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Belgium

Belgium regulates crypto under MiCA through the Law of 11 December 2025, which splits competence between the FSMA (CASP authorisation and conduct, non-stablecoin issuers, market abuse) and the National Bank of Belgium (prudential supervision and ART/EMT issuers); Belgium took the full 18-month grandfathering, which expired on 1 July 2026, and had no domestic pre-MiCA VASP registrations. Payments and e-money run under the Act of 11 March 2018, supervised prudentially by the NBB with conduct rules enforced by the FPS Economy, alongside the Instant Payments Regulation (fully applicable since 9 October 2025) and DORA (since 17 January 2025); PSD3/PSR is heading toward adoption in 2026. Gambling is a closed (numerus clausus) federal system under the Gaming Act of 7 May 1999, supervised by the Belgian Gaming Commission, where an online licence (A+, B+, F1+) requires the matching land-based licence and a Belgian connection — the minimum age is 21 since September 2024 and the National Lottery is a separate state monopoly.

Available licences

Crypto-Asset Service Provider authorisation (FSMA / NBB under MiCAR and the Law of 11 December 2025)

Custody, operation of a trading platform, exchange of crypto-assets for funds or other crypto-assets, execution, placing, reception and transmission of orders, advice, portfolio management and transfer services require authorisation under Article 63 MiCAR. The FSMA is the competent authority for CASPs that are not credit institutions or stockbroking firms (most pure-play exchanges and custodians); the NBB supervises CASPs already within its prudential remit, while the FSMA centralises conduct-of-business supervision for all CASPs. The FSMA's official lists of Belgian Art. 63 authorised and Art. 60 notified CASPs are live registers — check them before launch.

Asset-Referenced Token (ART) issuer authorisation (NBB / FSMA)

Public offering or admission to trading of a token referencing a basket of values, rights or currencies requires authorisation as an ART issuer under Title III MiCAR. The NBB handles prudential authorisation, capital and reserve requirements; the FSMA supervises white-paper, marketing and conduct rules.

E-Money Token (EMT) issuer (credit institution or EMI; NBB / FPS Economy)

EMTs may be issued only by an authorised credit institution or e-money institution, with redemption at par. The NBB handles prudential supervision under the EMD II framework; the FPS Economy enforces redeemability rules and the prohibition on granting interest to EMT holders.

Article 60 MiCAR notification route (existing financial institutions)

Credit institutions, investment firms, e-money institutions, payment institutions, UCITS management companies, AIFMs, CSDs and market operators already authorised under EU law may provide specified crypto-asset services by notifying the FSMA (amc@fsma.be) for the services their existing licence covers; portfolio-management, investment-advice, UCITS and AIF managers may use the route only for equivalent services and may not hold client crypto-assets under it.

Payment Institution authorisation (NBB under the Act of 11 March 2018)

A licence to provide payment services under the Act of 11 March 2018, prudentially supervised by the NBB; payment-services conduct rules (transposing PSD2 Titles III–IV) are enforced by the FPS Economy. Payment institutions may not take deposits or issue e-money.

E-Money Institution authorisation (NBB under the Act of 11 March 2018)

A licence to issue electronic money and provide related payment services, with EUR 350,000 minimum initial capital and safeguarding of client funds, supervised prudentially by the NBB.

Limited (light) payment or e-money institution (NBB)

Belgium has taken up the PSD2 option for a lighter national regime for limited payment institutions and limited e-money institutions below set volume thresholds; this status carries reduced requirements but does not enable EEA passporting.

Account Information and Payment Initiation Services (NBB / FPS Economy)

Open-banking providers — account information service providers and payment initiation service providers — fall within the Act of 11 March 2018, with NBB prudential oversight, FPS Economy conduct enforcement and strong customer authentication under PSD2.

Banking authorisation (NBB / ECB SSM under the Law of 25 April 2014)

Deposit-taking and lending require a banking licence under the Banking Law (Law of 25 April 2014). The NBB is the national supervisor and prepares the file; the ECB takes the final decision for significant institutions within the SSM.

Stockbroking firm / investment firm authorisation (NBB / FSMA — MiFID II)

Investment services in financial instruments require authorisation under the Law of 20 July 2022 on stockbroking firms (and related MiFID II framework), with the NBB as prudential supervisor and the FSMA supervising conduct of business.

Casino and online-casino licences (A / A+) (Gaming Commission under the Gaming Act 1999)

Class I gaming establishments (casinos) hold an A licence; an A+ supplementary licence permits the same operator to offer casino games online. The number of casino licences is capped (numerus clausus), and an A+ can be granted only to an A holder with a mandatory connection to Belgian territory.

Gaming-arcade, betting and supplier licences (B/B+, C, F1/F1+/F1P/F2, E)

Class II gaming arcades hold a B licence (B+ online); class III drinking establishments hold a C licence; betting is organised under an F1 licence (F1+ online, F1P for horse racing) and accepted on an F1 holder's behalf under an F2 licence; B2B suppliers of games of chance and online-gambling software hold an E licence, which cannot be combined with an operator licence.

National Lottery monopoly (Loterie Nationale / Nationale Loterij)

Public lotteries and certain games are operated as a state monopoly by the National Lottery under the National Lottery Act of 19 April 2002, separately from the Gaming Commission licensing system.

Detailed overview

Belgium at a glance

Belgium applies MiCAR through a twin-peaks split between the FSMA and the NBB, runs payments and e-money under a single 2018 act with prudential supervision by the NBB and conduct enforcement by the FPS Economy, and operates a closed, land-based-tethered gambling system under the Belgian Gaming Commission. The crypto framework only crystallised with the Law of 11 December 2025; the transitional regime applied to providers lawfully operating under another Member State's law and expired on 1 July 2026, and Belgium never had a pool of domestic registered VASPs to grandfather. Payments run under the Act of 11 March 2018 with the Instant Payments Regulation and DORA in force and PSD3/PSR approaching adoption. Gambling is built around a numerus clausus of land-based licences, with online play available only as a supplement to a matching land-based licence, a minimum age of 21 and a strict advertising regime, while the National Lottery sits apart as a state monopoly.

Crypto regime under MiCA — twin-peaks, FSMA/NBB-split, post-transition:

  • MiCA + national implementing law — Regulation (EU) 2023/1114 (MiCAR); the Law of 11 December 2025 implementing MiCAR and Regulation (EU) 2023/1113, adopted by Parliament on 4 December 2025 and in force from early January 2026
  • Competent authorities — the FSMA for CASPs that are not credit institutions or stockbroking firms, for issuers of crypto-assets other than ARTs/EMTs, for market abuse and for conduct of business across all CASPs; the NBB for prudential supervision of ART and EMT issuers and of CASPs already within its remit; the FPS Economy for EMT redeemability and the interest prohibition
  • Grandfathering — closed. Belgium took the full 18-month transitional period; CASPs lawfully providing services under another Member State's national law, and already active in Belgium without establishment on 30 December 2024, could continue only until 1 July 2026 (or until authorisation was granted or refused). That EU-wide backstop has now expired, and Belgium had no domestic pre-MiCA VASP registrations because the FSMA granted none under the former Royal Decree of 8 February 2022
  • Article 60 notifications — credit institutions, investment firms, e-money and payment institutions, UCITS managers, AIFMs, CSDs and market operators may notify the FSMA to provide crypto-asset services within their existing authorisation
  • AML/CFT — the Law of 11 December 2025 amended the Anti-Money Laundering Act of 18 September 2017, replacing "virtual currency" with MiCA terminology and treating CASPs as full obliged entities, with specific risk-mitigation measures for transfers to or from self-hosted wallets; the EU AML package (Regulation (EU) 2024/1624 / AMLR, with AMLA in Frankfurt) applies from 10 July 2027; the Belgian FIU is the CTIF-CFI
  • TFR — Regulation (EU) 2023/1113 (recast Transfer of Funds Regulation) applies the Travel Rule to crypto-asset transfers from 30 December 2024 and is implemented by the Law of 11 December 2025
  • Marketing — Belgium maintained a national FSMA advertising regime for virtual currencies (from 2023); MiCA now governs advertising within its scope, while marketing that falls outside MiCA (for example by influencers or for crypto-assets with no identifiable issuer) remains subject to the FSMA's national rules
  • Enforcement — the FSMA and NBB hold extensive remedial and sanctioning powers, and a Belgian court may declare a purchase void where the provider lacked authorisation or an approved white paper

Payments and e-money regime (NBB prudential, FPS Economy conduct):

  • PSD2 — Directive (EU) 2015/2366; transposed by the Act of 11 March 2018 on the status and supervision of payment and e-money institutions, with the NBB as prudential national competent authority and the FPS Economy enforcing conduct-of-business rules
  • Payment Institution licensing — initial capital EUR 20,000 (money remittance), EUR 50,000 (payment initiation) and EUR 125,000 (other payment services)
  • EMD2 / E-Money Institution — Directive 2009/110/EC; EUR 350,000 initial capital
  • Limited institutions — a national light regime for limited payment institutions (below EUR 1 million average monthly volume) and limited e-money institutions (below EUR 1.5 million average outstanding e-money), without EEA passporting
  • Instant Payments Regulation (Regulation (EU) 2024/886) — euro instant payments: receiving applicable from 9 January 2025 and sending from 9 October 2025
  • DORA (Regulation (EU) 2022/2554) — applicable from 17 January 2025
  • PSD3 / PSR — Commission proposals of 28 June 2023; provisional political agreement reached 27 November 2025, with final compromise texts published 23 April 2026 and formal adoption expected during 2026; the package will repeal PSD2 and EMD2 and fold e-money institutions into payment institutions, with PSD3 transposed nationally and the PSR directly applicable after a phased timeline
  • Banking infrastructure — the NBB supervises banks (with the ECB under the SSM for significant institutions); Belgium participates in the euro-area SEPA and TARGET infrastructure
  • Currency: euro (EUR); no exchange controls

Gambling regime — closed federal system under the Gaming Act 1999:

  • Gaming Act of 7 May 1999 (games of chance, betting, gaming establishments and protection of players) — the federal framework, regulated and supervised by the Belgian Gaming Commission, which advises, licenses, inspects and sanctions
  • Licence classes — A (casinos), B (gaming arcades), C (drinking establishments), D (employees), E (B2B suppliers), F1 (organisers of betting), F1P (horse-race betting), F2 (accepting bets on an F1 holder's behalf), with supplementary online licences A+, B+ and F1+
  • Online tethering — an online licence (A+, B+, F1+) can be granted only to a holder of the corresponding land-based licence, with a mandatory connection to Belgian territory; combining different online licence classes on the same domain is prohibited
  • Player protection — minimum age 21 for all games of chance (Law of 18 February 2024, in force 1 September 2024); mandatory EPIS (Excluded Persons Information System) checks before play; a default weekly online deposit cap; and heavily restricted advertising under the gambling-advertising regime in force from 1 July 2023, with a phased ban on sports sponsorship
  • National Lottery — public lotteries operated as a state monopoly by the National Lottery under the Act of 19 April 2002, outside the Gaming Commission licensing system
  • Tax — taxes on games of chance and bets are a regional competence (Flemish Region, Walloon Region and Brussels-Capital Region), with rates set by region and game type; player winnings are in principle not taxable
  • AML/CFT — gambling operators are obliged entities, with identification, monitoring and suspicious-transaction reporting to the CTIF-CFI

Last verified: July 2026. Reference rate: USD 1 = EUR 0.87 (EUR 1 = USD 1.15). The euro floats freely and there are no exchange controls.

Belgium is a twin-peaks EU venue: crypto runs under MiCAR and the Law of 11 December 2025 with the FSMA and NBB sharing supervision, payments sit under the Act of 11 March 2018 with the NBB prudential and the FPS Economy on conduct, and gambling is a closed federal system under the Gaming Act 1999 where online play (A+/B+/F1+) is reserved to holders of a matching land-based licence — with the National Lottery a separate state monopoly.

Is there a crypto licence in Belgium?

Yes. Belgium applies MiCAR, and since the Law of 11 December 2025 the FSMA and NBB share authorisation and supervision of crypto-asset activities. The full 18-month transitional window expired on 1 July 2026, so operating now requires a CASP authorisation, a valid MiCA passport, or an Article 60 notification.

The legal foundation:

  • Regulation (EU) 2023/1114 (MiCAR) — the directly applicable EU framework for offerings, admission and crypto-asset services
  • Law of 11 December 2025 — designates the FSMA and NBB, allocates competences, amends the AML Act, and provides the sanctions regime
  • AML Act of 18 September 2017 — AML/CFT obligations, amended to align with MiCA terminology and to bring CASPs fully into scope
  • Regulation (EU) 2023/1113 — Travel Rule for crypto-asset transfers

Structure:

  • A legal entity with substance in Belgium; criminal exposure attaches to providing CASP services without the required authorisation or Article 60 conditions
  • MiCAR own-funds floors by class — EUR 50,000 (Class 1), EUR 125,000 (Class 2), EUR 150,000 (Class 3) — with the prudential requirement set as the higher of the own-funds floor or a fixed-overheads measure
  • Fit-and-proper management and qualifying shareholders, AML officers, a white paper for in-scope offerings, custody, conflicts, complaints and market-abuse arrangements, and identity-verification measures for self-hosted-wallet transfers

Operational reality:

  • The FSMA is a sophisticated regulator; applications should be run as full regulatory authorisation projects, with correct service classification and an early read on whether the FSMA or the NBB is the prudential supervisor
  • The main execution risks are mis-classifying services, assuming Article 60 applies where the service is not equivalent, underestimating the FSMA/NBB split, relying on transition without evidence, and launching consumer marketing without a Belgian advertising review
  • New Belgium-facing activity should be structured through a MiCA authorisation, a valid passport or an Article 60 notification — not local grandfathering, which has closed

Official CASP roadmap: The FSMA does not publish a separate step-by-step roadmap, but its official CASP page sets out the route — determine whether you need an Article 63 authorisation or qualify for an Article 60 notification, confirm whether the FSMA or the NBB is your prudential supervisor, then submit the Article 63 file to casp@fsma.be (or an Article 60 notification to amc@fsma.be), and check the FSMA's live register before launch. See the FSMA Crypto-Asset Service Provider page and list of authorised Belgian CASPs.

Payments & E-money (NBB / FPS Economy — PSD2 / EMD2)

Best for payment, remittance, acquiring, wallet and open-banking operators that want an EU base with prudential supervision by the National Bank of Belgium.

What it is: Authorisation as a payment institution or e-money institution under the Act of 11 March 2018, with the NBB as prudential supervisor and the FPS Economy enforcing conduct rules, passportable across the EEA.

Who it suits: Money-remittance and transfer providers, acquirers, card and wallet issuers, payment-initiation and account-information providers, and e-money issuers seeking an EU foothold; smaller entrants may use the limited (light) regime.

Covers: The payment services under the Act of 11 March 2018 — incoming and outgoing transactions, transfers, card and instrument-based payments, money remittance, payment initiation and account information — plus issuance of electronic money.

Operational requirement: A Belgian entity; minimum initial capital by service type; ongoing own-funds and safeguarding of client funds; strong customer authentication; AML/CFT; DORA operational-resilience obligations; and fit-and-proper management, with the NBB encouraging informal pre-application contact.

Headline figures

  • Primary instruments: Act of 11 March 2018 (PSD2 / EMD2); Instant Payments Regulation (EU) 2024/886; DORA (Regulation (EU) 2022/2554)
  • Regulators: NBB (prudential authorisation and supervision); FPS Economy (conduct-of-business rules); ECB (SSM, for significant banks)
  • Entry capital: payment institutions EUR 20,000 / 50,000 / 125,000 by service type; e-money institutions EUR 350,000
  • Light regime: limited PI below EUR 1 million average monthly volume; limited EMI below EUR 1.5 million average outstanding e-money; no EEA passport
  • Instant payments: euro instant payments — receiving from 9 January 2025, sending from 9 October 2025
  • Reform pipeline: PSD3 / PSR — political agreement November 2025, compromise texts April 2026, adoption expected during 2026; EMD2 to be repealed and EMIs folded into payment institutions
  • Currency: EUR; no exchange controls

Is there a gambling licence in Belgium?

Yes, but within a closed system. Land-based gambling is licensed by the Belgian Gaming Commission under the Gaming Act 1999, and online play is available only as a supplement (A+, B+, F1+) to a matching land-based licence — there is no stand-alone online licence. The National Lottery is a separate state monopoly.

The legal foundation:

  • Gaming Act of 7 May 1999 — the federal framework for games of chance, betting and player protection, with a numerus clausus of licences
  • Belgian Gaming Commission — the sole licensing authority; advises, licenses, supervises and sanctions, and publishes the registers of licensed websites and the blacklist of unlicensed URLs
  • National Lottery Act of 19 April 2002 — the state-monopoly basis for the National Lottery
  • Regional tax legislation — taxes on games of chance and bets, set by the Regions

Structure:

  • Land-based classes A (casinos), B (arcades), C (drinking establishments), D (employees), E (suppliers), and F1/F1P/F2 (betting); online supplements A+, B+ and F1+
  • An online licence requires the matching land-based licence and a Belgian connection; only EU/EEA nationals and entities may apply for the principal licences
  • All operators are AML obliged entities, with player identification, EPIS exclusion checks and suspicious-transaction reporting to the CTIF-CFI

Gambling — Online licence (A+ / B+ / F1+) (Gaming Commission)

Best for established land-based casino, arcade or betting operators extending online; not for stand-alone online B2Cs or offshore operators targeting Belgian players.

What it is: A supplementary online licence (A+ casino, B+ arcade, F1+ betting) attached to a land-based A, B or F1 licence, granted and supervised by the Belgian Gaming Commission.

Who it suits: Holders of a Belgian land-based licence wanting to offer the same games online to Belgian players, under the closed-system rules.

Covers: Online casino games (A+), online gaming-arcade games (B+) or online betting (F1+), in each case mirroring the land-based licence; combining different online classes on one domain is prohibited.

Operational requirement: A matching land-based licence, a mandatory connection to Belgian territory, age and EPIS verification before play, responsible-gambling and deposit-limit compliance, AML/CFT, and a permanent data link to the Gaming Commission.

Headline figures

  • Primary instruments: Gaming Act of 7 May 1999 and implementing Royal Decrees; National Lottery Act of 19 April 2002; regional gaming-tax legislation
  • Regulators: Belgian Gaming Commission (licensing and supervision); the Regions (gaming taxes); CTIF-CFI (AML)
  • Costs: no application fees; guarantee deposits to the Deposits and Consignments Fund (EUR 250,000 A/A+; EUR 75,000 B/B+/F1+; EUR 10,000 F1); annual contribution set yearly by Royal Decree
  • Tax/duty: levied at regional level by game type; player winnings in principle not taxable
  • Player protection: minimum age 21 (since 1 September 2024); EPIS checks; default weekly online deposit cap; strict advertising regime in force from 1 July 2023
  • Online: supplementary only — reserved to holders of a matching land-based licence

Costs and timelines at a glance

  • Crypto: MiCAR via the Law of 11 December 2025, FSMA/NBB split; own-funds floors EUR 50,000 / 125,000 / 150,000 by class; Article 63 timeline of a 25-working-day completeness check plus a 40-working-day decision; transitional regime closed 1 July 2026
  • Payments primary instruments: Act of 11 March 2018 (PSD2 / EMD2); Instant Payments Regulation (EU) 2024/886; DORA
  • Payments regulators: NBB (prudential); FPS Economy (conduct); ECB (SSM, banks)
  • Banking entry: authorisation under the Banking Law (Law of 25 April 2014) with substantial initial capital; NBB prepares the file and the ECB decides for significant institutions
  • Reform pipeline: PSD3 / PSR — agreement November 2025, compromise texts April 2026, adoption expected during 2026
  • Gambling: closed federal system under the Gaming Act 1999; online (A+/B+/F1+) reserved to land-based licence holders; guarantee deposits of EUR 250,000 / 75,000 / 10,000; regional gaming taxes; minimum age 21
  • Currency: EUR; no exchange controls
  • FX: USD 1 = EUR 0.87 (EUR 1 = USD 1.15)

Who Belgium suits and who it does not

Suitable for

  • Crypto exchanges, custodians and token issuers wanting a MiCAR CASP authorisation from a sophisticated regulator in an established EU financial centre, with EEA passporting
  • Already-licensed banks, investment firms, payment and e-money institutions that can add crypto-asset services through the Article 60 notification route
  • Payment, remittance, acquiring, wallet and open-banking operators seeking an EU base under NBB prudential supervision, with instant-payments readiness
  • Smaller payment or e-money entrants that fit the limited (light) institution regime and do not need an EEA passport
  • Established land-based casino, arcade or betting operators wanting to extend online within the closed Belgian system

Not suitable for

  • Firms seeking informal registration or a low-substance route — Belgium applies MiCAR in full, with FSMA/NBB supervision and criminal exposure for unlicensed activity
  • Providers relying on a former VASP registration — Belgium never registered domestic VASPs, and the cross-border transitional window closed on 1 July 2026
  • Payment or e-money firms expecting to avoid EU prudential, safeguarding, DORA or AML obligations
  • Stand-alone online-casino or online-betting operators without a Belgian land-based licence — online play is reserved to holders of a matching land-based licence
  • Operators expecting light-touch gambling marketing — advertising is heavily restricted and the minimum age is 21

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