NBB Circular NBB_2026_09: Implementing EBA Guidelines on Criteria for Identifying Ancillary Services Undertakings under Regulation (EU) No 575/2013

Public NBB_2026_09 – 16 June 2026 Circular – Page 1/2 boulevard de Berlaimont 14 – 1000 Brussels tel. +32 2 221 38 12 company number: 0203.201.340 RPM Brussels www.bnb.be

Circular
Public
Brussels, 16 June 2026
Reference: NBB_2026_09 your contact:
Nicolas Staner tel. +32 2 221 44 69 nicolas.staner@nbb.be

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

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

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

Madam,
Sir,

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

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

Concretely, these are fundamental activities, closely integrated into the value chain of basic banking services, such as credit management, assessment of the solvency of individual clients, valuation of collateral, intermediation and distribution of loans through innovative channels, debt collection, etc. when these activities are mainly provided to credit institutions or financial establishments; b) the activities to be considered as ancillary to banking services. To this end, the EBA guidelines establish a criterion to assess whether the activities are sufficiently linked to the banking sector to be considered ancillary, depending on whether they support, complement or depend on it. This criterion is based both on the nature of the activities, such as operational support, risk management support,

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

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

Madam,
Sir,

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

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

Concretely, these are fundamental activities, closely integrated into the value chain of basic banking services, such as credit management, assessment of the solvency of individual clients, valuation of collateral, intermediation and distribution of loans through innovative channels,

National Bank
OF BELGIUM
Eurosystem
National Bank
OF BELGIUM
Eurosystem

Public NBB_2026_09 – 16 June 2026 Circular – Page 2/2 innovative channels, debt collection, etc. when these activities are mainly provided to credit institutions or financial establishments; b) the activities to be considered as ancillary to banking services. To this end, the EBA guidelines establish a criterion to assess whether the activities are sufficiently linked to the banking sector to be considered ancillary, depending on whether they support, complement or depend on it. This criterion is based both on the nature of the activities, such as operational support, risk management support, back-office and administrative support, etc., and the existence of a clear link with the banking sector. It is for this reason that an entity carrying out such activities will only be qualified as an ASU if this entity is part of a banking group. c) the guidelines further specify the procedure to be followed to determine the activities that should be considered as similar to those constituting a direct extension of banking activities or ancillary to banking services. The new definition of ASU also aims to capture new business models or hybrid activities that, without being explicitly mentioned in the EBA guidelines, might pose analogous risks or dependencies.

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

The guidelines entered into application on 4 May 2026.

They can be consulted on the NBB website.

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

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

Pierre Wunsch
Governor

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