Verification of Payee LEI Checks in Belgium

Verification of Payee LEI checks in Belgium offer a possible alternative to comparing a payee’s IBAN and name; companies do not need an LEI to receive payments. For a legal-person payee, an LEI check depends on the payer’s payment service provider (PSP) offering the channel and the payee’s PSP holding the identifier. The payer receives a verification result before authorising a euro credit transfer.

What this means in Belgium

Belgium is in the euro area. Under Regulation (EU) 2024/886 of 13 March 2024, the Instant Payments Regulation, which amended Regulation (EU) No 260/2012, Belgian PSPs have had to offer Verification of Payee under Article 5c since 9 October 2025 for standard and instant credit transfers in euro. This is a PSP compliance date, not a deadline for Belgian companies to obtain an LEI.

FPS Economy (FOD Economie) explains that banks automatically verify the payee name for a euro transfer within the euro area. Its guidance links the IBAN-name check to invoice fraud: it received more than 200 reports of invoice fraud in the previous year, with reported damage of 3.3 million euro. Those figures concern reported invoice fraud, not the availability of LEI-based checks.

Consider an Antwerp bvba/srl that receives an invoice showing a new account number. FPS Economy advises comparing that number with the order form or the supplier’s official website. A verification result can inform the payment decision, but it does not replace checking the new account number against those records. Belgian businesses should not assume that a PSP supports an LEI check simply because it performs the IBAN-name check. Ask the relevant PSPs whether the LEI channel is offered and whether the payee’s identifier is held in the payee PSP’s system.

Key points for Belgian businesses

• The usual Verification of Payee (VoP) check compares the payee’s IBAN with the name supplied by the payer.
• For a legal person, an LEI, fiscal number or European unique identifier (EUID) may be used for an alternative check if the conditions in Article 5c are met.
• VoP covers standard and instant credit transfers denominated in euro within the EU.
• A mismatch warns the payer; it does not stop the payer from authorising the transfer.
• Belgian PSPs have had to comply since 9 October 2025. PSPs in EU Member States whose currency is not the euro will have to comply by 9 July 2027.

The European Central Bank’s Instant Payments Regulation overview confirms that verification covers both standard and instant euro credit transfers.

When an LEI can be checked instead of a name

Article 5c(1) requires the payer’s PSP to offer verification immediately after the payer provides the payee details and before the payer can authorise the credit transfer, regardless of how the payment is initiated. In the usual check under Article 5c(1)(a), the payee’s PSP verifies on request whether the IBAN and payee name match. If they do not, the payer is notified that authorisation could send the funds to an account not held by the indicated payee.

Article 5c(1)(b) provides a different route for a payee that is a legal person. The payer’s PSP must offer a channel for supplying the IBAN and another data element that unambiguously identifies the payee, and the payee’s PSP must have that same element in its internal system. On request, the payee’s PSP then checks whether the IBAN and identifier match. The regulation lists a fiscal number, an EUID and an LEI as examples; it defines an LEI as a unique alphanumeric reference code based on ISO 17442 and assigned to a legal entity.

Displaying an LEI on an invoice does not establish that either PSP can perform this check. Article 5b(2) requires the verification service to be provided to payment service users free of charge. Under Article 5c(5), verification must not prevent a payer from authorising the transfer, even where the reported details do not match.

How the EPC scheme reports an identifier check

The European Payments Council (EPC) VOP Scheme Rulebook v1.1 was issued on 16 March 2026 and has been effective since 20 September 2026. It describes an identification-code check as an alternative to the name check for a legal person where the requesting PSP offers the channel and the code is available in the responding PSP’s system. Its examples include an LEI, a VAT number and a fiscal number.

The requesting PSP can consult the EPC Directory Service to establish whether the responding PSP supports identification-code checks. That does not show that every PSP supports LEI checks. The EPC VOP API Specifications v1.1.1 assign these responses to an identification-code and IBAN check:

• MTCH: match.
• NMTC: no match.
• NOAP: matching not possible.

The specifications state that the LEI field follows ISO 17442. These codes describe an identifier check; a general VoP result alone does not establish that an LEI was submitted or checked. The ECB describes payer-facing results more broadly as “match”, “close match”, “no match” or “other”.

Bulk payments, authorisation and liability

Article 5c(6) requires PSPs to let payment service users that are not consumers opt out of verification when submitting multiple payment orders as a package. Those users must be able to opt back in at any time. A Liège SME paying suppliers in batches can therefore ask its PSP how that choice is made before changing its payment process; the provision does not require the business to opt out.

A mismatch calls for review before authorisation, not an assumption that the PSP will block payment. Article 5c(8) addresses liability in defined circumstances: a PSP that has fulfilled Article 5c is not liable for executing a transfer to an unintended payee on the basis of an incorrect unique identifier. If the payer’s PSP fails to comply with Article 5c(1) and that failure results in a defectively executed transaction, it must refund the payer without delay. Discuss the facts of a disputed transfer with the PSP or an adviser.

Compliance dates and next steps

PSP location	Article 5c compliance date	Status on 18 October 2026
Euro-area Member States, including Belgium	9 October 2025	Applicable
EU Member States whose currency is not the euro	9 July 2027	Will apply

These are the PSP deadlines in Article 5c(9). The EPC rulebook’s effective date is separate from them. To review your company’s payment details:

• Check names and IBANs: compare the details you give customers with those used in payment records, and investigate a new account number on an invoice.
• Ask about the LEI route: find out whether the payer’s PSP offers an identifier channel and whether the PSP holding your account has recorded your LEI.
• Review bulk-payment settings: establish who can choose to opt out and how staff will assess a mismatch or a result that matching is not possible.
• Keep an existing identifier current: check its details and renew an LEI when needed.

If the company does not have an LEI and wants to make one available for an identifier check, it can apply for an LEI. The LEIFast Belgium blog covers related regulatory topics. Before relying on an LEI for payment verification, ask the relevant PSPs which channel is available and which identifier they hold.