Fintech 2025

BELGIUM Trends and Developments Contributed by: Tom Van Dyck and Louise Verstraete, Liedekerke Wolters Waelbroeck Kirkpatrick

and fraud mitigation. In the interim, many Bel - gian fintechs have continued to leverage PSD2’s open banking rules to create innovative solu - tions, though they closely monitor the upcoming changes that PSD3/PSR will bring. Practical implications for market players Concerning open banking collaborations, Bel - gian traditional banks have increasingly part - nered with fintechs to offer consumers integrat - ed digital payment and banking solutions. KBC’s “Kate Coin” project, launched in 2022, exem - plifies how incumbent banks attempt to blend in-house digital tokens with advanced payment functionalities. Concerning compliance preparations, Belgian- based payment service providers are currently reviewing whether PSD3’s proposals might require updates to their licensing status, opera - tional flows or user authentication protocols. Outsourcing and Fintech in Belgium Outsourcing critical and non-critical functions to fintech companies is increasingly common among Belgian financial institutions. This allows incumbents to leverage new technologies rap - idly while focusing on core business operations. Regulatory framework Belgium’s outsourcing rules are set out in EU guidelines from the European Banking Authority (EBA) and the European Insurance and Occupa - tional Pensions Authority (EIOPA), and by spe - cific circulars of the Belgian supervisory authori - ties. These require: • due diligence on the fintech provider’s IT security, risk management and financial soundness;

• clear contracts addressing scope, service levels, audit rights, data protection and exit strategies; and • ongoing oversight, ensuring the institution retains control over outsourced activities and can monitor performance continuously. Practical takeaways Institutions outsourcing to fintech companies must watch for: • critical or important functions requiring notifi - cation or prior approval; • cloud-based solutions and data localisation/ security issues; and • chain outsourcing, which might complicate governance and create systemic risks. DORA Implementation in Belgium Overview of DORA Regulation (EU) 2022/2554 on digital operational resilience (DORA) aims to ensure financial enti - ties can withstand and recover from information and communication technology (ICT) disrup - tions. The regulation applies broadly to banks, payment institutions, CASPs and insurance firms, with full obligations kicking in from Janu - ary 2025. Belgian adaptation The NBB and FSMA have issued clear guid - ance on the implementation of DORA – such as, in particular, the dedicated webpages and frequently asked questions (FAQs) published by the FSMA. AML/KYC Developments in the Fintech Context EU AML legislation overhaul The EU’s AML framework is undergoing a broad reform, including a new AML Regulation, the 6th AML Directive (AMLD6) and the establishment of

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