CPC reporting obligation extended to account balances

bankpas

Since the start of 2022, financial institutions operating in Belgium have been required to submit additional information to the Central Point of Contact for accounts and financial contracts (CPC):

  • bank and payment account balances as at 30/06 and 31/12;
  • aggregate amounts held under investment contracts and related contracts as at 30/06 and 31/12; 
  • aggregate amounts held under life insurance contracts as at 31/12.

Reporting

Credit institutions, payment institutions, electronic money institutions, stockbroking firms and insurance companies had until 31 January 2022 at the latest to report the following information to the CPC:

  • the balances held in bank and payment accounts and the aggregate amounts held under investment contracts and related contracts as recorded on 31/12/2020, 30/06/2021 and 31/12/2021;
  • the aggregate amounts held under insurance contracts as recorded on 31/12/2020.

Insurance companies have a three-month window to submit the aggregate amounts held under insurance contracts to the CPC (until 31/03/2022 for the amounts recorded on 31/12/2021). 

Subsequently, these financial institutions (declarers) must continue sending these data to the CPC on a regular basis. 

Consultation

The account balances and aggregate amounts can be consulted since February 2022.

Context and developments

The CPC has been centralising data on the accounts and financial contracts of private individuals and businesses in Belgium since 2011. As of 2015, it also centralises information on Belgian residents’ accounts abroad. The management of the CPC has been entrusted to the National Bank of Belgium (NBB).

Credit institutions, payment institutions, electronic money institutions, stockbroking firms, insurance companies, leasing companies, professional lenders and Bpost are legally obliged to report information from their customers on domestic accounts, financial contracts and transactions involving cash to the CPC. These entities are referred to as declarers.

In addition, Belgian residents are also required to declare any accounts they hold abroad to the CPC themselves.

Since its creation, the CPC has been expanded numerous times according to economic needs and technological developments. However, this expansion has also – and primarily – been driven by the needs of the bodies entitled by law to consult the CPC as part of their public interest mission (the ‘parties entitled to access the information‘). These bodies include the Federal Public Service (FPS) Finance, the FPS Justice, notaries (in the context of successions), the Flemish Tax Administration, Judicial Officers (at the request of an attachment judge) and the Financial Intelligence Processing Unit (CTIF/CFI).

The extended CPC declaration obligation applicable since 2022 stems from the Programme Law of 20 December 2020 (only available in Dutch or French) and the Royal Decree of 6 June 2021 (only available in Dutch or French).