Country Manual Credits
Belgium – Update 2025
BRP has updated its Country Manual Credits for
Belgium (RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | No |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | Yes |
Regulatory Template
Material changes
We have reviewed the documents following consultations with our local counsel. We can confirm that there have been no relevant regulatory changes since the last publication of this Country Manual.
Notwithstanding the foregoing, the country manual has been updated to reflect the evolution of the expert’s interpretation of the regulatory framework in the following aspects:
- Credit cards (Chapter 3): As already stated in Section 3.1.2, the Chapter only covers cases where the credit card contract does not qualify as a consumer contract. As a result, there is no need to specify “activity restricted by local consumer protection law” in the conditions.
- Lombard credits (Chapter 4): We have changed the basic premise of the Chapter in Section 4.1.2 to harmonise the approach with other Credits manuals. Only Lombard credits that do not qualify as consumer credits are covered by this Chapter. This modification justifies removing the conditions surrounding consumer credits. We have therefore removed the conditions “may qualify as consumer credit” and “activity restricted by local consumer protection law”. On the other hand, should Lombard credit qualify as a consumer credit, then it is necessary to refer to Chapter 1 (Consumer credits). Since the situation is quite delicate, a paragraph has been added as a reminder to proceed with caution.
In addition, it is evident that reverse solicitation must be duly documented, which is why this condition has been removed, although Credit Institutions must continue to observe this requirement.
Non-material changes
Several legal basis have been specified. The Tax and Data Protection parts have also been reviewed, without introducing any material changes.
Definition and Concept
The document Definitions and Concepts includes a Concordance Table. This Table is designed to help the users of the Country Manual Credits easily recognize existing or potential interactions between the rules of different types of credits.
For more information, please contact us: info@brpsa.com
Geneva, February 10th, 2025