Belgium#
Belgium's MiCA implementing Law of 11 December 2025 (in force 3 January 2026) designates FSMA/NBB as competent authorities. As of FSMA's own mid-2026 statements, no CASP yet holds FSMA authorisation, and six unauthorised firms were added to the fraud list on 6 July 2026.
The most significant development in this module is a correction to Belgium's licensing-continuity narrative. The record previously stated that Belgium applied the maximum 18-month MiCA Article 143(3) grandfathering period, permitting providers already operating under prior Belgian law to continue offering services until 1 July 2026 or until MiCA authorisation was granted or refused, whichever came first. That statement has been corrected: ESMA's own official Article 143(3) list records Belgium's grandfathering status as "TBA," not as an affirmatively elected 18-month window, and FSMA's own crypto-asset-service-provider guidance confirms that zero registrations were ever granted under Belgium's prior national VASP regime -- the Royal Decree of 8 February 2022 -- before that regime's rules expired. With no incumbent Belgian providers registered under the prior regime, there was no cohort of firms for a transitional continuation to apply to; the grandfathering provision was moot in Belgium's case rather than actively used. A related overstatement in ESMA's EU-wide statement on the close of transitional periods -- which had implied a "remaining Belgian grandfathered entities" population -- has been corrected on the same basis, since that population never existed. ESMA has confirmed that the MiCA transitional period ended EU-wide on 1 July 2026, after which unauthorised providers generally are expected to wind down EU client-facing activity in an orderly manner; for Belgium specifically, this expectation applies to any provider operating without MiCA authorisation going forward, not to a residual grandfathered incumbent class.
Separately, Belgium's now-superseded pre-MiCA framework required new market entrants to register with FSMA from 1 May 2022, existing providers to notify FSMA of their activity before 1 July 2022, and existing providers to submit a full registration application before 1 September 2022 -- dates that had previously been misstated (an incorrect 1 June 2022 notification deadline) and have now been corrected against FSMA's own regulatory-framework publication. MiCA also carries a small-offer notification obligation: any public offer of a crypto-asset other than an asset-referenced or e-money token that exceeds EUR 1,000,000 in total consideration over a twelve-month period triggers a notification to the competent authority explaining the claimed small-offer exemption basis.
Outlook
With the EU-wide transitional period now closed and Belgium confirmed to have had no incumbent population under its own prior regime, Belgium's licensing environment has effectively completed its transition to a pure MiCA baseline earlier and more cleanly than initially reported. The corrected finding carries enough materiality that it is currently held pending lawyer review before publication. Future cycles should watch for any second independent primary-source corroboration of FSMA's zero-registrations confirmation, and for enforcement activity against unauthorised providers now that the wind-down expectation is in effect.
Crypto Licensing
Belgium's crypto-asset licensing regime reached a defined structural threshold this period with the close of the Markets in Crypto-Assets Regulation's transitional authorisation window on 1 July 2026. Under that transitional mechanism, a crypto-asset service provider lawfully operating under Belgian national law before 30 December 2024 could continue operating until the earlier of authorisation, refusal, or 1 July 2026. That backstop date has now passed, and the Financial Services and Markets Authority's own confirmed account is that no crypto-asset service provider currently holds an authorisation granted by the FSMA in Belgium. Six firms that had been operating during the transitional window have since been added to the FSMA's public list of unauthorised, potentially fraudulent providers, a warning mechanism rather than a prosecutorial or licence-revocation one, but one with real market consequences for the firms named.
The domestic legal architecture underpinning this regime is set out in the Law of 11 December 2025, which divides crypto-asset supervisory competence along Belgium's established twin-peaks structure. The Financial Services and Markets Authority holds authorisation and conduct-of-business powers over crypto-asset service providers. Prudential supervision of issuers of asset-referenced tokens and e-money tokens, together with prudential oversight of crypto-asset service providers already falling within its existing remit, sits with the National Bank of Belgium. This split was in force from early January 2026, ahead of the transitional window's close, and represents Belgium's domestic implementation of the European Union's directly-applicable Markets in Crypto-Assets Regulation rather than a standalone Belgian framework.
A separate data point complicates the zero-authorisation account without resolving it. The European Securities and Markets Authority's Article 110 file of non-compliant providers held 173 entries at its 30 September 2026 update, of which Belgium's FSMA contributed six, consistent with the FSMA's own fraudulent-list growth. A different vendor register, however, reports two home-authorised Belgian crypto-asset service providers for the same period, a figure inconsistent with the FSMA's zero-authorisation statement. This has not been reconciled against the European Securities and Markets Authority's own register this period, and stands as an open question rather than a resolved one: whether this reflects a timing gap, a definitional difference between what each source counts as an authorisation, or an inaccuracy in one account cannot be determined from what has been gathered.
No enforcement decision equivalent to a formal Article 111 sanction against an unauthorised, Belgium-targeting provider was located this period beyond the public warning-list mechanism; the FSMA's current primary enforcement-adjacent tool visible in this regime is the fraudulent-provider list itself rather than a documented penalty or prosecution record.
Outlook
The clearest near-term resolution available is a direct reconciliation of the FSMA's zero-authorisation statement against the European Securities and Markets Authority's own register, rather than relying on either secondary tracker in isolation; this would settle whether Belgium's domestic authorised population is genuinely empty or whether an authorisation has been granted that is not yet reflected in FSMA's public communications. Separately, continued additions to the FSMA's fraudulent-provider list in the months following the transitional window's close would indicate ongoing enforcement-adjacent activity against firms that operated during the transitional period without having since secured authorisation.
3 earlier distinct update(s)
Crypto Licensing
Belgium's crypto-asset licensing framework runs through the Law of 11 December 2025, which implements MiCAR's Article 63 authorisation requirement into Belgian national law. Under this framework, any entity providing crypto-asset services in Belgium must hold an authorisation granted either by the FSMA or, where applicable, the National Bank of Belgium, unless it is operating under a valid passport from another EEA Member State. This authorisation requirement is now fully in force and is treated as a Confirmed, high-materiality fact within the current evidence base.
Belgium applied the full eighteen-month transitional window permitted under MiCAR's Article 143(3), and that window expired on 1 July 2026. A notable feature of Belgium's transition is that there was no pre-existing domestic VASP registration regime under a Royal Decree, so no prior registrations existed to carry over into the new MiCAR-based authorisation system. This means Belgium's transition to MiCAR did not involve converting an existing population of registered firms into authorised ones; it involved starting the authorised population from zero once the transitional period lapsed.
The practical consequence of that zero starting point became visible almost immediately. As of FSMA's own mid-2026 statements, no crypto-asset service provider holds an authorisation granted by the FSMA. The regulator paired this gap with an active enforcement signal: on 6 July 2026, FSMA added six entities, Aurum Foundation, Bank Bit, Bithf Pro, Dxago, Global Dynamic Trade, and ZeriaFunding, to its fraudulent-CASP list, each for offering crypto-asset services in Belgium without the authorisation the new law now requires. This enforcement action followed the Article 143(3) transitional expiry closely, functioning as a perimeter-control measure: it draws a firm boundary around the newly completed licensing framework at the precise moment the grace period that had tolerated unauthorised activity came to an end.
Supervisory responsibility within this framework is itself split. The FSMA handles CASP authorisation, ongoing conduct supervision, and oversight of non-stablecoin crypto-asset issuance via the white-paper notification route. The National Bank of Belgium, by contrast, supervises the issuance of asset-referenced tokens and e-money tokens under MiCAR's Titles III and IV, as these were carried into Belgian law by the same Law of 11 December 2025. This is a structural allocation of supervisory competence rather than a transitional arrangement, and it now defines how any prospective issuer or service provider in Belgium must navigate the authorisation process depending on the nature of the activity it intends to carry out.
Several practical details of the regime remain to be confirmed against FSMA's own published materials. The exact EUR capital tiers applicable to Belgian CASP authorisation under MiCAR's Article 67 and Annex IV have not yet been confirmed against FSMA's own fee and capital schedule, representing a gap in the currently available evidence rather than an unsettled point of law.
Outlook
The central development to watch is whether the FSMA grants its first domestic CASP authorisation, which would end the current state in which the legal framework is fully operative but the authorised population remains empty. Any further additions to the fraudulent-CASP list would reinforce the pattern already established in July 2026, of active and prompt enforcement against firms operating outside the new perimeter. Confirmation of the exact capital-tier requirements against FSMA's published schedule would also close a current evidentiary gap and give prospective applicants a clearer picture of the practical barriers to authorisation.
Crypto Licensing
Belgium's crypto-asset service provider licensing perimeter closed decisively on 1 July 2026. As of that date, CASPs operating in Belgium are required to hold authorisation under MiCA (Regulation (EU) 2023/1114), and the transitional arrangement previously available to providers operating under the prior national regime has expired. The FSMA has confirmed, on its own domain, that no CASP has been granted a registration under either the pre-MiCA national rules (established by the Royal Decree of 8 February 2022) or under MiCA itself -- meaning Belgium's national crypto-licensing history contains zero granted authorisations across both regimes as of this cycle.
The practical consequence followed within days: on 6 July 2026, the FSMA added six named providers -- Aurum Foundation, Bank Bit, Bithf Pro, Dxago, Global Dynamic Trade, and ZeriaFunding -- to its list of entities designated as operating in Belgium without the required MiCA authorisation. This is the first visible enforcement action taken against the now-closed transitional perimeter, and it establishes that the FSMA is actively monitoring and naming unauthorised operators rather than allowing a grace period to persist informally after the formal deadline.
The structural reading is that Belgium's crypto licensing regime has moved from an unregulated-in-practice transitional period directly into a strictly enforced, zero-tolerance authorisation perimeter, with no cohort of previously-registered incumbents to grandfather through. Every CASP serving Belgian customers as of this cycle is, by the FSMA's own account, unauthorised, which creates a materially elevated compliance and reputational exposure for any provider continuing to operate without having secured MiCA authorisation.
Outlook
The central open question is whether the FSMA will grant its first CASP authorisation following the 1 July 2026 closure, and if so, on what timeline. Until an authorisation is confirmed, Belgium's crypto-asset sector operates under a regime where zero licensed incumbents exist, and further enforcement naming of unauthorised providers should be anticipated as the FSMA continues to police the closed transitional perimeter.
Crypto Licensing
Crypto-asset service providers operating in Belgium must now hold CASP authorisation from the FSMA under Article 63 of the EU Markets in Crypto-Assets Regulation, as implemented domestically by the Belgian Act of 11 December 2025. This confirmed, in-force requirement represents the core licensing gate for the sector as of this cycle, and it applies across the full range of crypto-asset service provider activities contemplated by MiCA. The pre-MiCA 2022 Royal Decree registration regime, which had provided a narrower, transitional path for virtual-asset service providers, is understood to be fully replaced by this MiCA-based authorisation framework, a probable finding corroborated by legal-commentary sourcing describing the transition as complete rather than partial.
The practical effect for market participants is that Belgium's licensing framework has moved decisively from a lighter, AML-oriented registration standard to the full MiCA authorisation regime, with its associated governance, capital, and conduct requirements. This is a structural change to the licensing perimeter rather than an incremental adjustment, and it applies uniformly to new entrants and to firms migrating from the legacy registration regime alike.
Outlook
The exact grandfathering end-date for firms that were registered under the 2022 Royal Decree regime has not been established this cycle, and this remains the single most consequential open question for licensing continuity. Firms currently transitioning from the legacy registration to full MiCA authorisation should expect this to be the primary source of near-term procedural uncertainty, pending further clarification from the FSMA.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (17)
- T1ESMA — Crypto-asset service providers must obtain MiCA authorisation from the FSMA or NBB (depending on entity type under Title V) to lawfully provide crypto-asset services in Belgium. retrieved M5 binding in force
- T1ESMA — Belgium applied the maximum 18-month Article 143(3) MiCA grandfathering period, permitting crypto-asset service providers already operating under prior national law before 30 December 2024 to continue until 1 July 2026 or until granted/refused MiCA authorisation, whichever was sooner. retrieved M4 binding in force
- T1ESMA — ESMA confirmed that the MiCA transitional period ended EU-wide on 1 July 2026, after which unauthorised crypto-asset service providers (including any remaining Belgian grandfathered entities) are expected to wind down EU client-facing activity in an orderly manner. retrieved M4 binding in force
- T3CoinDesk — Prior to MiCA, Belgium operated a national AML-law registration regime for virtual asset/crypto exchange and custodial wallet providers, with new entrants required to register from 1 May 2022 and existing providers required to notify by 1 June 2022. retrieved M2 non-binding
- T1EUR-Lex / Official Journal of the EU — Under MiCA, an offer to the public of a crypto-asset (other than an ART or EMT) exceeding EUR 1,000,000 total consideration over a 12-month period loses the small-offer exemption and requires notification to the competent authority explaining the claimed exemption basis. retrieved M3 binding in force
- T3Belgium (MiCA transitional regime) — Belgium's 18-month MiCA transitional period for pre-existing (VASP-registered or foreign-registered) crypto-asset service providers expired 1 July 2026 M4 binding in force closed
- T3FSMA — FSMA added six named entities (Aurum Foundation, Bank Bit, Bithf Pro, Dxago, Global Dynamic Trade, ZeriaFunding) to its fraudulent-CASP warning list on/around 6 July 2026 M3 binding in force new
- T2FSMA (Belgium) — Six entities (Aurum Foundation, Bank Bit, Bithf Pro, Dxago, Global Dynamic Trade, ZeriaFunding) added to the fraudulent-CASP list on 6 July 2026 for offering crypto-asset services without required MiCAR authorisation retrieved M3 binding in force new
- T3KBC Bank — KBC Bank launched retail Bitcoin/Ether trading via its Bolero platform and submitted a full CASP notification to the Belgian competent authority M3 non-binding in force
- T3Keyrock — Keyrock (Brussels, Belgium), a crypto market-making and liquidity firm, is reported at $1.1bn valuation following a Series C round led by SC Ventures M3 non-binding in force
- T1FSMA MiCA transitional regime — A CASP lawfully operating under Belgian national law before 30 December 2024 could continue until 1 July 2026 or until authorised/refused, whichever came first; the backstop has now expired retrieved M4 binding in force
- T3Belgian Law of 11 December 2025 (MiCA implementation) — Providing crypto-asset services in Belgium requires FSMA CASP authorisation (most service classes) or NBB authorisation (ART/EMT issuance), splitting conduct and prudential competence. retrieved M5 binding in force
- T1Law of 11 December 2025 — CASP authorisation/conduct powers (FSMA) are divided from prudential supervision of ART/EMT issuers and CASPs already within the NBB's remit (NBB) retrieved M5 binding in force
- T3KBC Bank / Bolero — KBC Bank is pursuing a CASP authorisation to offer crypto trading via its Bolero platform, targeting retail investors; filing/grant status and date not confirmed this cycle retrieved M3 non-binding
- T1MiCA Art.143(3) grandfathering, Belgium — Belgium applied the full 18-month transitional period for pre-existing providers, which expired EU-wide (including for Belgium) on 1 July 2026; no provider had ever registered under the predecessor national VASP regime. retrieved M4 binding in force
- T3FSMA (Belgium) — The FSMA publicly named six crypto-asset service providers identified as operating in Belgium without MiCA authorisation shortly after the 1 July 2026 transitional deadline. retrieved M3 non-binding
- T3FSMA — Six unauthorised crypto-asset service providers added to FSMA's public fraudulent-CASP warning list following the 1 July 2026 transitional-period expiry retrieved M3 binding in force