Circular NBB_2025_22 on the periodic reporting scheme for electronic money 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 n i^iiiMiK'NationalefHHik DE BELCIQUE VAN BELCIE

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Circulaire
Public
Bruxelles, 16 decembre 2025
Reference: NBB_2025_22 vos correspondants :
Jimmy Jans tel. +32 2 221 38 75 jimmy.ians(a)nbb.be Circular relative to the periodic reporting scheme for electronic money institutions Scope Electronic money institutions referred to in Article 2, 73°, 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 issuing electronic money, and on access to payment systems. Limited electronic money institutions referred to in Article 2, 74°, 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 issuing electronic money, and on access to payment systems. Summary/Objectives This circular replaces Circular NBB_2019_10 of 19 October 2021 and describes the simplification of periodic reporting for the sector of electronic money institutions. The circular covers both the periodic reporting relating to the solvency of these institutions and 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. Public NBB_2025_22 - 16 December 2025 Circular - Page 1/27

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Table 1.5.5 is entirely based on the guidelines of the European Banking Authority on the criteria to be used to determine the minimum amount of professional civil liability insurance or other comparable guarantee under Article 5, paragraphs 4, of Directive (EU) 2015/2366.
Statement No. 1.6 - Detailed numerical information on cross-border activities offered or received abroad by the Belgian institution 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 transactions, by country, of the foreign activities of Belgian payment institutions operating in another EEA State via the 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 for an annual statement of the amount and volumes of channels from which or to which 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 transactions by country must be interpreted as described in Statement No. 5 - Numerical information on payment services; the amount of payment transactions must be declared in euros; the amount and volume of payment transactions 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 payment services in the relevant country. 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 transactions is the number of incoming (in) or outgoing (out) payment transactions declared from the country in which freedom to provide services is exercised. It may be that the processing of the foreign transaction 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.
Table 1.6.2 indicates, by country, the number of active and inactive established agents approved by the Bank.
The volume of transactions indicates, by country, the number of incoming (in) or outgoing ("out") payment transactions from established agents. Transactions 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 that would operate via freedom to provide services in another EEA State.
Table 1.6.4 indicates, by country, the number of branches approved by the Bank. The volume of transactions is the number of incoming (in) or outgoing (out) transactions reviewed or sent via the branch.
Table 1.6.5 is, by country, the sum of the amounts and volumes of payment transactions from Tables 1.6.1, 1.6.2, 1.6.2, 1.6.3, and 1.6.4.
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Table 1.6.6 must provide information on the countries (EU and non-EU) to or from which the Belgian institution 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 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 institution. Countries to or from which funds are received for a volume lower than 5% of the total transactions of the Belgian institution do not need to be declared. The country with the highest volume must be indicated first. The volume of transactions is the number of incoming (in) or outgoing (out) payment transactions of the Belgian institution, including freedom to provide services, established agent networks, non-established agent networks, and branches. Statement No. 1.7 - Safeguarding of funds received for the execution of payment transactions or in exchange for electronic money A specific reporting is expected from electronic money institutions regarding funds they have received in exchange for electronic money and which, at the end of the business day following the day they were received, are still held by the electronic money institution and have not yet been transferred following the use of the electronic money or its redemption. In this reporting, which must present the situation at the reporting date (as defined above in Section 1, Title 1 of this circular), detailed information must be communicated concerning the amount of these funds, as well as the measures that electronic money institutions have taken to safeguard these funds in accordance with Article 194, § 1, 2° and 3° of the Law. Tables 1.7.1 and 1.7.2 aim to provide an overview of the accounts held by the electronic money institution, used for the holding or processing of client assets, with the understanding that it is necessary to explicitly specify which of these accounts are, where applicable, 'separate accounts' (or 'global or individualized separate accounts', within the meaning of Article 194, § 1, 2°, a) of the Law). The following elements must be communicated per account: the account number in IBAN format, the balance in euros, the name, address, as well as the contact details and contact person of the credit institution, and whether a qualified separate account certificate1 provided by the credit institution is present. The institution specifies whether the account is used for the preservation of funds received for the execution of payment transactions or in exchange for electronic money. Tables 1.7.3 and 1.7.4 aim to provide an overview, respectively, of money market funds and assets in which funds have, where applicable, been invested in accordance with Articles 194, § 1, 2°, b) and 194, § 1, 2° c) respectively of the Law, with the
understanding that it is necessary to specify the following elements each time: the amount, currency, name of the money market fund, address, as well as the contact details and contact person (of the distributor) of the money market fund, and whether the conditions are present at the registered office of the electronic money institution. The institution specifies whether the money market funds or the assets in which funds have, where applicable, been invested are used for the preservation of funds received for the execution of payment transactions or in exchange for electronic money. 1 Certificate mentioning the following elements: signature by the credit institution, mention of compliance with respect to the PSD2 Directive and Article 194 of the Law, the name of the account holder, the IBAN of the account, the confirmation that the account does not fall under the 'single account' clause of all accounts held with this credit institution. Public NBB_2025_22 - 16 December 2025 Circular - Page 9/27

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Table 1.7.5 aims to provide an overview of the insurance, guarantees, or sureties2 by which funds have, where applicable, been covered in accordance with Article 194, § 1, 3° of the Law; with the understanding that it is necessary to specify the following elements each time: the amount covered, currency, name, address, as well as the contact details and contact person of the insurance company or credit institution that granted the insurance, guarantee, or surety, and whether the conditions are present at the registered office of the electronic money institution. The institution specifies whether the insurance, guarantee, or surety is used for the preservation of funds received for the execution of payment transactions or in exchange for electronic money.
Table 1.7.6 presents the total amount of funds held. Institutions transmit to the Bank, using the application provided for this purpose, a copy of the certificates and/or contracts present for which they have given confirmation in Tables 1.7.1, 1.7.3, 1.7.4, and 1.7.5.
Section 3 - Periodic information on solvency

Content
Institutions must report to the Bank on the adequacy of their own funds relative to the standards provided by the Regulation of 2 October 2018 concerning the own funds of electronic money institutions and the placement of funds received in exchange for issued electronic money. This information is provided based on Statements No. 2.1 (appendix) and 2.2 (appendix).
Commentary on Statement 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 4 of the Regulation concerning the own funds of electronic money institutions; sum of 020 + 130 + 140. Line 015 This line includes Tier 1 own funds; sum of 020 + 130. Line 020 This line includes Tier 1 basic own funds; sum of 030 + 040 + 050 + 060 + 070 + 080 + 090 + 100 + 110 + 120. Line 030 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. 2 The application of Article 194, § 1, 3°, of the Law requires prior approval by the Bank. Public NBB_2025_22 - 16 December 2025 Circular - Page 10/27

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Line 040
This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. Line 050 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. Line 060 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. Line 070 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, the elements defined in Article 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. Line 080 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money 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 26 June 2013. Line 090 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. Line 100 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. Line 110 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. Line 120 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, the elements defined in Article 36 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. Public NBB_2025_22 - 16 December 2025 Circular - Page 11/27

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Line 130
This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, additional Tier 1 own funds defined in Part Two, Chapter 3, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013. Line 140 This line includes, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, Tier 2 own funds defined in Part Two, Chapter 4, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013.
3. Commentary on Statement No. 2.2
In accordance with the Regulation concerning the own funds of electronic money institutions, the institution is required to declare the necessary data on its required own funds.
Line 190
This line includes the minimum legally required own funds as applicable to the electronic money institution (see Article 6 of the National Bank of Belgium Regulation of 2 October 2018 concerning the own funds of electronic money institutions and the placement of funds received in exchange for issued electronic money). For electronic money institutions, this amount must, at all times, be greater than or equal to the amount referred to in Article 173, first paragraph, 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 issuing electronic money, and on access to payment systems, or, if higher, to the sum of the amounts included in lines 195 and 600. Line 195 This line includes the amount corresponding to line 200, 300, or 400, depending on the method used by the institution for providing payment services, in accordance with Article 6 of the National Bank of Belgium Regulation of 2 October 2018 concerning the own funds of electronic money institutions and the placement of funds received in exchange for issued electronic money. Line 200 This line includes, by institutions calculating solvency requirements according to Method A, 10% of the general expenses of the previous financial year. When the institution has not recorded a complete year of activity at the calculation date, the own fund requirement is equal to 10% of the general expenses amount provided in its business plan, unless the Bank requires an adjustment of this plan. Lines 210 to 260 inclusive These lines include eligible general expenses. Other 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 transactions, which do not need to be borne in the absence of activity. Public NBB_2025_22 - 16 December 2025 Circular - Page 12/27

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Line 300
This line includes, by institutions calculating solvency requirements according to Method B, the solvency requirements (i.e., after multiplication by the scaling factor k) (see Article 6 of the Regulation concerning the own funds of electronic money institutions). Line 310 This line includes the total amount of payment transactions carried out by the institution during the previous financial year. Thus, for the reporting of 30 September 2019, the institution declares the total amount of payment transactions it carried out during the 2018 financial year. As specified in Section 2, when the distinction between incoming and outgoing flows is relevant, 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) should in principle be identical. Similarly, the total amount of payment transactions carried out by the institution during the previous financial year should in principle be equal to each of these two amounts as declared at the end of the previous financial year. When the institution has not recorded a complete year of activity at the calculation date, it takes into account in its calculation the total amount of payment transactions provided 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 310. 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 complete year of activity at the calculation date, 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 institution, in accordance with Article 6 of the Regulation concerning the own funds of electronic money institutions. Line 400 This line includes, by institutions calculating solvency requirements according to Method C, the solvency requirements (i.e., after multiplication by the scaling factor k) (see Article 6 of the Regulation concerning the own funds of electronic money institutions). Lines 410 to 440 inclusive These lines include the respective components of the applicable indicator. Public NBB_2025_22 - 16 December 2025 Circular - Page 13/27

Madame,
Monsieur,

This circular includes the simplification of periodic reporting for electronic money institutions, in application of the law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, access to the activity of payment service providers, and the activity of electronic money issuance, and access to payment systems.

The circular covers both the periodic reporting related to the solvency of institutions and the periodic financial reporting. This reporting is intended for the Bank. Belgian electronic money institutions communicate a detailed financial statement and numerical information to the Bank, prepared in accordance with the modalities and instructions described in this circular.

The simplification of this reporting implies the following adjustments:

Tableau 1.5.1. Transaction amount:

omission of the geographical breakdown;
omission of the breakdown by payment service (1 to 6, in accordance with Annex I.A of the law of 11 March 2018).

Tableau 1.5.2. Number of transactions:

omission of the geographical breakdown;
omission of the breakdown by payment service (1 to 6, in accordance with Annex I.A of the law of 11 March 2018).

Tableau 1.5.3. Turnover realized on transactions:

complete omission.

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

omission of the geographical breakdown;
omission of the breakdown by payment service user (PSU);
reduction of the frequency, from quarterly to annual.

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

omission of the geographical breakdown;
omission of the breakdown by account servicing payment service provider (ASPSP);
reduction of the frequency, from quarterly to annual.

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

omission of the geographical breakdown;
omission of the breakdown by account servicing payment service provider (ASPSPs) and payment service user (PSU);
reduction of the frequency, from quarterly to annual.

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PART 1: Schema for electronic money institutions

Section 1 - General provisions

Legal basis

Article 197, § 2 of the law of 11 March 2018 prescribes the following: electronic money institutions periodically communicate a detailed financial statement 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 taken for its implementation or the implementation measures of Directive 2009/110/EC.

For the aspect related to the solvency of electronic money institutions, reference must also be made to the Bank's regulation of 2 October 2018 concerning the own funds of electronic money institutions and the placement of funds received in exchange for issued electronic money, approved by the Royal Decree of 21 March 2019, as well as to the Royal Decree of 25 April 2014 approving the regulation of the National Bank of Belgium of 16 April 2014 concerning the own funds of credit institutions and stock exchange companies.

Scope of application

This part of the circular applies to the electronic money institutions referred to in Article 2, 73° of the law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, access to the activity of payment service providers, and the activity of electronic money issuance, and access to payment systems.

Frequency of reporting

Except for report forms no. 1.3 (allocation account), no. 1.5.4 (payment initiation services and account information services), no. 1.5.5 (minimum amount of professional civil liability insurance or other comparable guarantee) and no. 1.6 (numerical information on cross-border activities), which will be communicated annually, the report forms described below will be communicated quarterly to the Bank, and this 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 to the Board of Directors or managers.

Institutions must, however, be organizationally able to prepare, if necessary, in exceptional circumstances and at the request of the Bank, the report forms at a higher frequency.

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

Modalities of communication

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

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Other provisions

Unless otherwise stated, the amounts presented in the report forms are expressed in euros.

Entry into force

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

Section 2 - Periodic financial reporting

Content of financial reporting

The periodic information to be communicated on a standalone basis to the Bank under this circular includes the following report forms, as described in the annex:

Form no. 1.1.A: Balance sheet after allocation
Form no. 1.1.B: Balance sheet after allocation
Form no. 1.2: Income statement
Form no. 1.3: Allocation account
Form no. 1.4: Identification of third-party funds held and recorded on the balance sheet
Form no. 1.5: Supplementary statistical information tables:
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 civil liability insurance or other comparable guarantee

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

Form no. 1.6: Detailed numerical information on cross-border activities offered or reviewed abroad by the Belgian payment institution. This form is broken down as follows:
1.6.1: Foreign payment services provided by freedom to provide services 1.6.2: Foreign payment services provided via a foreign network of established agents 1.6.3: Foreign payment services provided via a foreign network of agents by freedom to provide services 1.6.4: Foreign payment services provided via an EM branch 1.6.5: Total of foreign payment services 1.6.6: Detail of payment operations in Belgium

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

Form no. 1.7: Protection of funds received for the execution of payment operations or in exchange for electronic money:
1.7.1: Separate accounts for holding client funds 1.7.2: Non-separate accounts for processing client funds 1.7.3: Approved money market investment funds for the preservation of client funds 1.7.4: Safe and liquid assets with a low risk rate 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 holding of client funds and attestations/conditions presented

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

Instructions regarding financial report forms

Forms no. 1.1.A and 1.1.B - Balance sheet after allocation

Institutions 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 197 of the law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, access to the activity of payment service providers, and the activity of electronic money issuance, and access to payment systems).

The balance sheet is prepared after allocation, that is to say taking into account any decisions on the allocation of the balance of the income statement for 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 prepared subject to this decision.

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

Form no. 1.2 - Income statement

Institutions 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 197 of the law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, access to the activity of payment service providers, and 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].

Form no. 1.3 - Allocation account

Institutions 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.

Form no. 1.4 - Identification of third-party funds held and recorded on the balance sheet

Institutions 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.

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Article 194 of the law of 11 March 2018 on the status and supervision of payment institutions and electronic money institutions, access to the activity of payment service providers, and the activity of electronic money issuance, and access to payment systems requires that funds received in exchange for issued electronic money be distinctly identified in the accounting, and never mixed with other funds. These funds must furthermore be deposited, invested or covered according to the modalities provided for in Article 194 of the law of 11 March 2018.

Article 194, § 3 of the law of 11 March 2018 provides for comparable provisions (by reference to Article 42 of the law of 11 March 2018) for funds received by the electronic money institution in the context of providing payment services not linked to the issuance of electronic money.

Table 1.4 aims to identify such funds when they are recorded on the balance sheet and allows verifying that the segregation of these funds is in compliance with the requirements. The reporting covers only the funds still held at the closing date of the balance sheet 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 the counterparty (as defined in Article 194 of the law of 11 March 2018) with whom the funds have been placed. When the counterparty places the funds in the name and for the account of the electronic money institution with a third party, this latter constitutes the counterparty of the institution to be mentioned in report form no. 1.4.

Form no. 1.5 - Supplementary statistical information tables

By "deposits", one must understand the debts resulting from the activity of collecting refundable funds from the clientele, with the exception of debts represented by a security.

By "clientele", one must understand all persons other than credit institutions, central banks and assimilated bodies, postal cheque offices and national and international official bodies with a banking character.

By "electronic money having a material support (hardware type)", one must understand electronic money that relies on a material support (electronic wallet or prepaid card ("hardware"), notably with a chip).

By "electronic money having software as support (software type)", one must understand electronic money that relies on a software support (virtual wallet that appears in the memory of a computer, for example for internet transactions).

By "receivables", one must understand the receivables resulting from the usual activity of the institution.

However, receivables that are represented by securities or negotiable instruments as well as receivables that are part of fixed assets are excluded.

Separate tables must be established at the end of each month:

for all currencies (euro and foreign currencies) for euro equivalent;
separately for the euro.

The Bank reserves the right to request, on an ad hoc and exceptional basis, additional statistical information in the case either of significant or unexpected developments in certain items of the supplementary statistical information tables, or of specific and targeted requests from the European Central Bank.

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Forms no. 1.5.1 and 1.5.2 - Numerical information on payment services

Electronic money institutions that execute payment services referred to in Article 191, § 1 of the law of 11 March 2018 communicate numerical information on transactions carried out as payment services, according to the schema included in the annex.

The information notably covers the number (volume) and amount 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 geographical breakdown.

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 normally 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, however, 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 are to be understood as follows:

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

number of payment accounts to which the institution had access: the number of payment accounts of 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 account servicing payment service providers (ASPSP) for losses resulting from one or more of the responsibilities referred to in Article 5, paragraphs 2 and 3, of Directive (EU) 2015/2366.

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Line 450

The applicable indicator is included in this line. 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 supervision under the law.

The applicable indicator is calculated based on the observation of twelve months carried out at the end of the previous financial year.

When the institution has not recorded a complete year of activity at the date of calculation, it takes into account in its calculation of the applicable indicator provided for in its business plan, unless the Bank requires an adjustment of this plan.

Line 460

The average, over the last three financial years, of the applicable indicator is included in this line.

Lines 470 to 510 inclusive

The results of the application of the multiplier as determined in the regulation concerning the own funds of electronic money institutions according to the different tiers are included in these lines.

Line 520

The applicable scale factor k for the reporting institution is included in this line, in accordance with Article 6 of the regulation concerning the own funds of payment institutions.

Line 600

The amount of own funds required for the activity of electronic money issuance is included in this line, in accordance with Article 6, point b) of the regulation of the National Bank of Belgium of 2 October 2018 concerning the own funds of electronic money institutions and the placement of funds received in exchange for issued electronic money.

Line 610

The amount included in this line corresponds to the average of the electronic money in circulation, as defined in Article 2, 77°, of the law on the status and supervision of payment institutions and electronic money institutions, access to the activity of payment service providers, and the activity of electronic money issuance, and access to payment systems.

In accordance with the regulation concerning the own funds of electronic money institutions, an electronic money institution, for which the amount of electronic money in circulation cannot be determined in advance, may, on the basis of historical data, calculate its required own funds based on a representative part of the funds that are presumed to be used in the context of electronic money issuance.

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n I )
Similarly, when an electronic money institution has not completed a sufficient period of activity, its required own funds are calculated based on the estimated electronic money in circulation resulting from its business plan, subject to any eventual adjustment of this plan required by the Bank.

Line 620
The amount included in this line corresponds to 2% of the amount shown in line 610.

Line 700
Own fund requirements for credit granting are included in this line, in accordance with Article 192 of the Law on the status and supervision of payment institutions and electronic money institutions, access to payment service provider activities, and electronic money issuance activities, and access to payment systems, and Article 9 of the Regulation concerning the own funds of electronic money institutions.

Section 4 - Periodic information regarding foreign exchange operations

Content
In accordance with Articles 102 and 207 of the Law of March 11, 2018, on the status and supervision of payment institutions and electronic money institutions, access to payment service provider activities, and electronic money issuance activities, and access to payment systems, within the framework of its mission to supervise foreign exchange operations by Belgian payment institutions and electronic money institutions, Belgian payment institutions and electronic money institutions conducting foreign exchange operations are required to transmit the following three tables to the Bank on a quarterly basis:

3.1: Statement of foreign exchange operations in currencies: purchases 3.2: Statement of foreign exchange operations in currencies: sales 3.3: Overall statement of foreign exchange operations

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 establishes quarterly statistics, by traded currency, of the volume and number of foreign exchange operations from the previous quarter. In this statistics, purchases and sales are treated separately (in tables 3.1 and 3.2). Furthermore, within each table (section), figures are broken down to distinguish operations below 10,000 euros from operations equal to or greater than this amount, and to show separately the figures related to operations concluded with professional counterparties (both Belgian and foreign) (credit institutions, exchange offices, stockbroking companies, La Poste).

When an institution has multiple branches, the aforementioned information must be provided on an aggregated basis, i.e., for all branches combined. 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 do not necessarily need to be mentioned in tables 3.1 and 3.2. However, they must appear in table 3.3 under item 2000.

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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: Schema for limited electronic money institutions

Section 1 - General provisions

Legal basis
Article 197, § 2 of the Law of March 11, 2018 states the following: electronic money 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 royal decrees and regulations taken for its implementation or implementing measures of Directive 2009/110/EC.

For the aspect related to the solvency of electronic money institutions, reference should also be made to the Bank's Regulation of October 2, 2018, concerning the own funds of electronic money institutions and the placement of funds received in exchange for issued electronic money, approved by the Royal Decree of March 21, 2019, as well as the Royal Decree of April 25, 2014 approving the Bank's Regulation of April 16, 2014, concerning the own funds of credit institutions and stockbroking companies.

Scope of application
Part 2 of this circular applies to limited electronic money institutions referred to in Article 2, 74° of the Law of March 11, 2018, and which are registered pursuant to Article 200 of the Law of March 11, 2018, on the status and supervision of payment institutions and electronic money institutions, access to payment service provider activities, and electronic money issuance activities, and access to payment systems.
Reporting frequency
Except for reporting forms no. 1.3 (allocation of profits account), no. 1.5.4 (payment initiation and account information services), and no. 1.5.5 (minimum amount of professional civil 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 calendar month following the reporting date. When the reporting date coincides with the closing date, the information must relate to the situation after the treatment of management proposals to the board of directors or managers.

Institutions must, however, be organizationally prepared to establish, if necessary, in exceptional circumstances and at the Bank's request, the reporting forms at a higher frequency.

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

Communication methods
These reporting forms, as well as other reporting obligations, will be communicated according to the Bank's appropriate procedures.

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Institutions ensure that the submitted reporting forms do not require corrections. If corrections prove necessary, they will in principle be made by sending a new corrected form bearing the note "corrected form."

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

Section 2 - Periodic financial reporting

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

Form no. 1.1.A: Balance sheet after allocation
Form no. 1.1.B: Balance sheet after allocation
Form no. 1.2: Income statement
Form no. 1.3: Allocation of profits account
Form no. 1.4: Identification of third-party funds held and included in the balance sheet
Form no. 1.5: Supplementary statistical information tables:
- 1.5.1: Transaction amounts (in euros)
- 1.5.2: Number of transactions

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

Instructions regarding financial reporting forms
Forms no. 1.1.A and 1.1.B - Balance sheet after allocation Institutions communicate a balance sheet established according to the schema included in the annex, applying the same accounting and valuation rules as for their annual accounts (Article 197 of the Law of March 11, 2018, on the status and supervision of payment institutions and electronic money institutions, access to payment service provider activities, and electronic money issuance activities, and access to payment systems).

The balance sheet is established after allocation, i.e., taking into account any decisions on the allocation of the balance of the income statement of the financial year and retained earnings. 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.

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

Form no. 1.2 - Income statement
Institutions communicate an income statement according to the schema included in the annex, applying the same accounting and valuation rules as for their annual accounts (Article 197 of the Law of March 11, 2018, on the status and supervision of payment institutions and electronic money institutions, access to payment service provider activities, and electronic money issuance activities, and access to payment systems).

Form no. 1.3 - Allocation of profits account
Institutions communicate an annual allocation of profits account established in accordance with the rules applied for annual accounts, and according to the schema included in the annex.

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

Article 194 of the Law of March 11, 2018, on the status and supervision of payment institutions and electronic money institutions, access to payment service provider activities, and electronic money issuance activities, and access to payment systems, requires that funds received in exchange for issued electronic money be distinctly identified in the accounting, and never mixed with other funds. These funds must furthermore be deposited, invested, or covered according to the modalities provided in Article 194 of the Law of March 11, 2018.

Article 194, § 3 of the Law of March 11, 2018 provides comparable provisions (by reference to Article 42 of the Law of March 11, 2018) for funds received by the electronic money institution in the context of providing payment services not related to the issuance of electronic money.

Table 1.4 aims to identify such funds when they are included in 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 reporting form requires the breakdown of funds received by the counterparty (as defined in Article 194 of the Law of March 11, 2018) with whom the funds have been placed. When the counterparty places the funds in the name and on behalf of the electronic money institution with a third party, this third party constitutes the counterparty of the institution to be mentioned in reporting form no. 1.4.

Form no. 1.5 - Supplementary statistical information tables By "deposits," it is understood debts resulting from the activity of collecting refundable funds from clients, excluding debts represented by a title.

By "clients," it is understood all persons other than credit institutions, central banks and assimilated bodies, postal check offices, and national and international official bodies with a banking character.

By "electronic money with a material support (hardware type)," it is understood electronic money based on a material support (electronic wallet or prepaid card ("hardware"), notably with a chip).

By "electronic money with software support (software type)," it is understood electronic money based on software support (virtual wallet located in the memory of a computer, for example for internet transactions).

By "receivables," it is understood receivables resulting from the usual activity of the institution. However, receivables represented by securities or negotiable instruments, and receivables forming part of fixed assets, are excluded.

Separate tables must be established at the end of each month:

for all currencies (euro and foreign currencies) for euro equivalent;
separately for the euro.

The Bank reserves the right to request, on an ad hoc and exceptional basis, additional statistical information in cases of either significant or unexpected developments in certain items of the supplementary statistical information tables, or of express and targeted requests from the European Central Bank.

Forms no. 1.5.1 and 1.5.2 - Numerical information on payment services Limited electronic money institutions providing payment services referred to in Article 203 of the Law of March 11, 2018, communicate numerical information on transactions carried out as payment services, according to the schema included in the annex.

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

These data must be broken down by outgoing flows (out) and, if 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 in transactions differs from the number of out transactions.

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) should in principle be identical. The Bank may request an explanation from the institution if this is not the case.

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Line 060
Included in this line, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, are 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
Included in this line, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, are 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
Included in this line, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, are the elements defined in the second part, chapter 1, section 2, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.

Line 090
Included in this line, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, are 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
Included in this line, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, are 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
Included in this line, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, are 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
Included in this line, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, are 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
Included in this line, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, are additional tier 1 own funds defined in the second part, chapter 3, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.

Line 140
Included in this line, in accordance with Article 4 of the Regulation concerning the own funds of electronic money institutions, are tier 2 own funds defined in the second part, chapter 4, of Regulation (EU) No 575/2013 of the European Parliament and of the Council of June 26, 2013.

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3. Commentary on table no. 2.2
In accordance with the Regulation concerning the own funds of electronic money institutions, the institution is required to declare the necessary data on its required own funds.

Line 190
Included in this line are the minimum own funds legally required as applicable to the limited electronic money institution (see Article 6 of the National Bank of Belgium's Regulation of October 2, 2018, concerning the own funds of electronic money institutions and the placement of funds received in exchange for issued electronic money).

In accordance with Article 3 of the Royal Decree of June 3, 2018 implementing the Law of March 11, 2018 regarding limited payment institutions and limited electronic money institutions, limited electronic money institutions are exempt from the application of Article 173 of the Law of March 11, 2018, provided that Article 17 remains applicable regarding the payment services offered by the limited electronic money institution.

Line 195
Included in this line is the amount corresponding to line 200, 300, or 400, depending on the method used by the institution for providing payment services, in accordance with Article 6 of the National Bank of Belgium's Regulation of October 2, 2018, concerning the own funds of electronic money institutions and the placement of funds received in exchange for issued electronic money.

Line 200
Included in this line, by institutions calculating solvency requirements according to method A, are 10% of the general expenses of the previous financial year.

When the institution has not recorded a complete year of activity at the calculation date, the own fund requirement is equal to 10% of the general expenses amount specified in its business plan, unless the Bank requires an adjustment of this plan.

Lines 210 to 260 inclusive
Included in these lines are eligible general expenses. Other operating expenses directly linked to the volume of activity are not taken into account for the determination of the requirement. For example, direct remuneration linked to the level of activity or the realization of operations, which do not need to be borne in the absence of activity, are excluded.

Line 300
Included in this line, by institutions calculating solvency requirements according to method B, are the solvency requirements (i.e., after multiplication by the scaling factor k) (see Article 6 of the Regulation concerning the own funds of electronic money institutions).

Line 310
Included in this line is the total amount of payment operations carried out by the institution during the previous financial year. Thus, for the reporting of September 30, 2019, the institution declares the total amount of payment operations it carried out during the 2018 financial year.

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As specified in section 2, when the distinction between incoming and outgoing flows is relevant, the amount of transactions in operated by the institution (in euros) and the amount of transactions out operated by the institution (in euros) must in principle be identical. Similarly, the total amount of payment transactions carried out by the institution during the previous financial year must in principle be equal to each of these two amounts as declared at the end of the previous financial year. When the institution has not recorded a full year of activity at the calculation date, it takes into account in its calculation the total amount of payment transactions planned in its business plan, unless the Bank requires an adjustment to this plan.

Line 320
This line includes the payment volume, which is one-twelfth of the total amount declared in line 310. 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 calculation date, 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 according to the different tiers.

Line 380
This line includes the scaling factor k applicable to the reporting institution, in accordance with Article 6 of the regulation concerning the own funds of electronic money institutions.

Line 400
This line includes, for institutions that calculate solvency requirements according to Method C, the solvency requirements (i.e., after multiplication by the scaling factor k) (see Article 6 of the regulation concerning the own funds of electronic money 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 financial year.

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When the institution has not recorded a full year of activity at the calculation date, it takes into account in its calculation the applicable indicator provided in its business plan, unless the Bank requires an adjustment to this plan.

Line 460
This line includes the average, over the last three financial 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 electronic money institutions according to the different tiers.

Line 520
This line includes the scaling factor k applicable to the reporting institution, in accordance with Article 6 of the regulation concerning the own funds of payment institutions.

Line 600
This line includes the own fund requirements for the electronic money issuance activity, in accordance with Article 6, point b) of the National Bank of Belgium Regulation of 2 October 2018 concerning the own funds of electronic money institutions and the placement of funds received in exchange for the issued electronic money.

Line 610
The amount included in this line corresponds to the average of the electronic money in circulation, as defined in Article 2, 77°, of the law on the status and control of payment institutions and electronic money institutions, access to the activity of payment service providers, and the activity of issuing electronic money, and access to payment systems. In accordance with the regulation concerning the own funds of electronic money institutions, an electronic money institution for which the amount of electronic money in circulation cannot be determined in advance may, based on historical data, calculate its required own funds based on a representative part of the funds presumed to be used in the context of issuing electronic money. Similarly, when an electronic money institution has not completed a sufficient period of activity, its required own funds are calculated based on the estimate of the electronic money in circulation resulting from its business plan, subject to any possible adjustment of this plan required by the Bank.

Line 620
The amount included in this line corresponds to 2% of the amount shown in line 610.

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Line 700
This line includes the own fund requirements for granting credit, in accordance with Article 192 of the law on the status and control of payment institutions and electronic money institutions, access to the activity of payment service providers, and the activity of issuing electronic money, and access to payment systems, and Article 9 of the regulation concerning the own funds of electronic money institutions.

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PART 3: 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 institution.
Please accept, Madam, Sir, the assurance of my distinguished consideration.

Pierre Wunsch Governor
Tim Hermans
Director - Secretary Vincent Magnee
Director

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Circular NBB_2025_22 on the periodic reporting scheme for electronic money institutions

Lineage: In force