Circulaire NBB_2026_09: Implementation of EBA Guidelines on Ancillary Services Undertakings under Regulation (EU) No 575/2013

Public NBB_2026_09 – 16 June 2026 Circular – Page 1/2

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Circular

Public

Brussels, 16 June 2026

Reference: NBB_2026_09

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Nicolas Staner

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Circular of the National Bank of Belgium implementing, in accordance with Article 4(5) of Regulation (EU) No 575/2013, the EBA guidelines specifying the criteria for identifying activities leading to the definition of ancillary services undertaking within the meaning of Article 4(1)(18) of Regulation (EU) No 575/2013

Scope

This circular applies to credit institutions, financial companies and mixed financial companies approved or designated under Belgian law that are less significant institutions (LSI), and to significant Belgian investment firms referred to in Article 1(2) and (5) of Regulation 2019/2033, hereinafter “institution”.

Summary/Objectives

This circular aims to implement the EBA/GL/2026/01 guidelines of the European Banking Authority specifying the criteria for identifying the activities referred to in Article 4(1)(18) of Regulation (EU) No 575/2013, leading to the qualification as ancillary services undertaking.

Madam, Sir,

The National Bank of Belgium wishes to indicate, by means of this circular, that the EBA guidelines of 9 January 2026 (EBA/GL/2026/01) specifying the criteria for identifying the activities referred to in Article 4(1)(18) of Regulation (EU) No 575/2013 are integrated into its supervisory practice.

These guidelines determine

a) simple and consistent criteria, accompanied by a list of activities, which should be used to determine whether a company carries on, as a principal activity, activities to be considered as a direct extension of banking activities (criterion based on the nature of the activities). In such a case, the entity carrying them on is considered an ancillary services undertaking (ASU), whether or not it is an entity part of a banking group.

Concretely, these are fundamental activities, closely integrated into the value chain of basic banking services, such as credit management, assessment of individual customers’ creditworthiness, valuation of collateral, intermediation and distribution of loans through innovative channels, debt collection, etc. when these activities are mainly provided to credit institutions or financial institutions;

b) the activities to be considered as auxiliary to banking services. To this end, the EBA guidelines establish a criterion to assess whether the activities are sufficiently linked to the banking sector to be considered ancillary, depending on whether they support, complement or depend on it. This criterion is based both on the nature of the activities, such as operational support, risk management support, back-office and administrative support, etc., and the existence of a clear link with the banking sector. It is for this reason that an entity carrying on such activities will only be qualified as an ASU if this entity is part of a banking group.

National Bank
OF BELGIUM
Eurosystem

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innovative channels, debt collection, etc. when these activities are mainly provided to credit institutions or financial institutions;

b) the activities to be considered as auxiliary to banking services. To this end, the EBA guidelines establish a criterion to assess whether the activities are sufficiently linked to the banking sector to be considered ancillary, depending on whether they support, complement or depend on it. This criterion is based both on the nature of the activities, such as operational support, risk management support, back-office and administrative support, etc., and the existence of a clear link with the banking sector. It is for this reason that an entity carrying on such activities will only be qualified as an ASU if this entity is part of a banking group.

c) the guidelines further specify the procedure to follow to determine the activities that should be considered as similar to those constituting a direct extension of banking activities or auxiliary to banking services. The new definition of ASU also aims to capture new business models or hybrid activities that, although not explicitly mentioned in the EBA guidelines, might pose analogous risks or dependencies.

The guidelines also provide clarification regarding situations in which operating leasing, holding or management of real estate, and data processing services activities should be considered as auxiliary to banking activities.

The guidelines entered into application on 4 May 2026.

They can be consulted on the NBB website.

A copy of this circular is sent to the auditor(s), approved auditor(s) of your institution.

We ask you to accept, Madam, Sir, the assurance of our distinguished consideration.

Pierre Wunsch

Governor

Appendix:

EBA guidelines specifying the criteria for identifying the activities referred to in Article 4(1)(18) of Regulation (EU) No 575/2013