In Belgium

In Belgium

Situation checked in the corpus on 29-10-2026.

The table reproduces the capacity that each text gives to each actor.

Actor	Role	Basis
Supervisory body, set up within FPS Economy	Supervision of trust service providers established in Belgium, including electronic archiving services	Art. I.18 Art. XV.26(2)
The minister or the minister’s delegate (so designated by the Code)	May prohibit a qualified provider that has not remedied a failure from continuing to offer qualified services, or a non-qualified provider from continuing to offer non-qualified trust services	Art. XV.26(4)
FPS Economy	Operator of the Belgian trusted list	Trusted List BE, sequence number 84 — summary
Director-General for Quality and Safety of FPS Economy	Sectoral authority, under the Act of 26 April 2024 on cybersecurity, for trust service providers	Art. 3(2)(4) Art. 1
FPS Policy and Support (FPS BOSA)	Electronic identification services for public applications, within the authentication service; approval of private services	Art. 9(1) Art. 10(1)
Federal service integrator (the FPS in charge of Digitalisation)	Develops and makes available a European Digital Identity Wallet (task 14 of Article 4 of the Act)	Art. 3 Art. 4
FPS Home Affairs and FPS Policy and Support	Make the qualified electronic signature service available	Art. 2(2)
Centre for Cybersecurity Belgium (CCB)	National cybersecurity authority; national cybersecurity certification authority	Art. 3(1) Art. 3

The role of supervisory body within the meaning of the eIDAS Regulation is presented in step 2.

In Belgium

Situation checked in the corpus on 29-10-2026.

The diagram reads in two columns. On the left, the supervisory body, set up within FPS Economy, supervises the trust service providers established in Belgium Art. I.18 Art. XV.26(2). FPS Economy is the operator of the Belgian trusted list Trusted List BE, sequence number 84 — summary, and its Director-General for Quality and Safety is, for these providers, the sectoral authority provided for by the Belgian Act of 26 April 2024 on cybersecurity, which transposes the NIS2 Directive (see below) Art. 1. On the right, FPS BOSA offers the authentication service for public applications Art. 9(1) and develops the federal digital identity wallet Art. 2(1)(3); together with FPS Home Affairs, it makes the qualified electronic signature service available Art. 2(2). At the bottom, the CCB is the national cybersecurity authority Art. 3(1) and the national cybersecurity certification authority Art. 3.

In Belgium

Situation checked in the corpus on 29-10-2026.

The Act of 21 July 2016 inserted into Book XII of the Code of Economic Law (CDE) a Title 2 devoted to trust services Act of 21-07-2016 (numac 2016009485) Code of Economic Law, Book XII, Title 2 (Art. XII.24-XII.39) + Art. I.18, XV.25-26, XV.123. It opens as follows (quoted in French, the language of the corpus version used):

Le présent titre met en oeuvre le règlement 910/2014.

In substance: this title implements Regulation 910/2014.

This title lays down rules supplementing the Regulation for electronic signature, electronic seal, electronic archiving, electronic registered delivery and electronic time-stamping services offered by a provider established in Belgium, as well as for an electronic archiving service operated on its own behalf by a public sector body or a natural or legal person established in Belgium Art. XII.24(2). It excludes from its scope, and from that of the Regulation, the components used for electronic signatures, electronic registered deliveries, electronic time-stamping and electronic archiving that an administrative authority, within the meaning of Article 14 of the coordinated laws on the Council of State, provides free of charge or against payment in performing the tasks entrusted to it by or under a law. To that end, the Code invokes the provision of the Regulation on closed systems Art. XII.24(3) Art. 2(2). Only the first paragraph of the articles of the Regulation on the legal effect of electronic signatures, electronic time stamps and electronic registered delivery remains applicable to signature, registered delivery and time-stamping components: their legal effect and admissibility as evidence in legal proceedings may not be denied solely on the grounds that they are in electronic form, or that they are not qualified. The other legal effects provided for by these articles are not made applicable Art. XII.24(3) Art. 25(1) Art. 41(1) Art. 43(1).

General principles

The Code first lays down a rule of freedom:

A défaut de dispositions légales contraires, nul ne peut être contraint de poser un acte juridique par voie électronique.

In substance: unless the law provides otherwise, no one may be compelled to perform a legal act electronically.

It adds several rules specific to Belgian law:

• a qualified electronic seal is treated as equivalent to the handwritten signature of the natural person who represents the legal person that created the seal. This equivalence applies only to legal acts performed exclusively by or between persons domiciled or established in Belgium, and without prejudice to the Civil Code and the rules on the representation of legal persons Art. XII.25(3);
• subject to specific legal or regulatory requirements, an obligation to retain data or documents imposed, expressly or tacitly, by a legal or regulatory text is presumed to be met by the use of a qualified electronic archiving service Art. XII.25(5);
• with the same reservation, a registered delivery imposed in the same way is presumed to be met by a qualified electronic registered delivery service Art. XII.25(7);
• with the same reservation, a dating obligation imposed in the same way is presumed to be met by a qualified electronic time stamp (paragraph 8 of the same article) Art. XII.25.

Other subparagraphs of the same paragraphs provide, with the same reservation and for obligations expressly imposed by a text, for the use of the qualified service if the user opts for the electronic route. Justel, the unofficial consolidation of Belgian texts (only the Belgian Official Gazette (Moniteur belge) is authentic), indicates an “undetermined” entry into force for them: they are therefore not in force Art. XII.25 Act of 16-07-2026 (numac 2026005829).

Qualified electronic archiving

The qualified electronic archiving service, specific to Belgian law, is presented in step 4. Two rules complete it.

Anyone who operates such a service on their own behalf is exempted from certain requirements of the Regulation and of Annex I to the Code. They must nevertheless send the supervisory body, before starting, their name, address, contact details, enterprise number and an assessment report drawn up at their own expense by a conformity assessment body; the supervisory body issues them an acknowledgement of receipt within five working days and may, if it considers it useful, in particular in the light of the assessment report, carry out an inspection Art. XII.28(2).

The King may also lay down the standards applicable to the service:

Le service d’archivage électronique qualifié qui respecte ces normes est présumé satisfaire à tout ou partie des exigences du présent titre et de son annexe I.

In substance: a qualified electronic archiving service that meets these standards is presumed to satisfy all or part of the requirements of this title and of its Annex I.

The Royal Decree of 29 March 2019 lays down these standards. It repeats the same presumption, for the requirements listed in its annex Art. 1. That annex maps requirements of the Code and of the Regulation to clauses of technical standards, including ISO standards and an AFNOR standard Royal Decree of 29-03-2019 (numac 2019011763).

The same paragraph of the Code opens with a reference to the Regulation Art. XII.28(3):

Sans préjudice de l’article 34, paragraphe 2, du règlement 910/2014

In substance: without prejudice to Article 34(2) of Regulation 910/2014.

In the consolidated version of the Regulation, that paragraph requires the Commission to establish, by means of implementing acts and by 21 May 2025, a list of reference standards and, where necessary, the specifications and procedures applicable to the qualified preservation service for qualified electronic signatures Art. 34(2). Compliance with these standards gives rise to a presumption that this service meets the requirements that the Regulation lays down for it Art. 34(1) Art. 34(1a). Its current text is the one substituted by Regulation 2024/1183, which is later than the 2016 Act Art. 1. The corpus does not contain the 2014 text to which the 2016 Act referred. Regulation 2024/1183 inserted a new paragraph Art. 34(1a) and replaced paragraph 2, without renumbering: the reference still points to an existing paragraph Art. 1.

Qualified certificates and sanctions

Without prejudice to several articles of the Regulation, the Code lists the cases in which a qualified provider revokes a qualified certificate: at the request of the previously identified holder; where there are serious grounds for believing that the certificate is based on erroneous or falsified information, that its information is no longer in line with reality or that the confidentiality of the creation data has been breached; where the courts have ordered the measures provided for by the Code in respect of supervision Art. XV.26(4); in the event of cessation of activity without full takeover; upon the death or dissolution of the holder, after verification Art. XII.31. The holder, for their part, must have the certificate revoked in the event of serious doubt about the confidentiality of their signature or seal creation data, or if the information in the certificate is no longer in line with reality Art. XII.32.

Usurping the capacity of qualified trust service provider without being included in the trusted list is punishable by a level 5 sanction Art. XV.123. The extracts of the Code held in the corpus do not contain the provision that specifies what this level covers Code of Economic Law, Book XII, Title 2 (Art. XII.24-XII.39) + Art. I.18, XV.25-26, XV.123.

A text that predates eIDAS 2

Title 2 of Book XII dates from the 2016 Act. No source in the corpus, consulted on 29-10-2026, shows any adaptation of this title to Regulation 2024/1183 (see step 1) Code of Economic Law, Book XII, Title 2 (Art. XII.24-XII.39) + Art. I.18, XV.25-26, XV.123. Several references in the Code still point to Article 17 of the Regulation, in particular the definition of the supervisory body Art. I.18 and the minister’s power of prohibition Art. XV.26(4)(c). They are reproduced as they appear in the Code; in the consolidated version of the Regulation, the supervision of trust services is organised by Art. 46b (see step 2).

In Belgium

Situation checked in the corpus on 29-10-2026.

Supervision of providers

The supervisory body is responsible for supervising the trust service providers established in Belgium. It may be assisted by experts who are independent of the providers Art. XV.26(2). When it finds a failure to comply with the Regulation or the Code, it gives the provider formal notice and sets a reasonable period to remedy it, assessed according to the nature and seriousness of the failure Art. XV.26(3). The Code then provides:

Si après l’expiration de ce délai, les mesures nécessaires n’ont pas été prises, le ministre ou son délégué peut :

In substance: if, after that period has expired, the necessary measures have not been taken, the minister or the minister’s delegate may act.

The minister or the minister’s delegate may then prohibit a qualified provider from continuing to offer qualified services, order it to inform its users of the loss of qualified status, or prohibit a non-qualified provider from continuing to offer non-qualified trust services Art. XV.26(4)(a) Art. XV.26(4)(b) Art. XV.26(4)(c).

According to FPS Economy, qualification takes place in several stages. The supervision of candidates relies in particular on a conformity assessment report drawn up by a body accredited for the service concerned; a first body to certify electronic archiving was accredited by BELAC (the Belgian Accreditation Body) in April 2023 FPS Economy — thematic page, Les prestataires de services de confiance qualifiés en Belgique. FPS Economy also states that qualified providers are supervised ex ante and ex post, through a periodic audit every two years or an extraordinary audit requested by the supervisory body FPS Economy — thematic page, Sécurité et contrôle. The steps for a provider that wants to become qualified are detailed in step 7.

The cybersecurity side (NIS2)

The Act of 26 April 2024 establishing a framework for the cybersecurity of network and information systems also applies, regardless of their size and without prejudice to its Article 6, to entities of a type referred to in its Annexes I or II where their services are provided by trust service providers Art. 3(3)(1)(b). It aims in particular to transpose Directive (EU) 2022/2555, known as NIS2, presented in step 2 Art. 2. For these providers, the sectoral authority is the federal Minister for the Economy or, by delegation, a senior official of the minister’s administration Art. 3(2)(4). A Ministerial Decree of 18 September 2024 designates for this purpose the Director-General for Quality and Safety of FPS Economy Art. 1(1).

The Belgian trusted list

Each Member State establishes, maintains and publishes a trusted list of the qualified trust service providers for which it is responsible and of their qualified services Art. 22(1). Its role and how to read it are explained in step 5.

The Belgian version in the corpus bears sequence number 84. Issued on 20 October 2026, it announces its next update for 20 April 2027. It lists 17 providers; some now have only services with the status “withdrawn”, for example Portima or Universign Trusted List BE, sequence number 84 — summary. Only the signed XML file is authentic; the corpus summary is derived from it Trusted List BE, sequence number 84 Trusted List BE, sequence number 84 — summary.

In Belgium

Situation checked in the corpus on 29-10-2026.

FPS Economy also publishes a readable list of the active qualified trust service providers established in Belgium. The version in the corpus is dated 19 May 2026. It classifies twelve providers, designated by their trade name, under fifteen categories of services FPS Economy — list of 19-05-2026. The table summarises it.

Category of qualified services (list of 19 May 2026)	Providers ticked
Qualified certificate for electronic signatures with a qualified device (QSCD)	Certipost, Digicert Belgium, ZetesConfidens, GlobalSign, Belgium - Federal Government
Qualified certificate for electronic signatures without a QSCD	GlobalSign
Management of remote qualified signature or seal creation devices	Belgium - Federal Government
Qualified certificate for electronic seals with a QSCD	Digicert Belgium, ZetesConfidens, GlobalSign, Belgium - Federal Government
Qualified certificate for electronic seals without a QSCD	GlobalSign
Qualified certificate for website authentication	GlobalSign
Qualified electronic registered delivery	Connect Solutions, UnifiedPost, Dioss Smart Solutions, Easypost
Qualified electronic time stamp	ZetesConfidens, GlobalSign, Belgium - Federal Government
Validation of qualified signatures and seals	Belgian Mobile ID, Nitro
Preservation of qualified signatures and seals	Docbyte
Qualified electronic archiving under Belgian law, for the preservation of electronic documents	Docbyte
Qualified electronic archiving under Belgian law, for the digitisation of documents	no provider ticked

Source of the table: FPS Economy — list of 19-05-2026. The conversion of the French version merges the Easypost and Docbyte rows; the Dutch version of the same list separates them and attributes the preservation and archiving ticks to Docbyte FPS Economy — list of 19-05-2026.

The trusted list, which is more recent, also contains services whose “granted” status dates from after 19 May 2026, for example at Banqup SA since 15 June 2026 Trusted List BE, sequence number 84 — summary. Only the signed XML file of the trusted list is authentic Trusted List BE, sequence number 84 Trusted List BE, sequence number 84 — summary.

Steps 4 and 5 explain what these services cover (step 4) and how to check a qualified status (step 5).