Circular NBB_2025_21 / Circular on the periodic reporting scheme for payment institutions

boulevard de Berlaimont 14 - BE-1000 Bruxelles tel. +32 2 221 23 88 numero d'entreprise : 0203.201.340 RPM Bruxelles www.bnb.be Nationale Bank VAN BELGIE Eurosystem

Circular
Public
Brussels, 16 December 2025

Reference: NBB_2025_21

your correspondents:
Jimmy Jans tel. +32 2 221 38 75 jimmy.jans@nbb.be

Circular on the periodic reporting scheme for payment institutions

Scope

Payment institutions of Belgian law referred to in Article 2, 8°, of the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, on access to the activity of payment service providers, and on the activity of electronic money issuance and access to payment systems.

Aggregate account payment institutions referred to in Article 2, 9°, of the Law which are registered pursuant to Article 89 of the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, on access to the activity of payment service providers, and on the activity of electronic money issuance and access to payment systems.

Limited payment institutions referred to in Article 2, 9°, of the Law which are registered pursuant to Article 82 of the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, on access to the activity of payment service providers, and on the activity of electronic money issuance and access to payment systems.

Summary/Objectives

This circular replaces Circular NBB_2018_31 of 19 October 2021 and describes the simplification of periodic reporting for the sector of payment institutions. The circular covers both the periodic reporting related to the solvency of these institutions, as well as the periodic financial reporting (essentially the balance sheet, income statement, and information on transactions carried out). The reporting statements defined in the circular are intended for the National Bank of Belgium (hereinafter: the "Bank") and will, unless otherwise specified, be communicated on a quarterly basis.

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Dear Sir,
Dear Madam,

This circular includes the simplification of periodic reporting by payment institutions, in application of the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, on access to the activity of payment service providers, and on the activity of electronic money issuance and access to payment systems. The circular covers both the periodic reporting related to the solvency of the institutions and the periodic financial reporting. This reporting is intended for the Bank. Belgian payment institutions communicate to the Bank a detailed financial situation and numerical information established in accordance with the modalities and instructions described in this circular.

The simplification of this reporting implies the following adjustments:

Table 1.5.1. Transaction amount:

• omission of the geographic distribution
• omission of the distribution by payment service (1 to 6, in accordance with Annex I.A of the Law of 11 March 2018).

Table 1.5.2. Number of transactions:

• omission of the geographic distribution
• omission of the distribution by payment service (1 to 6, in accordance with Annex I.A of the Law of 11 March 2018).

Table 1.5.3. Revenue generated on transactions:

• complete omission.

Table 1.5.4.1. Payment Initiation Services and Account Information Services - Number of users:

• omission of the geographic distribution;
• omission of the distribution by payment service user (PSU);
• reduction of the frequency, from quarterly to annual.

Table 1.5.4.2. Payment Initiation Services and Account Information Services - Payment:

• omission of the geographic distribution;
• omission of the distribution by account servicing payment service providers (ASPSP)
• reduction of the frequency, from quarterly to annual.

Table 1.5.4.3. Payment Initiation Services and Account Information Services - Refund:

• omission of the geographic distribution;
• omission of the distribution by account servicing payment service providers (ASPSP) and payment service users (PSU);
• reduction of the frequency, from quarterly to annual.

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PART 1: Scheme for payment institutions
Section 1 - General provisions

1. Legal basis

Article 77 of the Law of 11 March 2018 states the following: payment institutions periodically communicate a detailed financial situation to the Bank. This is established in accordance with the rules fixed by the Bank, which also determines its frequency. The Bank may, furthermore, prescribe the regular transmission of other numerical or descriptive information necessary to verify compliance with the provisions of this Law or the decrees and regulations taken for its implementation or the implementing measures of Directive (EU) 2015/2366.

For the part related to the solvency of payment institutions, reference should also be made to the Regulation of the Bank of 10 April 2018 concerning the own funds of payment institutions, approved by the Royal Decree of 27 April 2018, as well as to the Royal Decree of 25 April 2014 approving the Regulation of 16 April 2014 of the National Bank of Belgium concerning the own funds of credit institutions and brokerage companies.

2. Scope

Part 1 of this circular is applicable to payment institutions of Belgian law referred to in Article 2, 8° of the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, on access to the activity of payment service providers, and on the activity of electronic money issuance and access to payment systems.

3. Frequency of reporting

Except for reporting statements no. 1.3 (allocation account), no. 1.5.4 (payment initiation services and account information services), no. 1.5.5 (minimum amount of professional liability insurance or another comparable guarantee) and no. 1.6 (numerical information on cross-border activities), which will be communicated annually, the reporting statements described below will be communicated quarterly to the Bank, no later than the first business day of the second calendar month following the reporting date. When the reporting date coincides with the closing date, the information must relate to the situation after processing of the proposals of the Management to the Board of Directors or to the managers.

Payment institutions must, however, be organizationally capable of establishing, if necessary, in exceptional circumstances and at the request of the Bank, the reporting statements at a higher frequency.

The annexes to the statutory annual accounts as well as, if applicable, the consolidated annual accounts of payment institutions must be communicated annually to the Bank, fifteen days before the general meeting.

4. Communication modalities

These reporting statements, as well as other reporting obligations, must be transmitted according to the Bank's appropriate procedures. The institutions ensure that the reporting statements transmitted do not require corrections. If corrections prove necessary, they will in principle be carried out by sending a new corrected statement bearing the mention "corrected statement".

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5. Other provisions

Unless otherwise stated, the amounts presented in the reporting statements are expressed in euros.

6. Entry into force

This circular enters into force on 1 January 2026. From then on, the first reporting in application of this circular must be communicated no later than 30 April 2026.

Section 2 - Periodic financial reporting

1. Content of financial reporting

The periodic information to be communicated on a legal entity basis to the Bank pursuant to this circular includes the following reporting statements, as described in the annex:

• Statement no. 1.1: Balance sheet after allocation
• Statement no. 1.2: Income statement
• Statement no. 1.3: Allocation account
• Statement no. 1.4: Identification of third-party funds held and included in the balance sheet
• Statement no. 1.5: General numerical information on payment services; which is subdivided as follows:
  1.5.1: Transaction amount (in euros)
  1.5.2: Number of transactions
  1.5.4: Payment initiation services and account information services 1.5.5: Minimum amount of professional liability insurance or another comparable guarantee

Statements no. 1.5.1 and 1.5.2 apply only to institutions providing payment services. Statements no. 1.5.4 and 1.5.5 apply only to institutions providing account information services and/or payment initiation services.

• Statement no. 1.6: Detailed numerical information on cross-border payment services offered or received abroad. This statement is broken down as follows:
  1.6.1: Foreign payment services provided under freedom to provide services 1.6.2: Foreign payment services provided through the intermediary of a foreign network of established agents 1.6.3: Foreign payment services provided through the intermediary of a foreign network of agents under freedom to provide services 1.6.4: Foreign payment services provided through the intermediary of an EU branch 1.6.5: Total of foreign payment services 1.6.6: Detail of payment operations in Belgium

Statement no. 1.6 applies only to institutions offering fund transmission services.

• Statement no. 1.7: Protection of funds received for the execution of payment operations:
  1.7.1: Separate accounts for the holding of client funds 1.7.2: Non-separate accounts used for the processing of client funds 1.7.3: Approved monetary funds for the preservation of client funds 1.7.4: Liquid and safe low-risk assets for the preservation of client funds 1.7.5: Insurance, guarantee or surety for the preservation of client funds 1.7.6: Total amount of client funds held and attestations/conditions presented

The annexes to the statutory annual accounts as well as, if applicable, the consolidated annual accounts of payment institutions will also be communicated annually to the Bank according to the modalities described in Section 1.

2. Instructions regarding financial reporting statements

Statement no. 1.1 - Balance sheet after allocation

Payment institutions communicate a balance sheet established according to the scheme reproduced in the annex, applying the same accounting and valuation rules as for their annual accounts (in accordance with Article 78 of the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, on access to the activity of payment service providers, and on the activity of electronic money issuance and access to payment systems).

The balance sheet is established after allocation, that is to say taking into account any decisions on the allocation of the balance of the income statement of the financial year and the carried-forward result. When, in the absence of a decision taken by the competent body, this allocation is not definitive, the balance sheet is established subject to the suspensive condition of this decision.

The balance sheet is established at the closing date of the interim or annual period to which it relates.

Statement no. 1.2 - Income statement

Payment institutions communicate an income statement established according to the scheme reproduced in the annex, applying the same accounting and valuation rules as for their annual accounts (in accordance with Article 78 of the Law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, on access to the activity of payment service providers, and on the activity of electronic money issuance and access to payment systems).

The income statement covers the period from the beginning of the statutory accounting financial year of the institution up to the closing date of the interim or annual period to which it relates (year-to-date).

Statement no. 1.3 - Allocation account

Payment institutions communicate an annual allocation account of results established in accordance with the rules applied for the annual accounts, and according to the scheme reproduced in the annex.

Statement no. 1.4 - Identification of third-party funds held and included in the balance sheet

Payment institutions communicate a table identifying, at the closing date of the reporting period, the third-party funds held and included in the balance sheet, according to the scheme reproduced in the annex.

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Article 42 of the Law requires that funds received from third parties directly or through other payment service providers, for the execution of payment operations, be distinctly identified in the accounting, and never mixed with other funds. The table aims to identify such funds when they are included in the balance sheet and allows verifying that the segregation of these funds is in compliance with the requirements. The reporting concerns only the funds still held at the closing date of the balance sheet and not the incoming and outgoing flows which have been fully compensated during the financial year.

The reporting statement requires the breakdown of funds received by counterparty with whom the funds have been placed. When the counterparty places the funds in the name and for the account of the payment institution with a third party, this third party constitutes the counterparty of the institution to be mentioned in reporting statement no. 4.

Statement no. 1.5 - Numerical information on payment services

Payment institutions communicate numerical information on transactions carried out as payment services, according to the scheme reproduced in the annex.

The information concerns on the one hand the number (volume) and the amount (in euros) of transactions carried out by the institution for payment services 1 to 6, as they appear in Annex I.A of the Law of 11 March 2018. This concerns transactions that have taken place worldwide, without geographic distribution.

The reporting of numerical information on payment services covers the period from the beginning of the statutory accounting financial year of the institution up to the closing date of the interim or annual period to which it relates (year-to-date).

These data must be broken down according to outgoing flows (out) and, if applicable, incoming flows (in). This subdivision is only required for payment services for which such a distinction is relevant, which is only the case if the number of transactions carried out in differs from the number of transactions carried out out.

The amount of in transactions carried out by the institution (in euros) and the amount of out transactions carried out by the institution (in euros) must in principle be identical. The Bank may ask the institution for an explanation if this is not the case.

If, as explained above, the distinction between incoming and outgoing flows is not relevant, the reporting of all numerical information on payment services must only be carried out in the out column. If the distinction between incoming and outgoing flows is relevant, the declaration must be carried out in both the out and in columns.

For the reporting of statistics in table 1.5.4 on payment initiation services and account information services, the following concepts should be understood as follows:

number of users: the number of payment service users (also called Payment Service Users or PSU) of the institution who used the service, taking each client separately into account;

number of payment accounts to which the institution had access: the number of payment accounts of the payment service users to which the institution had access;

total number of times an institution had access to payment accounts: the total number of times (frequency) an institution had access to the payment accounts of its payment service users. For payment initiation services, this figure is equal to the total number of payment operations initiated by the institution. For account information service providers, this figure is equal to the total number of consultations the institution carried out on the payment accounts of its payment service users;

value of initiated payments: the total value of all transactions initiated by the institution;

value of reviewed refund requests: the total value of all refund requests submitted by the payment service users of the institution and the account servicing payment service providers (ASPSP) for losses resulting from one or more of the liabilities referred to in Article 5, paragraphs 2 and 3, of Directive (EU) 2015/2366.

Table 1.5.5 is entirely based on the European Banking Authority guidelines on the criteria to be used to determine the minimum amount of professional liability insurance or another comparable guarantee pursuant to Article 5, paragraph 4, of Directive (EU) 2015/2366.

Statement no. 1.6: Detailed numerical information on cross-border payment services offered or received abroad.

Statement no. 1.6 applies only to institutions offering fund transmission services as referred to in point 6 of Annex I of the Law of 11 March 2018.

The purpose of table 1.6 is, on the one hand, to obtain an annual statement of the amount and volume of payment operations, by country, of the foreign activities of Belgian payment institutions operating in another EEA State via freedom to provide services, a network of established agents, a network of non-established agents or an EU branch. On the other hand, table 1.6 must allow establishing an annual statement of the amount and volumes of the channels from which or to which payment institutions execute or receive fund transmissions.

All tables 1.6 must comply with the following rules:

the breakdown of the amount and volume in and out of payment operations by country must be interpreted as described in Statement no. 5 - Numerical information on payment services;

the amount of payment operations must be declared in euros;

the amount and volume of payment operations by country and by table are linked.

In table 1.6.1, the following elements must be declared: 1) the date of approval, by the Bank, of the freedom to provide services by country and 2) the start date of the payment service provision in the country concerned. If conversion to euros is necessary, the exchange rate to be used is that of the last business day of the reporting period.

The volume of operations is the number of incoming (in) or outgoing (out) payment operations declared from the country in which freedom to provide services is exercised. It may be that the processing of the foreign operation takes place in Belgium or in another EU country, but the declaration is made for the country with which the individual client or business relationship is established. Internet client relationships must be declared based on the residence location of the sender or recipient client.

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Table 1.6.2 indicates, by country, the number of active and inactive agents approved by the Bank.
The volume of operations indicates, by country, the number of incoming (in) or outgoing (out) payment operations of established agents. Operations processed by non-established agents must be declared separately in Table 1.6.3.
Table 1.6.3 is structured in the same manner as Table 1.6.2, but concerns figures relating to non-established agents operating under the free provision of services in another EEA Member State.
Table 1.6.4 indicates, by country, the number of branches approved by the Bank. The volume of operations is the number of incoming (in) or outgoing (out) payment operations reviewed or sent via the branch.
Table 1.6.5 is, by country, the sum of the amounts and volumes of payment operations from Tables 1.6.1, 1.6.2, 1.6.2, 1.6.3, and 1.6.4.
Table 1.6.6 must specify the countries (EU and non-EU) to or from which the Belgian establishment receives or sends funds.
In the case where a direct relationship is established with the client, the country to be declared is that of the final sender or recipient of the funds. In this case, the declaration does not include the country of the payment institution's processing centers; when acting as an intermediary for another payment institution, electronic money institution, bank, or other counterparty, the country to be declared is that from or to which the counterparty's funds are received or sent. In this case, it may be either a processing center or another establishment. Countries to or from which funds are received for a volume less than 5% of the total operations of the Belgian establishment need not be declared. The country with the highest volume must be indicated first. The volume of operations is the number of incoming (in) or outgoing (out) payment operations of the Belgian payment institution, including the free provision of services, the network of established agents, the network of non-established agents, and branches.

Form No. 1.7 - Protection of funds received for the execution of payment operations Payment institutions providing the payment services referred to in points 1 to 6 of Annex I.A of the law are required to carry out specific reporting concerning funds entrusted to them by users of said payment services for the execution of payment operations and which are still held by them at the end of the business day following the day they were received and have not yet been transferred to their beneficiary or another payment service provider. This reporting, which reports the situation as of the reporting date (as defined above in section 1, title 3 of this circular), must provide detailed information on the amount of these funds and on the measures taken by payment institutions to protect them in accordance with Article 42, §1, 2° and 3°, of the law. Public NBB_2025_21 - December 16, 2025 Circular - Page 8/24

Tables 1.7.1 and 1.7.2 aim to provide a statement of accounts held by the payment institution, which are used for the holding or processing of client assets, it being understood that it is necessary to explicitly specify which of them are, if applicable, "separate accounts" (i.e., "distinct global or individualized accounts" within the meaning of Article 42, §1, 2°, a) of the law). For each account, the following information will be communicated: the account number in IBAN format, the balance in euros, the name, address, contact details, and contact person of the credit institution, as well as the indication of the presence or absence of a qualified separate account certificate issued by the credit institution. Tables 1.7.3 and 1.7.4 aim to provide an overview of monetary funds or assets in which funds have, if applicable, been invested pursuant to, respectively, Article 42, §1, 2°, b) and Article 42, §1, 2° c) of the law, systematically specifying: the amount, currency, name of the monetary fund, address, contact details, and contact person (of the distributor) of the monetary fund, as well as the indication of the presence or absence of the conditions at the registered office of the payment institution.
Table 1.7.5 aims to offer an overview of insurance, guarantees, or sureties serving, if applicable, to cover funds in accordance with Article 42, §1, 3°, of the law, systematically specifying: the covered amount, currency, name, address, contact details, and contact person of the insurance company or credit institution that provided the insurance, guarantee, or surety, as well as the indication of the presence or absence of the conditions at the registered office of the payment institution.
Table 1.7.6 specifies the total amount of funds held. Institutions make a copy of the certificates and/or contracts present for which they have transmitted to the Bank a confirmation in Tables 1.7.1, 1.7.3, 1.7.4, and 1.7.5 using the application provided for this purpose.

Section 3 - Periodic information on solvency

1. Content
   Payment institutions must report to the Bank on the adequacy of their own funds relative to the standards provided by the Bank's regulation of April 10, 2018, concerning the own funds of payment institutions.
   This information is provided based on Forms No. 2.1 (appendix) and 2.2 (appendix).

2. Commentary on Form No. 2.1
   If a title or element is preceded by a minus sign (-), the relevant information should also appear with a minus sign. Any amount increasing own funds or own fund requirements is recorded as positive. Conversely, any amount decreasing own funds or own fund requirements is recorded as negative. Line 010 This line includes the total own funds in accordance with Article 5 of the regulation concerning the own funds of payment institutions; sum of 020 + 130 + 140. Line 015 This line includes Category 1 own funds; sum of 020 + 130. Line 020 This line includes Core Tier 1 own funds; sum of 030 + 040 + 050 + 060 + 070 + 080 + 090 + 100 + 110 + 120. Line 030 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Line 040 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Line 050 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Line 060 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Line 070 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Line 080 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Part Two, Title I, Chapter 2, Section 2, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Line 090 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Line 100 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Public NBB_2025_21 - December 16, 2025 Circular - Page 10/24

Line 110
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 120
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 130
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, additional Category 1 own funds defined in Part Two, Title I, Chapter 3, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Line 140 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment institutions, Category 2 own funds as defined in Part Two, Title I, Chapter 4, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.

3. Commentary on Form No. 2.2
   In accordance with the regulation concerning the own funds of payment institutions, the institution must declare in this table the data necessary for the calculation method (A, B, or C) assigned to it.
   Line 190
   This line includes the minimum own funds legally required as applicable to the payment institution (see Article 4 of the regulation concerning the own funds of payment institutions).
   For institutions, this amount must permanently be greater than or equal to the amount referred to in Article 17, paragraph 1, of the Law of March 11, 2018, on the status and control of payment institutions and electronic money institutions, access to the activity of payment service providers, and access to payment systems. Line 200 This line includes, by payment institutions calculating solvency requirements according to Method A, 10% of the previous year's general expenses (see Article 9, §2, of the regulation concerning the own funds of payment institutions). When the institution has not recorded a full year of activity at the date of calculation, the own fund requirement is equal to 10% of the general expenses amount stated in its business plan, unless the Bank requires an adjustment of this plan. Public NBB_2025_21 - December 16, 2025 Circular - Page 11/24

Lines 210 to 260 inclusive
These lines include eligible general expenses. In accordance with Article 9, §2, of the regulation concerning the own funds of payment institutions, other general operating charges directly linked to the volume of activity are not taken into account for the determination of the requirement. Examples of this exclusion include direct remuneration linked to the level of activity or the completion of operations, which should not be borne in the absence of activity. Line 300 This line includes, by payment institutions calculating solvency requirements according to Method B, the solvency requirements (i.e., after multiplication by the scaling factor k) (see Article 9, §2, of the regulation concerning the own funds of payment institutions). Line 310 This line includes the total amount of payment operations that the payment institution has carried out during the previous year. Thus, for the reporting of September 30, 2019, the payment institution declares the total amount of payment operations it carried out during the 2018 fiscal year. As specified in Section 2, when the distinction between incoming and outgoing flows is relevant, the amount of transactions processed by the institution (in euros) and the amount of transactions processed by the institution (in euros) should in principle be identical. Likewise, the total amount of payment operations carried out by the payment institution during the previous year should in principle be equal to each of these two amounts as declared at the end of the previous year. When the institution has not recorded a full year of activity at the date of calculation, it takes into account in its calculation the total amount of payment operations stated in its business plan, unless the Bank requires an adjustment of this plan. Line 320 This line includes the payment volume, i.e., one-twelfth of the total amount declared in line 280. If the payment volume is based on a period of less than 12 months, which is only possible when the institution has not recorded a full year of activity at the date of calculation, the amount must be divided by the number of months on which the payment volume calculation is based. Lines 330 to 370 inclusive These lines include the results of applying the percentages determined in the regulation concerning the own funds of payment institutions in accordance with the different bands. Line 380 This line includes the scaling factor k applicable to the reporting payment institution, in accordance with Article 9, §3, of the regulation concerning the own funds of payment institutions. Public NBB_2025_21 - December 16, 2025 Circular - Page 12/24

Line 400
This line includes, by payment institutions calculating solvency requirements according to Method C, the solvency requirements (i.e., after multiplication by the scaling factor k) (see Article 9, §2, of the regulation concerning the own funds of payment institutions).
Lines 410 to 440 inclusive
These lines include the respective components of the applicable indicator.
Line 450
This line includes the applicable indicator. Sum of 410 + 420 + 430 + 440.
Each of the elements listed above is included in the sum with its sign, positive or negative.
Exceptional or unusual income cannot be used to calculate the applicable indicator. Expenses related to the outsourcing of services provided by third parties may reduce the applicable indicator if they are incurred by a company subject to control under the law.
The applicable indicator is calculated based on a twelve-month observation made at the end of the previous year.
When the institution has not recorded a full year of activity at the date of calculation, it takes into account in its calculation the applicable indicator stated in its business plan, unless the Bank requires an adjustment of this plan.
Line 460
This line includes the average, over the last three years, of the applicable indicator.
Lines 470 to 510 inclusive
These lines include the results of applying the multiplier as determined in the regulation concerning the own funds of payment institutions in accordance with the different bands.
Line 520
This line includes the scaling factor k applicable to the reporting payment institution, in accordance with Article 9, §3, of the regulation concerning the own funds of payment institutions.
Line 530
This line includes own fund requirements for granting credit, in accordance with Article 21, §3, 4°, of the Law on the status and control of payment institutions and electronic money institutions, access to the activity of payment service providers, and access to payment systems.
Line 540
This line includes, in accordance with Article 10 of the regulation concerning the own funds of payment institutions, adjustments to own fund requirements.
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Section 4 - Periodic information on foreign exchange operations
1 Content
In accordance with Articles 102 and 207 of the Law of March 11, 2018, on the status and control of payment institutions and electronic money institutions, access to the activity of payment service providers, and access to payment systems, within the framework of its mission to exercise control over the foreign exchange operations of Belgian payment institutions and electronic money institutions, Belgian payment institutions and electronic money institutions that conduct foreign exchange operations are required to transmit the following three tables to the National Bank of Belgium on a quarterly basis:
3.1: Statement of foreign exchange operations on currencies: purchases 3.2: Statement of foreign exchange operations on currencies: sales 3.3: Overall statement of foreign exchange operations

2 Commentary on Tables 3.1, 3.2, and 3.3
Only currency codes corresponding to ISO-4217 codes are accepted in the tables (sections). The reporting institution prepares a quarterly statistic, by currency traded, of the volume and number of foreign exchange operations of the previous quarter. In this statistic, purchases and sales are treated separately (in Tables 3.1 and 3.2). Furthermore, within each table (section), the figures are broken down to distinguish operations less than 10,000 euros from operations equal to or greater than this amount, and to separately display figures relating to operations concluded with professional counterparties (both Belgian and foreign) (credit institutions, exchange offices, stock exchange companies, La Poste). When an institution has multiple branches, the aforementioned information need only be provided on an aggregated basis, i.e., for all branches. There is no need to distinguish whether transactions are in banknotes, by check, or by payment card. Foreign exchange operations with a turnover per currency per month not exceeding the equivalent of 250 euros need not necessarily be mentioned in Tables 3.1 and 3.2. They must, however, appear in Table 3.3 under item 2000.
Table 3.3 includes, both in currencies and in euro equivalent, the general total of foreign exchange operations carried out by the exchange office (both purchases and sales). This total therefore includes operations with clients as well as those concluded with professional counterparties.
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PART 2: Scheme for registered account aggregation payment institutions

Section 1 - General provisions

1. Legal basis
   Article 77 of the Law of March 11, 2018, prescribes that payment institutions periodically communicate a detailed financial situation to the Bank. This is established in accordance with the rules fixed by the Bank, which also determines the frequency. The Bank may, furthermore, prescribe the regular transmission of other numerical or descriptive information necessary to verify compliance with the provisions of this law or the decrees and regulations adopted for its implementation or implementing measures of Directive (EU) 2015/2366.

2. Scope
   Part 2 of this circular applies to registered account aggregation payment institutions referred to in Article 2, 9° of the Law of March 11, 2018, and which are registered pursuant to Article 89 of the Law of March 11, 2018, on the status and control of payment institutions and electronic money institutions, access to the activity of payment service providers, and access to payment systems.

3. Reporting frequency
   Except for reporting forms No. 1.3 (allocation account), No. 1.5.4 (payment initiation and account information services), and No. 1.5.5 (minimum amount of professional liability insurance or other comparable guarantee), which will be communicated annually, the reporting forms described below will be communicated quarterly to the Bank, no later than the first business day of the second civil month following the reporting date. When the reporting date coincides with the closing date, the information must relate to the situation after the processing of the proposals by the management to the board of directors or managers. Payment institutions must, however, be organizationally capable of establishing, if necessary, in exceptional circumstances and upon request of the Bank, the reporting forms at a higher frequency. The appendices to the statutory annual accounts and, if applicable, the consolidated annual accounts of payment institutions will be communicated annually to the Bank, fifteen days before the general meeting.

4. Communication methods
   These reporting forms, as well as other reporting obligations, will be communicated according to the Bank's appropriate procedures. Institutions ensure that the reporting forms transmitted do not require corrections. If corrections prove necessary, they will in principle be made by sending a new corrected form marked "corrected form."

5. Other provisions
   Unless otherwise stated, the amounts presented in the reporting forms are expressed in euros.
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6. Entry into force
   This circular enters into force on January 1, 2026. Consequently, the first reporting under this circular must be communicated no later than April 30, 2026.

Section 2 - Periodic financial reporting

1. Content of financial reporting
   The periodic information to be communicated on a statutory basis to the Bank under this circular includes the following reports, as described in the annex:

• Report No. 1.1.A: Balance sheet after distribution
• Report No. 1.1.B: Balance sheet after distribution
• Report No. 1.2: Income statement
• Report No. 1.3: Allocation account
• Report No. 1.4: Identification of third-party funds held and recorded on the balance sheet
• Report No. 1.5: General numerical information on payment services; which are subdivided as follows:
  1.5.4: Payment initiation and account information services 1.5.5: Minimum amount of professional liability insurance or comparable guarantee The annexes to the statutory annual accounts and, where applicable, the consolidated annual accounts of payment establishments will also be communicated annually to the Bank according to the procedures described in Section 1.

2. Instructions regarding financial report forms
   Report No. 1.1. - Balance sheet after distribution Payment establishments communicate a balance sheet prepared according to the schema included in the annex, applying the same accounting and valuation rules as for their annual accounts (in accordance with Article 78 of the law of March 11, 2018 relating to the status and supervision of payment establishments and electronic money establishments, access to the activity of payment service providers, and the activity of issuing electronic money, and access to payment systems). The balance sheet is prepared after distribution, i.e., taking into account any decisions regarding the allocation of the balance of the income statement account of the financial year and carried-forward results. When, in the absence of a decision taken by the competent body, this distribution is not definitive, the balance sheet is prepared subject to the suspensive condition of this decision. The balance sheet is prepared at the closing date of the interim or annual period to which it relates. Report No. 2 - Income statement Payment establishments communicate an income statement prepared according to the schema included in the annex, applying the same accounting and valuation rules as for their annual accounts (in accordance with Article 78 of the law of March 11, 2018 relating to the status and supervision of payment establishments and electronic money establishments, access to the activity of payment service providers, and the activity of issuing electronic money, and access to payment systems). Public NBB_2025_21 - December 16, 2025 Circular - Page 16/24

The income statement covers the period from the beginning of the statutory accounting financial year of the establishment up to the closing date of the interim or annual period to which it relates (year-to-date).
Report No. 3 - Allocation account
Payment establishments communicate an annual allocation account of results prepared in accordance with the rules applied for annual accounts, and according to the schema included in the annex.
Report No. 4 - Identification of third-party funds held and recorded on the balance sheet This report does not apply to registered payment establishments that provide only account aggregation services.
Report No. 5 - Numerical information on payment services Payment establishments communicate numerical information on transactions carried out as payment services, according to the schema included in the annex.
Registered payment establishments that provide only account aggregation services must establish reporting only for the account aggregation services they have themselves performed.
For the reporting of statistics in table 1.5.4 on payment initiation and account information services, the following concepts should be understood as follows:
number of users: the number of payment service users (also called Payment Service Users or PSU) of the establishment that used the service, taking each client separately into account; number of payment accounts to which the establishment had access: the number of payment accounts of the payment service users to which the establishment had access; total number of times an establishment had access to payment accounts: the total number of times (frequency) an establishment had access to the payment accounts of its payment service users. For payment initiation services, this figure is equal to the total number of payment operations initiated by the establishment. For account information service providers, this figure is equal to the total number of consultations the establishment has performed on the payment accounts of its payment service users; value of initiated payments: the total value of all transactions initiated by the establishment; value of reviewed refund requests: the total value of all refund requests submitted by the payment service users of the establishment and the account servicing payment service providers (PSPGC, also called Account Servicing Payment Service Providers - ASPSP) due to losses resulting from liabilities referred to in Article 5, paragraphs 2 and 3, of Directive (EU) 2015/2366.
Table 1.5.5 is entirely based on the European Banking Authority guidelines concerning the criteria for determining the minimum amount of professional liability insurance or comparable guarantee under Article 5, paragraph 4, of Directive (EU) 2015/2366.
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PART 3: Schema for limited payment establishments
Section 1 - General provisions

1. Legal basis
   Article 77 of the law of March 11, 2018 requires that payment establishments periodically communicate a detailed financial situation to the Bank. This is prepared in accordance with the rules fixed by the Bank, which also determines its frequency. The Bank may, furthermore, prescribe the regular transmission of other numerical or descriptive information necessary to verify compliance with the provisions of this law or the decrees and regulations adopted for its implementation or the implementing measures of Directive (EU) 2015/2366.
   For the aspect related to the solvency of establishments, reference should also be made to the Bank's regulation of April 10, 2018 concerning the own funds of payment establishments, approved by the Royal Decree of April 27, 2018, as well as to the Royal Decree of April 25, 2014 approving the regulation of April 16, 2014 of the National Bank of Belgium concerning the own funds of credit institutions and brokerage companies.

2. Scope of application
   Part 3 of this circular applies to limited payment establishments referred to in Article 2, 9° of the law of March 11, 2018 and who are registered under Article 82 of the law of March 11, 2018 relating to the status and supervision of payment establishments and electronic money establishments, access to the activity of payment service providers, and the activity of issuing electronic money, and access to payment systems.

3. Frequency of reporting
   Except for report No. 1.3 (allocation account), which will be communicated annually, the reports described below will be communicated quarterly to the Bank, no later than the first business day of the second calendar month following the reporting date. When the reporting date coincides with the closing date, the information must relate to the situation after processing the proposals of the Management Board to the Board of Directors or managers. Establishments must, however, be organizationally able to prepare, if necessary, in exceptional circumstances and at the Bank's request, the reports according to a higher frequency. The annexes to the statutory annual accounts and, where applicable, the consolidated annual accounts of establishments will be communicated annually to the Bank, fifteen days before the general meeting.

4. Communication methods
   These reports, as well as other reporting obligations, must be transmitted according to the Bank's appropriate procedures.
   Establishments ensure that the reports transmitted do not require corrections. If corrections prove necessary, they will in principle be carried out by sending a new corrected report bearing the mention "corrected report".
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5. Other provisions
   Unless otherwise stated, the amounts presented in the reports are expressed in euros.

6. Entry into force
   This circular enters into force on January 1, 2026. Consequently, the first reporting under this circular must be communicated no later than April 30, 2026.

Section 2 - Periodic financial reporting

1. Content of financial reporting
   The periodic information to be communicated on a statutory basis to the Bank under this circular includes the following reports, as described in the annex:

• Report No. 1.1: Balance sheet after distribution
• Report No. 1.2: Income statement
• Report No. 1.3: Allocation account
• Report No. 1.4: Identification of third-party funds held and recorded on the balance sheet
• Report No. 1.5: General numerical information on payment services; which are subdivided as follows:
  1.5.1: Transaction amounts (in euros)
  1.5.2: Number of transactions
  The annexes to the statutory annual accounts and, where applicable, the consolidated annual accounts of payment establishments will also be communicated annually to the Bank according to the procedures described in Section 1.

2. Instructions regarding financial report forms
   Report No. 1.1 - Balance sheet after distribution Payment establishments communicate a balance sheet prepared according to the schema included in the annex, applying the same accounting and valuation rules as for their annual accounts (in accordance with Article 78 of the law of March 11, 2018 relating to the status and supervision of payment establishments and electronic money establishments, access to the activity of payment service providers, and the activity of issuing electronic money, and access to payment systems). The balance sheet is prepared after distribution, i.e., taking into account any decisions regarding the allocation of the balance of the income statement account of the financial year and carried-forward results. When, in the absence of a decision taken by the competent body, this distribution is not definitive, the balance sheet is prepared subject to the suspensive condition of this decision. The balance sheet is prepared at the closing date of the interim or annual period to which it relates. Public NBB_2025_21 - December 16, 2025 Circular - Page 19/24

Report No. 1.2 - Income statement
Payment establishments communicate an income statement prepared according to the schema included in the annex, applying the same accounting and valuation rules as for their annual accounts (in accordance with Article 78 of the law of March 11, 2018 relating to the status and supervision of payment establishments and electronic money establishments, access to the activity of payment service providers, and the activity of issuing electronic money, and access to payment systems). The income statement covers the period from the beginning of the statutory accounting financial year of the establishment up to the closing date of the interim or annual period to which it relates (year-to-date). Report No. 1.3 - Allocation account Payment establishments communicate an annual allocation account of results prepared in accordance with the rules applied for annual accounts, and according to the schema included in the annex. Report No. 1.4 - Identification of third-party funds held and recorded on the balance sheet Payment establishments communicate a table identifying, at the closing date of the reporting period, the third-party funds held and recorded on the balance sheet, according to the schema included in the annex.
Article 42 of the law requires that funds received from third parties directly or through other payment service providers, for the execution of payment operations, be distinctly identified in the accounting, and never mixed with other funds. The table aims to identify such funds when they are recorded on the balance sheet and allows verification that the segregation of these funds complies with the requirements. The reporting concerns only the funds still held at the balance sheet closing date and not the incoming and outgoing flows that have been fully compensated during the financial year.
The report form requires the breakdown of funds received by counterparty with whom the funds were placed. When the counterparty places the funds in the name and for the account of the payment establishment with a third party, the latter constitutes the counterparty of the establishment to be mentioned in report form No. 4. Report No. 1.5 - Numerical information on payment services Payment establishments communicate numerical information on transactions carried out as payment services, according to the schema included in the annex. The information notably concerns the number (volume) and amount (in euros) of transactions carried out by the establishment for payment services 1 to 6, as listed in Annex I.A of the law of March 11, 2018. This concerns transactions that took place worldwide, without geographical breakdown. The reporting of numerical information on payment services covers the period from the beginning of the statutory accounting financial year of the establishment up to the closing date of the interim or annual period to which it relates (year-to-date). Public NBB_2025_21 - December 16, 2025 Circular - Page 20/24

These data must be broken down by outgoing flows (out) and, where applicable, incoming flows (in). This subdivision is required only for payment services for which such a distinction is relevant, which is the case only if the number of transactions carried out in differs from the number of transactions carried out out. The amount of in transactions carried out by the establishment (in euros) and the amount of out transactions carried out by the establishment (in euros) must in principle be equal. The Bank may ask the establishment for an explanation if this is not the case. If, as explained above, the distinction between incoming and outgoing flows is not relevant, the reporting of all numerical information relating to payment services should only be done in the out column. If the distinction between incoming and outgoing flows is relevant, the declaration should be done in both the out and in columns.

Section 3 - Periodic information on solvency

1. Content
   Payment establishments must report to the Bank on the adequacy of their own funds relative to the standards provided by the Bank's regulation of April 10, 2018 concerning the own funds of payment establishments.
   This information is provided on the basis of table No. 2.1 (annex) and table No. 2.2 (annex).
2. Commentary on table No. 2.1
   If a title or element is preceded by a minus sign (-), the concerned information should also appear with a minus sign. Any amount increasing own funds or own fund requirements is recorded as positive. Conversely, any amount decreasing own funds or own fund requirements is recorded as negative. Line 010 This line includes the total of own funds in accordance with Article 5 of the regulation concerning the own funds of payment establishments; sum of 020 + 130 + 140. Line 015 This line includes Category 1 own funds; sum of 020 + 130. Line 020 This line includes Core Category 1 own funds; sum of 030 + 040 + 050 + 060 + 070 + 080 + 090 + 100 + 110 + 120. Line 030 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Public NBB_2025_21 - December 16, 2025 Circular - Page 21/24

Line 040
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 050
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 060
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 070
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 080
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Part Two, Title I, Chapter 2, Section 2, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 090
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 100
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 110
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
Line 120
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.
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Line 130
This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, additional Category 1 own funds defined in Part Two, Title I, Chapter 3, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Line 140 This line includes, in accordance with Article 5 of the regulation concerning the own funds of payment establishments, Category 2 own funds as defined in Part Two, Title I, Chapter 4, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013. Public NBB_2025_21 - December 16, 2025 Circular - Page 23/24

PART 4: Annexes
The annex to this circular consists of the following documents:
the reporting tables.
A copy of this circular is addressed to the commissioner(s), approved auditor(s) of your establishment.
Please accept, Madam, Sir, the assurance of my distinguished consideration.

Tim Hermans
Pierre Wunsch Director • Secretary
Governor
Vincent Magnée
Director
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