Communication concerning qualitative reporting by credit institutions and stockbroking firms

NBB_2025_19 – 25 November 2025 Communication – Page1/3 14 Boulevard de Berlaimont – 1000 Brussels +32 2 221 38 12 Company number: 0203.201.340 Brussels RLE www.nbb.be Communication Brussels, 25 November 2025 Reference: NBB_2025_19 Your contact:
Nicolas Strypstein
Tel. +32 2 221 44 74 – Mobile +32 494 53 38 90 nicolas.strypstein@nbb.be Communication concerning qualitative reporting by credit institutions and stockbroking firms Scope

• Credit institutions incorporated under Belgian law;
• Stockbroking firms incorporated under Belgian law; and
• Belgian branches of credit institutions and stockbroking firms incorporated under the law of a non￾EEA country.
  Summary/Objectives
  This communication specifies the “qualitative” reports (on governance, organisational and compliance matters) that credit institutions and stockbroking firms are required to submit to the supervisory authority (NBB/ECB) pursuant to the applicable laws and regulations and provides a framework for the possible use, in these reports, of cross-references to the institution’s internal documents. Structure

1. Qualitative reporting by credit institutions and stockbroking firms
2. Use in qualitative reporting of cross-references to internal documents
3. Transmission channels
   BanqueNationale Jank
   DE BELGIQUE VAN BELGIË
   Eurosystem
   BanqueNationale Jank
   DE BELGIQUE VAN BELGIË
   Eurosystem

NBB_2025_19 – 25 November 2025 Communication – Page2 /3 Dear Sir or Madam, The legislation on the prudential supervision of banks and stockbroking firms1 and the Anti-money Laundering Act2 stipulate that credit institutions and stockbroking firms must submit a number of so-called qualitative reports (“qualitative reporting”) to the supervisory authority, i.e. the National Bank of Belgium (NBB) and/or the European Central Bank (ECB). The purpose of this communication is to provide a centralised list of these qualitative reports3 and to establish a framework that allows, under certain conditions, the use of cross-references therein in order to reduce the administrative burden on in-scope institutions.

1. Qualitative reporting by credit institutions and stockbroking firms
   The qualitative reports to be submitted by credit institutions are listed in Annex 1 to this communication; those to be submitted by stockbroking firms are set out in Annex 2. Each of these two annexes consists of two sections:
   1) Qualitative reporting required by the applicable laws and regulations;
   4 and
   2) Internal governance documents which, if provided to the supervisory authority, may be cross￾referenced in qualitative reporting.
   With regard to the annual compliance report mentioned in Section 1 of Annexes 1 and 2, the supervisory authority will allow this report to cross-reference the AMLCO’s report insofar as the AML chapter is concerned.
   2. Use in qualitative reporting of cross-references to internal documents
   In order to reduce the administrative burden on credit institutions and stockbroking firms, the supervisory authority allows cross-references to the institution’s internal documents, provided the following three conditions are met:
   1. Only those internal documents/policies listed in Section 2 of Annexes 1 and 2 to this communication
   may be cross-referenced, insofar as they have effectively been communicated in advance to the supervisory authority (NBB/ECB). 5
   2. Cross-references must be precise/targeted, i.e. they must refer to a specific provision, paragraph or
   (sub)section of the internal policy concerned.
   1 Act of 25 April 2014 on the legal status and supervision of credit institutions and the Act of 20 July 2022 on the legal status and supervision of stockbroking firms. 2 Act of 18 September 2017 on the prevention of money laundering and terrorist financing and on restriction of the use of cash. 3 With regard to consolidated reporting and reporting by financial holding companies and mixed financial holding companies, reference is made to Communication NBB_2022_30 of 22 November 2022 (Communication NBB_2022_30 / Reporting expected from (mixed) financial holding companies governed by Belgian law following the modification of their supervisory regime in the Banking Law | National Bank of Belgium). The use of cross￾references in qualitative reporting by financial holding companies and mixed financial holding companies is also permitted, provided the conditions set out in point 2 of the present communication are met. In this regard, the list of qualifying internal policies is mutatis mutandis identical to that applicable to credit institutions (Annex 1). Furthermore, with regard to reporting by the accredited statutory auditors of credit institutions and stockbroking firms, reference is made to Circular NBB_2024_12 of 16 July 2024 (Circular NBB_2024_12 / Accreditation of auditors and audit firms and duty of cooperation of accredited statutory auditors | National Bank of Belgium). 4 This is a list of the minimum reports to be submitted to the supervisory authority and does not preclude the imposition of additional reporting requirements on an ad hoc basis. 5 References to other internal documents/policies are not permitted given that these documents (i) may not be stable and (ii) may not be in the possession of the supervisory authority (NBB/ECB).

NBB_2025_19 – 25 November 2025 Communication – Page3 /3
3. Qualitative reporting must be self-supporting (minimum editorial content to enable readers to
understand the topics discussed without consulting the referenced documents) 6 : the institution shall take the necessary care to ensure that the information it reports to the supervisory authority is clear, complete and precise, so that the reader can understand the intricacies of the points raised without having to refer to the referenced documents. Institutions that would like to use cross-references must moreover ensure that the internal policies they submit to the supervisory authority via NBB Supervision are always the latest version and have been internally validated.
3. Transmission channels
The qualitative reporting covered by this communication and, where applicable, the internal policies to be cross-referenced are to be submitted via the usual transmission channels, i.e. NBB Supervision or OneGate. For more information on NBB Supervision (https://supervision.nbb.be), please see the Supervision FAQ (FAQ - Supervision portal | National Bank of Belgium), in particular the section entitled “How can I invite a new user to the Supervision portal?”.7 For more information on OneGate, please see the FAQ on the NBB’s website (OneGate FAQ | National Bank of Belgium). For technical questions or problems relating to these platforms, please contact helpdesk.supervision@nbb.be (for NBB Supervision) or access.onegate@nbb.be (for OneGate). Yours faithfully, Pierre Wunsch Governor Annexes
Annex 1 – Qualitative reporting by credit institutions
Annex 2 – Qualitative reporting by stockbroking firms
6 The aim is to ensure that qualitative reports do not become a list of cross-references. 7 Reference is also made to Communication NBB_2022_14 of 28 June 2022.