Safeguarding requirements for Belgian payment institutions and electronic money institutions

Last year, the National Bank of Belgium (NBB) released a Circular (available in French here and in Dutch here – the Circular) in which it clarified certain safeguarding requirements for payment institutions (PIs) and e-money institutions (EMIs).

Both institutions are expected to comply with these requirements since the beginning of 2023 (more precisely, the NBB gave them until Saturday 31 December 2022).

The NBB Circular covers three topics related to safeguarding:

1. the obligation for the institution to safeguard the funds, including when it has outsourced the payout of the funds to another payment service provider (PSP) in the payment chain;
2. certain clarifications in connection with the main safeguarding methods; and
3. other expectations when reporting to the NBB on the safeguarding measures that have been taken.

We address each topic in turn, including relevant Q&As from the European Banking Authority (EBA) on the same topics.

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