Filing Pillar 2 returns in Belgium? Four updates to know

The past few days have brought four important changes to Belgian Pillar 2 compliance:

• More time to file: the deadline for the FY2024 Pillar 2 compliance requirements is pushed back again, to 16 November 2026.
• QDMTT returns now legally due 15 months after year-end, in line with the other Pillar 2 filings.
• A new penalty regime, with tiered fines.
• DAC9 is now part of Belgian law, which makes central GIR filing within the EU legally possible.

The first update was announced by the Belgian tax authorities on 29 October 2026. The other three come from the law of 25 October 2026, published in the Belgian Official Gazette on 30 October 2026. This law transposes Council Directive (EU) 2025/872 (DAC9) and amends the Belgian Pillar 2 law of 19 December 2023.

1. Extension: Pillar 2 filings due by 16 November 2026

The MyMinfin filing application is currently unavailable following a cyberattack. As a result, the Belgian tax authorities announced on 29 October 2026 that Pillar 2 filers get extra time. The QDMTT return, the IIR top-up tax return and the GIR (notification) that were legally due on 31 October 2026, as well as filings that were moved to 31 October 2026 by the earlier extension, can now be filed in time until 16 November 2026.

Example: for a calendar fiscal year 2024, the QDMTT return is now due by 16 November 2026.

2. QDMTT return: from 11 to 15 months

Belgium had originally set the QDMTT return deadline at 11 months after year-end. That was well ahead of the GIR, the IIR/UTPR returns and the 15-month deadline used in most countries. The new article 52 of the Belgian Pillar 2 law now sets the deadline at the last day of the 15th month after year-end (for fiscal years on 31 December 2024 at the latest, the deadline becomes 18 months). All Belgian Pillar 2 filings now share one timeline.

Example: for a calendar fiscal year 2025, the QDMTT return is now due by 31 March 2027 instead of 30 November 2026.

3. A clearer penalty regime, with a royal decree still to come

The law also makes the Belgian Pillar 2 penalty regime clearer. The old article 61 of the Belgian Pillar 2 law provided a single range of EUR 2,500 to 250,000 for any infringement. The new article 61 sets separate fines for each type of infringement, with higher amounts for fraudulent intent or intent to harm:

Fines may be waived if there is no bad faith. A royal decree will set the exact scale, taking into account how serious the infringement is and whether it is repeated.

4. DAC9: Belgium catches up

Belgium was late in transposing DAC9. The deadline was 31 December 2025, and in July 2026 the European Commission sent Belgium a reasoned opinion. With this law, Belgium now has the legal basis for automatic GIR exchange within the EU. In practice, a group can file its GIR once, centrally, through its ultimate parent entity or designated filing entity. Each Member State then receives only the sections relevant to it. Belgium will exchange GIR information for the first time no earlier than 1 December 2026.

Any questions?

We are happy to help you with the above and/or the preparation, review and filing of your Belgian Pillar 2 compliance deliverables. Please reach out to your usual PwC contact, or contact Pieter Deré, Koen De Grave or Maxim Allart.