Do you need to declare crypto accounts or wallets in Belgium? A practical step-by-step guide for 2026

Cryptocurrencies such as Bitcoin, Ethereum and other digital assets have become firmly established among Belgian private individuals in recent years. This has inevitably raised a number of tax-related questions. In addition to the much-debated new capital gains tax on crypto-assets and the qualification of crypto income, we are very frequently asked another, more practical question: do crypto accounts or crypto wallets need to be declared in the Belgian personal income tax return or separately reported to the Central Point of Contact of the National Bank of Belgium (the “CPC”)?

At present, Belgian individual taxpayers are not explicitly required by law to declare crypto accounts or crypto wallets in their tax return or to report them to the CCP, however, it is advisable to report such accounts or wallets, in light of the broad interpretation of foreign accounts and the increasing level of tax transparency.

This question is far from theoretical. The increasing international reporting obligations as from 2026, such as the Common Reporting Standard (CRS) and the new DAC8 Directive for crypto service providers, will significantly increase tax transparency with respect to crypto-assets. This article therefore focuses exclusively on the declaration and reporting obligations applicable to crypto accounts and wallets in Belgium, the relevant rules and the potential consequences of non-compliance.

The basic principle: the obligation to report foreign accounts in the tax return and to the CPC

All Belgian tax residents are legally required to report their foreign accounts to the Central Point of Contact of the National Bank of Belgium (CPC ). This basic principle is enshrined in Article 307, §1, second paragraph of the Belgian Income Tax Code (WIB 92), which provides that, at the latest at the time of filing the tax return in which the existence of foreign accounts is mentioned, the account numbers, the name of the relevant banking, exchange, credit or savings institution and the country or countries where the accounts were opened must also be communicated to the CPC , unless this information was already provided in a previous tax year.

The key question is therefore whether a crypto wallet can be regarded as an “account” within the meaning of Belgian tax law, and whether a centralised crypto platform (such as Kraken, Binance, Bitvavo or Coinbase) can be equated with a banking, exchange, credit or savings institution as referred to in Article 307 WIB 92. As long as this qualification is not explicitly confirmed by the legislator, the application of the existing reporting obligation to crypto structures remains legally uncertain.

What is the Central Point of Contact (CPC)?

The Central Point of Contact of the National Bank of Belgium, commonly referred to as the CPC , is a statutory central database in which certain financial data relating to Belgian taxpayers are recorded. The purpose of the CPC is to enable the tax authorities to more efficiently verify whether Belgian tax residents correctly declare their foreign accounts and to support tax audits.

The underlying principle is that all Belgian tax residents must report the existence of their foreign accounts. The scope of the information recorded in the CPC is strictly limited. No account balances are recorded, nor are details of transactions or movements carried out through the accounts. The registration is limited to the existence of the account, the account number, the identity of the financial institution involved and the country in which the account was opened. In other words, the CPC is not a register of assets, but an instrument designed to identify the existence of foreign accounts. It should be noted, however, that for domestic accounts (with Belgian banks), semi-annual balances and certain cash transactions have been recorded in the CPC since 2020.

The information recorded in the CPC may be consulted by the tax authorities in the context of tax audits, without the need to systematically request prior information from the taxpayer. The CPC must be clearly distinguished from international information exchange mechanisms such as the Common Reporting Standard (CRS) and the DAC8 Directive, which concern automatic reporting by financial and crypto service providers and whose data are not recorded in the CPC .

Do crypto accounts or wallets need to be reported to the CPC?

Whether crypto accounts or crypto wallets must be reported to the CPC depends directly on whether a crypto wallet can be regarded as an “account” within the meaning of tax law, and whether a centralised crypto platform can be equated with a banking, exchange, credit or savings institution as referred to in Article 307 WIB 92.

From a strictly legal perspective, there are, in our view, strong arguments to support the position that crypto accounts and crypto wallets do not automatically fall within this statutory framework. This is due to the specific nature of crypto wallets, which do not in themselves constitute an account held with a financial institution, and the particular role of crypto exchanges, which differs fundamentally from that of the traditional banking, credit or savings institutions envisaged by Article 307 WIB 92. The current legal provisions were drafted with traditional financial structures in mind and do not explicitly address decentralised or hybrid crypto structures.

It should also be emphasised that, to our knowledge, no Belgian court has yet ruled explicitly on the qualification of crypto accounts or crypto wallets as foreign accounts within the meaning of Article 307 WIB 92. This lack of case law contributes to the existing legal uncertainty.

That being said, taxpayers do not operate in a legal vacuum. In practice, it is therefore important not only to analyse the statutory provisions, but also to take into account the position of the CPC itself and the approach adopted by the tax authorities.

Position of the CPC

The Central Point of Contact of the National Bank of Belgium has addressed this issue in its publicly available FAQ. The CPC appears to receive this question regularly and has clarified its administrative position accordingly. In its FAQ, the CPC states the following:

You need only report the existence of a foreign crypto account to the CPC (and on your tax return), if it is held at a foreign bank, exchange office, or credit or savings institution (within the meaning of Article 318 of the Income Tax Code 1992).”

Although the CPC does not explicitly refer to crypto wallets as a separate category, this wording suggests that, according to the CPC , the reporting obligation is limited to crypto accounts or wallets held with a foreign banking, exchange, credit or savings institution. In practice, this corresponds to so-called custodial wallets, i.e. wallets or accounts held with centralised crypto exchanges where the user does not control the private keys.

This typically concerns accounts or wallets held with foreign crypto exchanges such as Kraken, Coinbase, Binance, Bitvavo and similar platforms. A defining feature of these structures is that the crypto-assets are held and managed by the exchange, meaning that the user is legally and factually dependent on a third party.

This position implies, conversely, that non-custodial wallets (where the user controls the private keys and no banking, exchange, credit or savings institution is involved) fall outside the scope of the CPC reporting obligation. Examples include software and hardware wallets such as MetaMask, Ledger, Trezor and Ngrave.

It is important to emphasise that this interpretation stems from the CPC administrative position and not from an explicit statutory provision. Nevertheless, it is highly relevant in practice.

Position of the tax authorities: parliamentary question on crypto wallets

The Belgian tax authorities have also expressly addressed the reporting obligation for crypto wallets through the Minister of Finance, following a parliamentary question raised in 2024. This intervention is particularly significant, as it clearly distinguishes for the first time between custodial and non-custodial wallets in the context of Belgian tax reporting obligations.

Parliamentary question of 26 March 2024

On 26 March 2024, Mr Van Hees submitted a parliamentary question to the Minister of Finance (Parliamentary Question No. 1971) concerning the obligation to declare foreign crypto wallets. He asked for clarification as to whether, and to what extent, different types of crypto wallets must be declared in the personal income tax return, explicitly distinguishing between custodial and non-custodial wallets.

More specifically, he asked whether a non-custodial wallet held abroad should be declared by analogy with the rules applicable to PayPal accounts. He distinguished three situations: professional use, private use exclusively for payment purposes, and private use for investment purposes, pointing to the existing legal uncertainty surrounding the qualification of non-custodial wallets.

Answer of the Minister of Finance (6 May 2024)

In his answer of 6 May 2024, the Minister of Finance confirmed that the obligation to declare foreign accounts is based on Article 307 WIB 92. This provision covers foreign accounts of any type, provided that they are held with a foreign banking, exchange, credit or savings institution.

According to the Minister of Finance, the term “account of any kind” must be interpreted very broadly and may, in principle, also include crypto wallets. This does not mean, however, that every crypto wallet automatically falls within the reporting obligation. In order to be subject to Article 307 WIB 92, the account must also be opened with a bank, exchange, credit or savings institution located abroad.

The Minister further clarifies that the reporting obligation depends on the status and activities of the platform with which the crypto wallet is opened. Only where that platform, abroad, professionally provides financial services comparable to those of Belgian bank, exchange, credit or savings institutions does the crypto wallet need to be declared in the personal income tax return and reported to the CAP.

Under this approach, custodial wallets (where an intermediary is involved in the safekeeping of the crypto-assets and the management of the private keys) fall in principle within the scope of the reporting obligation, provided that the foreign intermediary can be qualified as a financial institution.

Non-custodial wallets, however, are treated differently. Wallets where the taxpayer controls the private keys and no intermediary qualifies as a foreign banking, exchange, credit or savings institution do not fall within the reporting obligation under the current legal framework. This includes hardware wallets, paper wallets and other self-custody solutions.

Such non-custodial wallets therefore do not need to be declared in the personal income tax return nor reported to the Central Point of Contact of the National Bank of Belgium, as they are not “held” with a foreign financial institution within the meaning of Article 307 WIB 92.

Scope and significance of this administrative position

The Minister’s answer makes it clear that, according to the tax authorities, crypto accounts and crypto wallets must be declared when they are held through an intermediary qualifying as a foreign financial institution. In practice, this means that custodial wallets held with foreign crypto exchanges fall within the reporting obligation.

This administrative position should not be underestimated, as it is guiding for tax audits and assessments. At the same time, it must be placed in its proper perspective. An answer given by the Minister of Finance does not constitute legislation and cannot extend the statutory scope of Article 307 WIB 92. The Minister does not form part of the legislative branch.

Nevertheless, academic debate persists. Certain authors continue to argue that, when strictly interpreted, the current statutory wording does not cover crypto wallets or crypto accounts, and that explicit legislative intervention would be required to bring them unambiguously within the scope of the reporting obligation. In this context, previous government policy statements announced an intention to amend the legislation to expressly include crypto accounts and wallets and thereby put an end to interpretative uncertainty. At the time of writing, in early 2026, such legislative amendments have not yet been enacted, meaning that legal uncertainty persists despite the clear administrative stance.

In practice, most tax advisers now adopt a pragmatic approach and recommend declaring custodial wallets held with foreign crypto exchanges in the personal income tax return and reporting them to the CPC . This advice is generally not driven by a strict legal obligation, but by a risk-based assessment. As explained below, failure to report may result in significant tax and administrative sanctions, which often leads to a cautious approach prevailing in practice.

What are the risks and sanctions for failing to declare crypto accounts?

Failure to declare foreign accounts in the personal income tax return or to report them to the Central Point of Contact of the National Bank of Belgium may result in administrative fines of up to EUR 1,250 per infringement.

In addition, concealing taxable income derived from crypto-assets may give rise to tax surcharges. Depending on the circumstances and the assessment made by the tax authorities, such surcharges may range from 10% to 200% of the tax due.

In practice, failure to declare crypto accounts or wallets is sometimes also relied upon to establish tax fraud. Such a qualification has significant consequences, as it may trigger extended audit and assessment periods. This allows the tax authorities to go back considerably further in time, increasing the risk of additional assessments and sanctions.

Position of Belgian banks in the repatriation of crypto-assets

Although the position of legal doctrine and that of the tax authorities is of considerable legal importance, in practice it is above all the position of Belgian banking institutions that plays a decisive role in the repatriation of crypto-assets (see our separate article for a detailed discussion of the repatriation of crypto-assets).

When crypto-assets are transferred to a Belgian bank account, banks almost systematically ask whether the relevant crypto accounts or wallets have been reported in the personal income tax return and declared to the CAP. It is not uncommon for banks to refuse to accept these funds unless proof is provided that the accounts or wallets have been duly and correctly declared.

Can the tax authorities obtain information about my foreign crypto accounts?

There is currently an international information exchange system involving approximately 120 countries (including all EU Member States) through which tax authorities receive information on foreign financial accounts (such as bank accounts) held by Belgian taxpayers, as well as the income generated on those accounts (interest, dividends, etc.). This system is known as the Common Reporting Standard (CRS). As from 2026, the CRS framework has also been extended to crypto accounts and wallets.

As outlined above, 2026 represents a turning point for crypto from a tax perspective. With the entry into force of the DAC8 Directive, the existing EU framework for administrative cooperation in tax matters has been expanded to include specific reporting obligations for crypto-assets. DAC8 requires crypto service providers to report information on their users and crypto transactions to the tax authorities, which is then automatically exchanged between EU Member States.

In practical terms, this means that, as from this year, the Belgian tax authorities will annually receive information from foreign crypto platforms concerning Belgian taxpayers. This information can be matched against the personal income tax returns filed, significantly increasing detection risks in cases of non-declaration. The scope and practical impact of DAC8 are discussed in detail in a separate article and are therefore not further addressed here.

In addition to international information exchange, the Belgian tax authorities make use of internal analytical tools such as MoneyControl. MoneyControl is not a standalone database, but an internal tool that allows the tax authorities to combine and analyse information from various sources (including tax returns, CPC data and international exchanges such as DAC8) for risk analysis and audit purposes. The functioning and legal framework of MoneyControl are discussed in more detail in a separate publication.

What if I have not yet declared my crypto accounts to the CPC ?

Where crypto accounts have not yet been reported to the Central Point of Contact, it is generally advisable in practice to do so as soon as possible. The current legislation has not yet been explicitly adapted to crypto-assets: crypto accounts are not expressly mentioned in the existing statutory provisions and the reporting obligation is not clearly articulated in this respect. On that basis, it can still be argued today that such accounts do not formally fall within the scope of the reporting obligation, meaning that any administrative fine could potentially be challenged.

However, this legal debate is rapidly losing practical relevance. As from this year, crypto exchanges are required under DAC8 to report information on Belgian users to the relevant authorities, meaning that the Belgian tax administration will obtain visibility on these accounts in any event. Failing to declare crypto accounts therefore serves little practical purpose, as the administration will become aware of them regardless. Combined with the clear position adopted by the Minister of Finance, our practical recommendation is to report crypto accounts to the CPC , even though it may still be legally arguable that no explicit statutory obligation currently exists.

How to declare crypto accounts or wallets to the CPC in practice

Against this background, it is often recommended in practice to declare crypto accounts and custodial wallets in the personal income tax return and to report them to the CPC , not because of an explicit statutory obligation, but based on a pragmatic risk assessment. This is, however, easier said than done, as the CPC is currently designed primarily for traditional bank accounts. Below we therefore explain, step by step, how a crypto account or wallet can be reported in practice.

1. Go to: https://cappcc.nbb.be/my.policyYou may first need to click on “Click here to continue”.

2. Log in (for example via itsme).

3. Select “Declare your foreign bank accounts”.

4. At “Identification of the taxpayer”, click “Next”.

5. Under “Account details”, click “Add an account” and complete the following fields:

   • Account number: Crypto accounts and crypto wallets do not have a traditional account number. In practice, an identifying reference can be entered here, such as the full name of the account holder, optionally combined with the customer number provided by the exchange or the user name/login used on the platform.

   • Name of the institution: Preferably mention the legal name of the crypto exchange. This information can usually be found in the privacy policy, terms and conditions or legal notices on the exchange’s website.

   • Country where the account was openedIndicate the country where the legal entity operating the exchange is established, as stated in the exchange’s legal documentation.

   • Oldest tax year in which the account existedMention the earliest tax year during which the crypto account or wallet existed.

   • Date of closureOnly complete this field if the crypto account or wallet has already been closed.

6. Repeat step 5 for each crypto exchange with which you hold an account.

Conclusion

Although crypto accounts are not currently explicitly listed among the foreign accounts that must be declared in the annual personal income tax return and reported to the CPC , it is generally advisable to do so. This is because the Minister of Finance — and, consequently, the tax authorities — have adopted this position. In addition, this is often one of the questions Belgian banks raise when crypto gains are transferred to a Belgian bank account. For these reasons, declaration is often the most pragmatic solution, even if it requires a degree of creativity in practice.

Do you have questions about your specific situation or whether your crypto accounts need to be declared? You can schedule a no-obligation meeting via the button below. During this meeting, we will review your situation in detail and provide our initial insights.

FAQ – Reporting of crypto accounts and wallets in Belgium

Do I have to declare or report my crypto accounts or crypto wallets in Belgium?

Belgian law requires the declaration and reporting only of foreign accounts held with a bank, exchange, credit institution or savings institution. Crypto accounts are not explicitly mentioned in the legislation. In practice, however, the tax authorities expect crypto accounts held with foreign centralised crypto exchanges to be declared.

Does this also apply to hardware wallets or self-custody software wallets?

No. Wallets for which you manage the private keys yourself and where no financial intermediary is involved are, under the current state of affairs, not subject to a declaration or reporting obligation.

What about accounts held with foreign crypto exchanges such as Kraken, Binance, Bitvavo or Coinbase?

According to the position of the Minister of Finance, such crypto accounts must in principle be declared and reported to the Central Point of Contact (CAP). This position is currently guiding for tax audits and for the practice of Belgian banks.

What are the risks if I do not declare my crypto accounts?

Failure to declare may lead to administrative fines, tax surcharges and extended audit periods. In addition, Belgian banks may refuse to accept crypto-related funds unless proof of declaration is provided.

Can the tax authorities discover my foreign crypto accounts?

Yes. As from 2026, crypto accounts are subject to automatic reporting under DAC8. The Belgian tax authorities are expected to receive this information as from 2027, significantly increasing the detection risk in case of non-declaration.

I do not want to declare my crypto accounts as a matter of principle. Is that possible?

There are still legal arguments to support the view that crypto accounts do not fall within the scope of the current legislation. However, the tax authorities do not follow this position. Anyone who deliberately chooses not to declare accepts an increased risk of discussions and audits and should ensure that this position is supported by a well-reasoned legal analysis.

What is the practical advice today?

In practice, it is generally recommended to declare crypto accounts held with foreign centralised exchanges, based on a pragmatic risk-management approach.

For other crypto-related questions, please also consult our Frequently Asked Questions (FAQ).

Appointment

Christophe Romero Senne Verholle

christophe.romero@aeacus.be senne.verholle@aeacus.be