NBB lists of payment and e-money institutions (Belgium)
The National Bank of Belgium’s lists of payment institutions and e-money institutions are the NBB register that tells the market who may provide payment services or issue e-money in Belgium, with which services, and through which branches and agents. Belgium has no single “register” in the Dutch or French sense. The Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions requires the NBB to keep a list for each regime and publish it on its website. For a payment or e-money institution they show your own status as counterparties see it, your notified agents, and the EEA firms passported into Belgium. This article covers using the lists, not licensing.
1. What the law requires
Two parallel provisions do the work. Article 8 of the Law of 11 March 2018 obliges the NBB to keep a list of entities entitled to provide payment services in Belgium. Article 166 does the same for entities entitled to issue e-money. Each list separates the categories the law creates.
- Payment side (Article 8). Licensed payment institutions (Article 12), registered limited payment institutions (Article 82), registered account information service providers (Article 91), persons allowed to provide payment services within a limited network (Article 6) and electronic communications providers allowed to do so (Article 7).
- E-money side (Article 166). Licensed e-money institutions (Article 169), registered limited e-money institutions (Article 200), and the limited-network and electronic communications categories (Articles 164 and 165).
The minimum content is set by law. For a licensed institution the list must show the payment services it may provide, the address of its branches in Belgium and abroad, and the identity of its agents in Belgium and abroad. For a limited institution the law requires only Belgian branches and Belgian agents. Limited-network entries must say which type of network is involved.
Three duties follow in the same articles. The NBB notifies the European Banking Authority (EBA) without delay of the listed information and every update. It publishes the list on its website. And it keeps the information regularly updated. Licensing decisions feed the list directly: Article 14 places a newly licensed payment institution on it, and Article 170 does the same for a licensed e-money institution.
2. What the NBB publishes
The NBB presents the lists under its prudential supervision pages for payment and e-money institutions. Archived copies from September 2024 show eleven separate lists:
- licensed payment institutions;
- registered payment institutions, split into limited payment institutions and account information service providers;
- EEA payment institutions with a branch in Belgium;
- EEA payment institutions providing services into Belgium without a branch;
- licensed e-money institutions;
- limited e-money institutions;
- EEA e-money institutions with a Belgian branch;
- EEA e-money institutions providing services into Belgium without a branch;
- limited-network providers;
- electronic communications providers allowed to provide payment services.
Each list opens by citing the article it implements, for example Article 8 §1, 1° for licensed payment institutions or Article 126 for inbound service providers.
3. How to read an entry
A Belgian entry, as published in the archived copies, carries these elements:
- Name, legal form and registered address. Match all three against your onboarding file, not only the trading name.
- Unique identification number. For Belgian firms this is the enterprise number. Match on it rather than on spelling; see our note on the BCE/KBO enterprise number.
- Date of entry on the list. The date the NBB listed the firm, not necessarily the date it started trading.
- Service columns. Payment services are numbered 1 to 8, following Annex I.A of the Law (the PSD2 list: cash placement, cash withdrawal, execution of transactions, execution covered by a credit line, issuing and acquiring, money remittance, payment initiation, account information). An X marks credit linked to services 4, 5 or 7. The e-money list adds A for issuing e-money and B for distribution and redemption.
- Annex link. Where a firm has branches, agents, distributors or cross-border services, the entry links to a separate annex file listing them.
- “Situation au” date. The date of the data you are looking at.
- Changes over the last twelve months. A log at the foot of each list records removals, address changes and similar events with their effective dates.
A firm listed for service 6 alone is a money remitter, not an account provider. A limited payment institution under Article 81 is a different counterparty from a licensed one, and its entry shows only its Belgian network.
4. Agents and distributors of Belgian institutions
Article 71 lets a payment institution provide payment services through an agent, in Belgium or abroad. Before doing so it must give the NBB a defined data set: the agent’s identity, the services mandated, a description of the agent’s internal controls under the Law of 18 September 2017 and Regulation (EU) 2023/1113, the identity of its managers, evidence of their professional standing and expertise, its organisational structure and any unique identifier.
Article 72 sets the timing. If the data are accurate and complete and raise no concern for sound and prudent management, the NBB enters the agent on the list and informs the institution within two months. Otherwise it refuses and says so within the same period. The agent may start providing services for the institution once it is on the list. Article 73 then requires at least an annual check of each agent, on documents and on site. Article 74 requires the institution to tell the NBB without delay of any change to the notified data.
E-money institutions follow the same route for payment services. Article 190 §2 applies Articles 71 to 74 to their agents, while §1 forbids them to issue e-money through agents. They may distribute and redeem e-money through distributors, and §3 makes them liable for both. The NBB’s annex column for e-money institutions covers distributors alongside branches and agents, so check the annex rather than the main entry.
5. Branches and agents abroad
A Belgian payment institution opening an EEA branch notifies the NBB under Article 59. The NBB passes the file to the host authority within a month (Article 60) and must decide within three months of a complete file (Article 61 §2). Once it notifies a decision not to oppose, Article 61 §3 has it record the branch on the Article 8 list. Article 70 applies the branch procedure to an agent established in another member state. If the NBB considers the agent is not an establishment there, the cross-border services procedure in Articles 65 to 69 applies instead. Articles 188 and 189 extend the same mechanics to e-money institutions using distributors or agents abroad.
The outbound annex is the public trace of what you notified; a lapsed agent still shown there is yours to correct under Article 74.
6. Inbound EEA firms
An EEA payment institution may open a Belgian branch once the NBB has notified it that the home authority’s decision has been received and the branch is entered in the home register (Article 120). It may not actually start before the date the home authority communicates (Article 121). Cross-border services start once the NBB has notified receipt of the home decision (Article 124). Inbound agents follow the branch rules by analogy (Article 127). Articles 218 to 221 apply the same rules to EEA e-money institutions, including their distributors.
The NBB publishes inbound branches and service providers “for information” under Articles 123 and 126, if need be by referring to the home authority’s website. The legal status sits at home. The NBB’s inbound service-provider lists mark with (#) firms that have set up agents or distributors in Belgium. The NBB notes that such firms fall under the Law of 18 September 2017 for those Belgian activities, and points to the home authority and the EBA register for the agent names. Do not expect the agent itself in the NBB list.
7. NBB lists, the FSMA and the EBA register
| Source | Kept by | What it shows | Use it to |
|---|---|---|---|
| Article 8 list (payment) | NBB | Licensed, limited and AISP payment institutions, limited-network and telecom providers, services, branches, agents | Verify a Belgian payment firm and its agents |
| Article 166 list (e-money) | NBB | Licensed and limited e-money institutions, activities A/B, services, branches, agents, distributors | Verify a Belgian e-money issuer and its network |
| Article 123/126 lists | NBB, for information | EEA firms with a Belgian branch or providing services in, with (#) for Belgian agents or distributors | Confirm an inbound passport exists |
| EBA central register | EBA, from national data | Payment and e-money institutions, agents and branches across the EEA | Cross-check EEA firms and inbound agents |
The FSMA does not keep these lists. Its role under the 2018 Law is advisory: Articles 11 and 167 have the NBB decide on a licence after the FSMA’s opinion on the professional standing of proposed managers new to an NBB-supervised firm. The NBB alone lists and removes.
The EBA register rests on Article 15 of Directive (EU) 2015/2366, Implementing Regulation (EU) 2019/410 on the information national authorities notify, and Delegated Regulation (EU) 2019/411 on the register’s operation and access. Under Article 15 the national authority remains responsible for the accuracy of what it sends. Where the NBB list and the EBA register differ on a Belgian firm, the NBB list is the national source.
8. Removals and their limits
Article 118 (payment) and Article 216 (e-money) require the NBB to strike off a firm that has not started within twelve months, renounced its status, stopped for more than six months or been declared bankrupt. The NBB publishes every withdrawal or strike-off decision on its website, removes the firm from the list and tells the EBA why. Under Articles 119 and 217 a struck-off firm stays subject to the Law until it has settled its obligations to users, unless the NBB exempts it.
Before concluding a firm has vanished, check the twelve-month change log and the NBB’s published decisions.
9. Worked cases
A Belgian agent ready before the list
Facts: a Belgian payment institution signs a money-remittance agent with retail outlets, files the Article 71 data, and three weeks later the agent wants to open.
What the rule says: under Article 72 the NBB enters the agent within two months if the data are complete and raise no concern, and the agent may act only once listed.
What the practitioner does: keeps system access off and watches the annex until the agent appears with service 6.
Outcome: go-live follows the list entry, and the audit trail shows it.
An EEA e-money partner “authorised in Belgium”
Facts: a Belgian payment institution plans a card programme with an EEA e-money institution that describes itself as authorised in Belgium.
What the rule says: under Articles 219 and 124 the firm provides services on its home licence; the NBB lists it for information under Article 126.
What the practitioner does: finds the firm on the NBB inbound e-money list, checks whether it carries the (#) marker, then confirms the licence and any Belgian distributors on the home register and the EBA register, with dated records.
Outcome: the file names the supervisor that would act, and the Belgian distributor network is verified where it actually lives.
A stale agent abroad
Facts: a Belgian e-money institution ended an agent mandate in another member state months ago; the agent still appears in its NBB annex.
What the rule says: Article 74, applied through Article 190 §2, requires notice to the NBB without delay of any change to agent data.
What the practitioner does: notifies the NBB with the termination date and rechecks the annex and the EBA register until both change.
Outcome: the public record stops showing an agent the institution no longer controls but would still answer for.
10. FAQ
Is the NBB list a register in the legal sense?
The 2018 Law calls it a list (Articles 8 and 166). It works as the Belgian public register for payment and e-money institutions and feeds the EBA register.
Does the FSMA keep a register of payment institutions?
Not under the 2018 Law. The FSMA gives opinions on managers’ professional standing; the NBB keeps and updates the lists.
When may a Belgian agent start?
Once the NBB has entered it on the list, under Article 72. The NBB has two months from receipt of the agent data.
Are agents of EEA firms on the NBB list?
No. The NBB flags inbound firms with Belgian agents or distributors with (#) and points to the home authority and the EBA register for the names.
What do the numbers and letters in an entry mean?
Numbers 1 to 8 are the Annex I.A payment services, X is linked credit, and on the e-money list A is issuing and B is distribution and redemption.
Are limited institutions’ foreign agents listed?
The law requires only Belgian branches and Belgian agents for limited institutions.
11. What to do, today
- COO: pull your own entry and annex and confirm services, branches and agents match your licence decision and notifications.
- Agent network owner: gate every agent go-live on its appearance in the NBB annex, and reconcile your agent list against it at least quarterly.
- Head of partnerships: store the enterprise number for every Belgian counterparty, and verify EEA firms on the home and EBA registers too.
- MLRO: treat a (#) marker as a signal of Belgian agents or distributors and confirm who supervises their AML compliance.
- Compliance: file every change to agent or distributor data with the NBB without delay, and recheck the list after each filing.
Related: REGAFI, the French register · PSD2 agents and distributors: register and liability · OneGate reporting for Belgian PIs and EMIs
