargeback data for the other — produce divergent numbers nobody can explain months later.

Worked example — two fraud numbers, one firm. A Belgian institution reports one fraud figure in its payment-statistics return and a different one in its supervisory fraud reporting for the same half-year. Rule: both describe fraudulent payment transactions by service, channel and authentication method; the dimensions overlap. What the team does: designates one fraud event store as the single source, maps each return’s dimensions onto its fields in a written mapping document, and records the definitional differences that legitimately produce a delta instead of forcing the totals to match. Outcome: a documented, explainable difference — the difference between a supervisory question and a supervisory finding.

7. What this is not: the prudential reports

A Belgian payment or e-money institution also files prudential and financial reports to the NBB through the same portal but a different domain, with strong-secured certificate access — the PI, ELMI and qualitative returns. Those are supervisory returns on the institution; the payment statistics here are statistical returns on the market, driven by the ECB and balance-of-payments regulations.

Keeping the two apart matters when access is provisioned: the enrolment, the roles and in some cases the certificate requirement differ between domains, and a firm that enrols one team for the prudential domain often finds its statistics declarer locked out in the first month.

8. FAQ

9. What to do, today

• Check the published exempted-institutions list for your own entity before concluding anything about scope.
• Put the 20th in the monthly close calendar if you issue or acquire card payments, and treat it as a hard close, not a best-efforts date.
• Re-scope the MCC extraction to all card usage, domestic and cross-border, and key it on the merchant category code in the transaction message.
• Resolve portal access by route. Confirm whether your declarers can use CSAM; if not, start the certificate procurement now, separately from the prudential-domain enrolment.
• Write the fraud mapping document tying the statistical fraud tables to your supervisory fraud reporting, and record the legitimate deltas.
• Reconcile stocks and flows deliberately — end-of-period positions for Tables 1, 2, 3 and 7, accumulated flows for Tables 4, 5, 6, 8 and 9.

Related: The NBB’s PI and ELMI reports · PSD2 fraud reporting · External-sector reporting compared · The NBB periodic AML questionnaire