Summary
The Belgian tax authorities have access to an increasing amount of financial information about taxpayers. Bank accounts, account balances, investment contracts, life insurance policies and foreign accounts are already collected for several years through different reporting systems.
Since the end of 2025, Belgium has taken this one step further. Information from the Central Point of Contact for accounts and financial contracts (CAP/CPC) can now be combined with the much broader data warehouse of the Belgian tax authorities and used for data matching, data mining and risk profiling.
In practice, this means that tax audits will increasingly be selected on the basis of automated comparisons between different sources of information.
This does not mean that the tax authorities can simply open your bank account and inspect every transaction. But it does mean that discrepancies between your tax return, your financial information and data received from third parties can become much easier to identify.
For Belgian taxpayers, the message is therefore straightforward: consistency and correct reporting are becoming more important than ever.
What is the CAP?
Belgium has operated a Central Point of Contact for accounts and financial contracts, commonly referred to as the CAP in Dutch and CPC in French, for many years. The database is managed by the National Bank of Belgium. It centralizes information concerning, among other things:
- Belgian bank and payment accounts
- certain investment and financial contracts
- certain life insurance contracts
- foreign bank accounts reported by Belgian residents and
- certain financial transactions involving cash.
Since 2022, Belgian banks must also periodically report your account balances. For Belgian bank and payment accounts, the balance is generally reported on 30 June and 31 December. Similar information is collected for investment contracts, while certain life insurance values are reported annually. The CAP therefore contains considerably more information than simply a list of bank account numbers.
Foreign accounts are slightly different. Belgian residents who hold a foreign bank account must normally report its existence both (annually) in their Belgian personal income tax return and (one-time) separately to the CAP.
Tax authorities already receive information from many other sources
The CAP is only part of the picture. The Belgian tax authorities already operate a large data warehouse containing information collected from numerous sources.
Obviously, this includes information from your own Belgian tax returns. But it can also include information reported by employers, companies, financial institutions and other third parties.
Belgium furthermore participates in several international systems for the automatic exchange of information. A Belgian resident with an investment account in another (European) country should therefore not assume that the account remains unknown simply because the money is held abroad.
Under the Common Reporting Standard (CRS), financial account information is routinely exchanged between participating countries. Similar information can be obtained through FATCA in relation to the United States.
Digital platforms like Uber and Airbnb are also increasingly subject to reporting obligations. Under the European DAC7 rules, for example, information concerning certain sellers, landlords and service providers operating through online platforms may be transmitted to the tax authorities.
The result is that information which taxpayers may previously have considered separate is increasingly becoming part of the same overall picture.
What changed in December 2025?
The important development came with the Law of 18 December 2025. The legislation allows specifically designated tax officials to combine CAP information with information already contained in the FPS Finance data warehouse for purposes including data mining, data matching and profiling.
This sounds rather technical, but the concepts are relatively simple.
- Data matching means comparing information from different sources. Imagine that a Belgian tax return indicates that no foreign bank account exists, while information received through an international reporting system shows an account abroad. A computer can identify that inconsistency without an individual tax inspector manually reviewing both records.
- Data mining goes one step further. Large volumes of information are analyzed to identify patterns, unusual situations or combinations of factors which could indicate a tax risk.
- Profiling can then be used to assess certain characteristics and to help determine which taxpayers or files should receive additional attention.
The Belgian tax authorities are therefore gradually moving from a system where a tax audit is primarily initiated after an inspector notices something unusual to a system where technology helps determine which files inspectors should look at in the first place.
Does this mean the tax authorities can see all your bank transactions?
No. This is an important distinction. The CAP contains extensive financial information, but it is not a complete database of every individual payment made from your bank account.
For example, it can contain the existence of an account and its balance at certain reporting dates. It can also contain information regarding particular financial contracts.
This is very different from having unrestricted access to all underlying bank statements and individual payments. The Belgian Court of Audit has similarly confirmed that the CAP does not currently contain information about each individual banking transaction.
If the tax authorities subsequently want more detailed banking information in the context of an individual tax investigation, additional legal and procedural conditions generally apply.
The December 2025 legislation expressly distinguishes between using CAP information for risk analysis and communicating the underlying CAP information to the individual tax inspector conducting the audit.
In other words, the database can help determine that a file deserves closer examination without automatically giving the inspecting officer unrestricted access to all of the financial information behind that selection.
How does the selection process work?
The legislation contains an important safeguard. Before CAP information is included in the FPS Finance data warehouse for these analyses, personal information must be pseudonymised. In simplified terms, this means that the analysis should initially take place without the data miner directly working with the taxpayer’s name.
Different information can nevertheless be combined and analysed. Where predefined risk factors indicate a possible infringement of tax legislation, the information relating to that particular taxpayer can then be de-pseudonymised and the file can be referred for further investigation.
Importantly, being selected by such a system is not evidence of tax fraud. It merely means that the file has met certain risk criteria and may therefore be examined by a tax official. The legislation itself expressly recognises this distinction. That distinction is important because automated systems inevitably create the possibility of false positives.
An apparent inconsistency may have a perfectly legitimate explanation. For example, two sources may report the same income differently, an account may have been closed, a taxpayer may merely have signing authority rather than beneficial ownership, or foreign information may relate to a different tax year. Being selected for an audit therefore does not in itself mean that anything was done incorrectly.
Foreign accounts will become increasingly difficult to overlook
For internationally mobile taxpayers, the practical consequences are particularly relevant. Many Belgian residents hold accounts, investments, pensions or insurance products outside Belgium. This is perfectly legal.
The issue is whether the relevant Belgian tax and reporting obligations have been respected. A foreign bank account may, for example, have to be:
- 1. reported to the CAP; and
- 2. mentioned in the annual Belgian personal income tax return.
Income generated by the account may also have to be reported separately. The fact that an investment or bank account is located outside Belgium therefore does not remove it from the Belgian reporting environment.
Through CRS and other international information-exchange systems, the Belgian tax authorities may receive information directly from the country where the account is held. The possibility of automatically comparing this foreign information with Belgian tax filings makes omissions considerably easier to identify than in the past.
And what about crypto?
Crypto-assets are also gradually entering this reporting environment. The Law of 18 December 2025 extended the types of information to be included in the CAP to cover certain securities accounts and crypto-asset accounts.
Further implementing rules have been required to put these additional reporting obligations into practice. In July 2026, the Belgian Government approved a draft Royal Decree dealing with parts of this expanded framework. This development should also be viewed together with broader European initiatives to increase transparency surrounding crypto-assets.
The practical assumption that crypto held through a professional exchange or service provider remains outside the normal tax information network is therefore becoming increasingly outdated. This does not necessarily mean that every crypto holding is taxable. The reporting obligation and the tax treatment of a transaction remain two different questions.
Artificial intelligence & tax audits
The increased use of technology by tax administrations is certainly not uniquely Belgian. Tax authorities have enormous quantities of data available to them, and it is logical that technology is increasingly used to identify inconsistencies and select cases for audit.
The difficulty is determining where legitimate risk analysis ends and excessive profiling begins.
An algorithm may, for example, conclude that a combination of foreign accounts, company interests, unusual financial movements and information obtained from third parties makes a particular taxpayer statistically more interesting for an audit.
But the taxpayer will generally not know exactly which indicators were used, how heavily they were weighted or why his or her file ultimately crossed the relevant risk threshold.
That complete lack of transparency is one of the reasons why the new Belgian system has attracted considerable legal debate.
Constitutional Court challenge
Several provisions of the Law of 18 December 2025 are currently being challenged before the Belgian Constitutional Court.
One of the pending cases specifically concerns the use of CAP information within the tax administration’s data warehouse and the rules surrounding data mining, data protection and de-pseudonymisation.
The Court is therefore being asked to consider whether the new framework provides sufficient protection for fundamental rights such as privacy and personal-data protection. As of September 2026, these proceedings are still pending.
It remains to be seen whether the Constitutional Court will uphold the system in its current form, restrict certain aspects of it or annul particular provisions. For the time being, however, taxpayers should assume that the new framework applies.
What should taxpayers do?
There is no reason to panic because the tax authorities have access to more information. There is, however, every reason to make sure that the information reported in Belgium is complete and consistent.
This is particularly important for taxpayers with an international profile. Someone who has lived in several countries may simultaneously have foreign bank accounts, brokerage accounts, pension plans, stock options, foreign companies or real estate abroad. Different pieces of information concerning those assets can reach the Belgian tax authorities through different channels.
An innocent reporting error may therefore become much more visible once those databases are compared automatically. Particular attention should be paid to:
- foreign bank and investment accounts
- foreign life insurance and investment products
- overseas pension and retirement accounts
- interests in foreign companies and other legal structures
- income received through online platforms
- crypto-assets held through professional service providers and
- differences between information reported abroad and the Belgian tax return.
The question should no longer simply be: “Did I report this info somewhere?”. The better question is: “Does all the information reported about me tell the same story?”
Check your own CAP information
Taxpayers can also take a simple practical step themselves. The National Bank allows individuals to consult the information registered in their own name in the CAP free of charge. The easiest method is through the online application using itsme or your Belgian ID card.
It can be useful to check this information periodically, particularly if you have several Belgian or foreign accounts or have given or received powers of attorney over accounts.
Incorrect information can also be rectified. For Belgian accounts and contracts, corrections will generally need to be initiated through the financial institution that originally reported the information. Foreign account information previously reported by the taxpayer can also be updated.
Increasing transparency
The direction of travel is clear. Belgian taxation is moving towards an environment in which information is increasingly reported automatically, centralised and compared digitally.
A tax inspector no longer necessarily needs to discover an inconsistency manually. The systems available to the administration can increasingly identify unusual situations before a human inspector becomes involved.
For most compliant taxpayers, this should not fundamentally change their tax position.
But it does make accurate tax reporting more important.
Foreign accounts, investments or other assets should not be ignored simply because the amounts involved are small or because they are held outside Belgium. Information that appears insignificant in isolation may become relevant when matched against several other sources. And while the courts will still have to determine exactly where the limits of Belgium’s new “Money Control” framework lie, one practical conclusion can already be drawn: in an increasingly interconnected tax system, consistency is becoming almost as important as compliance itself.