BELGIUM Trends and Developments Contributed by: Christophe Romero and Senne Verholle, Aeacus Lawyers
MiCA implementation in Belgium: from EU framework to local enforcement A harmonised framework and licensing requirements The application of the Markets in Crypto-Assets Reg- ulation (MiCA) marks a fundamental shift in the regu- lation of crypto-asset activities across the European Union. For the first time, a harmonised framework governs the provision of services relating to crypto- assets, replacing fragmented national approaches. In Belgium, this framework is complemented by national legislation designating the Financial Services and Markets Authority (FSMA) and, depending on the activity, the National Bank of Belgium (NBB) as com- petent authorities. From a client perspective, the most immediate impact lies in the introduction of a licensing requirement for crypto-asset service providers (CASPs). Entities offer- ing services such as the following must obtain authori- sation to operate within the EU:
Belgium’s Blockchain Landscape in 2026: Convergence of Regulation, Taxation and Transparency Introduction: a turning point for blockchain in Belgium The Belgian blockchain landscape is entering a deci- sive phase in 2026. After years of legal uncertainty and fragmented guidance, a more structured regulatory and fiscal framework is emerging at both European and domestic level. While blockchain technology encompasses a broad range of applications beyond financial use cases, the Belgian landscape is currently driven predominant- ly by developments relating to crypto-assets. This chapter of the guide therefore approaches blockchain through the lens of crypto-assets, which represent the primary area of legal, tax and compliance relevance for clients in Belgium. Three developments are particularly significant: • the application of the EU Markets in Crypto-Assets Regulation (MiCA), introducing a harmonised regu- latory framework for crypto-asset service provid- ers; • the adoption of a new Belgian tax regime for finan- cial assets, explicitly including crypto-assets; and • the implementation of international reporting obli- gations under DAC8 and the OECD’s Crypto-Asset Reporting Framework (CARF), increasing transpar- ency. Taken together, these developments mark a transition towards a more formalised and data-driven environ- ment. However, this should not be understood as a move towards full legal certainty. Important areas of ambiguity remain, particularly where traditional legal and tax concepts are applied to evolving crypto-relat- ed activities. 2026 should therefore be understood as a turning point: the Belgian blockchain landscape is becoming more structured, but also more demanding.
• custody of crypto-assets; • exchange services; and • execution or transfer of crypto-assets.
A transitional regime applies to existing providers, allowing them to continue operating for a limited period while applying for authorisation. While this ensures continuity, it also creates uncertainty as it remains unclear which providers will ultimately obtain a licence. Regulatory complexity and banking constraints ( AML ) While MiCA introduces a dedicated framework for crypto-assets, it does not operate in isolation. Anti- money laundering, prudential and conduct of busi- ness rules continue to apply, often resulting in overlap- ping compliance obligations. A particularly relevant issue in Belgium is the persis- tence of banking constraints. Despite regulatory rec- ognition under MiCA, financial institutions continue to adopt a cautious approach. In practice, banks require detailed information on the origin of funds, transac- tion flows and the compliance status of counterpar- ties before accepting crypto-related transfers. This
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