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Belgium

Frequently Asked Questions

General​

What is required for testing and development?

Testing and development require access to a dedicated testing environment to ensure proper integration and validation.

Requirements

Testing and development require access to a test FDM.

This can be provided as:

  • a virtual FDM, or
  • a test hardware FDM

Access to test systems

Access to the test devices is provided via the Zwartedoos SDK.

The SDK must be:


Important limitation

Test FDMs are:

  • intended solely for development and integration testing
  • not allowed to be used in production environments

Certification​

Can we roll out a critical bug fix immediately, or do we need to wait for FPS Finance approval?

When releasing updates to a certified POS system, it is important to understand when approval from FPS Finance is required.

Explanation

  • If the update is only to correct a critical bug:
    • it may be applied immediately
    • this is an exception to the normal pre-approval process
  • For non-critical changes:
    • FPS Finance must decide within the statutory review period
    • the update may only be commercialized after approval
Does any change to a certified POS require recertification?

Changes to a certified POS system may affect its compliance status and therefore require review by the responsible authority.

Explanation

  • Changes to an already certified cash register system:
    • require starting a new certification procedure

The extent of the re-certification is determined by:

  • FPS Finance
  • depending on how significant the changes are

Important Requirement

Before introducing a new version, FPS Finance must be notified at least 1 month before commercialization in Belgium.

Is there a cap on functional updates per year?

When managing updates to a certified POS system, there are limits regarding the number of functional changes that can be introduced within a given period.

Explanation

  • Yes. Except for critical bug fixes:
    • updates related to functionalities defined in the decree must be limited to:
    • 12 updates per calendar year
When must changes be reported before releasing a new version?

When making changes to a certified cash register system, it is important to comply with reporting requirements before releasing a new version.

Explanation

  • Changes to a certified cash register system must be reported:
    • at least one month before the new version is marketed in Belgium

Important requirement

  • The notification must be:
    • done in advance
    • submitted to the responsible authority

This ensures that compliance requirements are met before commercialization.

FDM​

Does each cash register system require its own Fiscal Data Module (FDM)?

When setting up fiscal systems, it is important to understand how Fiscal Data Modules (FDMs) are assigned and used.

Explanation

Each cash register system must be connected to its own dedicated Fiscal Data Module (FDM)

This means:

  • An FDM is exclusively linked to a single cash register system
  • It may not be shared between:
    • multiple cash register systems
    • different establishments

Important limitation

  • One FDM = one cash register system
  • Sharing an FDM across multiple systems is not permitted
Does each FDM require configuration by FPS Finance before it can be used?

Before a Fiscal Data Module (FDM) can be used, it must go through a defined setup and registration process with the responsible authority.

Explanation

  • Yes. An FDM must be registered in the FPS Finance GKS e‑service
  • This registration is carried out:
    • by the relevant stakeholders
    • during the production and delivery phases

The FDM is then:

  • linked to a specific cash register system
  • assigned at:
    • enterprise level
    • establishment level

Commissioning process

Upon commissioning:

  • the FDM establishes a secure connection with the:
    • FPS Finance cloud service

During this process:

  • the FDM is verified
  • required certificates are issued
  • necessary fiscal parameters are assigned
Does the FDM need to be in the same network as the EFR in order to work?

The communication between the EFR (Electronic Fiscal Register) and the FDM (Fiscal Data Module) depends on the network configuration.

Explanation

Currently, yes, the FDM must be:

  • in the same network as the EFR
  • reachable for communication between both systems
Does the FDM require an Internet connection?

The Fiscal Data Module (FDM) can operate independently without requiring a permanent internet connection.

Explanation

The FDM does not require a continuous internet connection to function

  • It can:
    • receive transactions
    • sign transactions
    • store transactions locally

While offline the transactions are buffered internally.

Data transmission

When an internet connection becomes available again:

  • the FDM will automatically transmit the buffered data
  • data is sent to the FPS Finance servers

Offline limitation

  • The offline buffering period is limited
  • This period is defined by the financial authority

By default the period can extend up to approximately 10 days.

After this period:

  • the FDM may refuse to sign new transactions
  • until the connection is restored and data is transmitted
How must cloud POS systems handle FDM architecture in Belgium?

Belgian legislation defines specific requirements for the use of Fiscal Data Modules (FDMs), which also apply to modern POS architectures such as browser-based or fully cloud-based systems.

Explanation

Belgian legislation explicitly states that:

  • an FDM may not be shared between multiple establishments
  • at least one FDM per establishment is required

This requirement applies regardless of the POS architecture, including:

  • locally installed POS systems
  • browser-based POS systems
  • fully cloud-based POS systems

Architectural requirement

Even in cloud-based environments:

  • the fiscal component remains bound to a specific establishment

Therefore, the POS architecture must ensure that:

  • all fiscal transactions of an establishment are processed
  • through its dedicated FDM
What happens if the EFR has no connection to the FDM?

A stable connection between the EFR (Electronic Fiscal Register) and the FDM (Fiscal Data Module) is essential for compliant receipt issuance in Belgium.

Explanation

As required by Belgian legislation on registered cash register systems:

  • Receipt issuance depends on a successful response from the FDM
  • This response must include a valid digital signature

If the EFR does not receive this response:

  • the receipt cannot be completed correctly
  • the EFR will return an error

note

A working connection to the FDM is mandatory

Without a valid response:

  • no compliant receipt can be issued
  • the transaction process is interrupted

Where must the FDM be physically located?

The location of the Fiscal Data Module (FDM) is defined by legal requirements and must comply with specific conditions.

Legal requirement

According to Article 59:

  • The FDM must always be:
    • physically located within the business
    • linked to the cash register system

This is required due to the nature and function of the FDM.

Possible locations

The FDM may be physically located at:

  • the address of the establishment (recommended)
  • the administrative address
  • the fiscal domicile of the company
  • any other location within the EU

Important Limitation

An FDM may not be shared between multiple establishments. There must be at least one FDM per establishment.