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COVID-19 - Impact on Financial Sector - 29 June 2020


Please find below a summary of  COVID-19 developments of last week (22/6 until 26/6 included); these alerts are dedicated to following up on the financial  regulators’ responses to the crisis. We have also created a COVID-19 Resource Center to offer legal and business insights as this crisis continues to evolve. We wish you and your loved ones well.

If you have any questions please feel free to contact: 

Tom Van Dyck
+32 475 90 90 91

Freya Mareels 
+32 475 25 11 50

Wim Dedecker
+32 491 36 03 99



COVID-19: updating of customer information where ongoing investment services are provided or IBIPs are sold


The FSMA calls on companies in the banking, investment and insurance sector to update client information when providing continuous investment services of investment advice or asset management or when distributing insurance with an investment component.

The expectations of the FSMA are the following: 

  • In order to maintain the quality of the services in the interest of the client, the FSMA stresses that timely updating of the information collected is of great importance. That is why the FSMA calls on companies in the banking, investment and insurance sector to pay extra attention in the coming months to the possible tightening of their update policy and its implementation.

  • The FSMA expects companies in the banking, investment and insurance sector to demonstrably have procedures and update measures that suit their own organization and client base in the current market conditions.

  • The FSMA expects that in their update policy these companies will take into account possible significant changes in the client situation due to the Covid-19 crisis. This may involve implementing relevant changes in the provision of continuous investment services of investment advice, in their asset management, and/or in the distribution of insurance with an investment component.

  • It is important to note that, according to the FSMA, it is not sufficient to wait until the periodic update or until a client informs the company in the banking, investment and insurance sector about his/her changed situation on his/her own initiative. There may be a need to approach a wide range of clients earlier and/or more frequently.


Extension of the cycle of continuing education of certain compliance officers as a result of the Covid-19 health crisis


Compliance officers approved by the FSMA (as well as the employees in their departments) must ensure that their knowledge is kept up to date. They are required to take 40 hours and 20 hours of continuous training per three-year cycle, respectively.

  • In order to take into account the possible difficulties that Compliance Officers could face in the context of the situation resulting from the Covid-19 outbreak, a Royal Decree extends by 4 months the period available to persons whose recycling period expires on 31 December 2020.

  • This extension of the recycling cycle allows these persons to spread over time, exceptionally, their recycling obligations for the period expiring at the end of the year 2020 until 30 April 2021.


The FSMA publishes a Q&A for listed companies concerning the half-yearly financial report during the Covid-19 period


Most listed companies will soon be publishing their results for the first half of 2020. This will likely be their first mandatory periodic report to investors that provides a more comprehensive and detailed view of the impact of the Covid-19 pandemic on their financial situation, their activities and their results.

The FSMA wishes to set out a number of points that are to be taken into account in this regard, in the form of a Q&A published as a follow-up on: 


NBB confirms: credit tap remains open despite corona crisis



The NBB gave a state of affairs to the House of Representatives on bank lending during the corona crisis. Main findings:


  • During the Covid-19 crisis, banks played their role in supporting society and the economy, both in granting deferred payments and in granting new credit.

  • The ability to request a deferral for current credits has proved very useful. Many individuals and companies have appealed to it.

  • Payment deferments were requested for almost 10% of all company loans.

  • New lending to companies also remains at the same level. Business sectors that have been (more) badly affected by the crisis are also still receiving new credit.

  • Less than 4% of all requests for new credit (with a state guarantee) were refused by the banks.



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