Framework of permitted services for depositary banks

Public NBB_2026_10 – 8 June 2026 Communication – Page 1/3 boulevard de Berlaimont 14 – 1000 Bruxelles tél. +32 2 221 23 88 numéro d’entreprise: 0203.201.340 RPM Bruxelles www.bnb.be Communication Public Brussels, 8 June 2026 Référence: NBB_2026_10 votre correspondant:
Ingmar Vansieleghem tél. +32 2 221 26 06 – GSM +32 473 82 69 65 ingmar.vansieleghem@nbb.be The framework of permitted services for depositary banks Champ d’application

• Custodian banks pursuant Art. 36/26/1 § 6 of the Organic Law (Act of 22 February 1998 establishing
  the organic statute of the National Bank of Belgium).
  Résumé/Objectifs
  The purpose of this publication is to explain the permitted activities of depositary banks and certain aspects of the conditions for carrying them out. Dear Sir Madam, The Act of 31 July 2017 introduced a new category of institutions known as “custodian banks”. Authorisation to operate as a custodian bank may only be granted to credit institutions established in Belgium whose activity consists exclusively of providing custody, account maintenance and settlement services for securities, as well as related non-banking-type services (i), in addition to the activities referred to in Article 1, § 3, paragraph 1, of the Act of 25 April 2014 on the legal status and supervision of credit institutions and stockbroking firms – namely, receiving deposits or other repayable funds from the public and granting credit on their own account – where these activities are ancillary or related to the aforementioned services (ii). Finally, it may be justified in certain cases to authorise custodian banks to carry out activities other than those they perform as custodian banks, without this calling into question their additional status (iii). The purpose of this communication is to clarify the scope of the activities concerned and certain aspects of the conditions, making them permissible within that scope.

Public NBB_2026_10 – 8 June 2026 Communication – Page 2/3 (i) With regard to the concept of non-banking-type services relating to the custody, account maintenance and settlement of securities, these services may include, but are not limited to:

1. services related to the settlement service, such as:
   a) the organisation, as an agent, of a securities lending mechanism; b) the provision, as an agent, of collateral management services; c) settlement matching, instruction routing, trade confirmation and trade verification;
2. services related to securities accounts maintenance, such as:
   a) services related to registers of nominative shares; b) services related to the processing of corporate actions, including tax, general meetings and information services; c) instruction routing and processing, fee collection and processing and related reporting;
3. any other service relating to the custody, account maintenance or settlement of securities, such as:
   a) the provision, as an agent, of general collateral management services; b) the preparation of regulatory reporting; c) the provision of IT services; (ii) With regard to the activities referred to in Article 1, § 3, paragraph 1 of the Act of 25 April 2014, namely receiving deposits or other repayable funds from the public and granting credit on their own account, where these activities are ancillary or related to the aforementioned services, these activities consist in particular of:
4. providing cash accounts to, and accepting deposits from, holders of securities accounts
5. providing short-term cash credit, cash lending to pre-finance corporate actions and lending securities
   to holders of securities accounts;
6. payment services involving the processing of cash and foreign exchange transactions;
7. guarantees and commitments related to securities lending;
8. treasury activities related to the management of account holders’ credit balances;
   (iii) As for other activities that may be authorised by the NBB on an individual basis, they may be subject to specific conditions imposed by the Bank with a view to ensuring sound and prudent management and adequate risk control. In any event, these activities must meet the following criteria:
9. fall within the scope or direct extension of the services provided as a custodian bank, or be ancillary
   to or an extension thereof;
10. have a similar profile in terms of target clients, objective and risk;

Public NBB_2026_10 – 8 June 2026 Communication – Page 3/3
3) for business activities that do not meet the above criteria, these must be marginal and subject to risk
capping and robust and irrevocable mechanisms for transferring risks outside the custodian bank. This implies, among other things, that the institution must be able to demonstrate that its three lines of defense and its governance bodies have the necessary expertise and all systems and tools required to identify, measure, report and control the inherent and residual risks associated with these activities and their risk transfer mechanism. The activities described above refer to the nature of the services provided, regardless of the technology underlying the service provision and/or the assets to which these services apply. Pierre Wunsch Gouvernor