Directive (EU) 2025/25 in Belgium: transposition status

Status: one step taken, nothing notified, nothing in force. On 3 July 2026 the Belgian federal Council of Ministers approved a preliminary draft law transposing one point of the Directive: Article 2, point (5), which is the preventive-control rule [Belgian Council of Ministers decision of 3 July 2026Implementation note]. That draft goes to the Council of State for an opinion and then through Parliament. It is not law. Belgium has communicated no measure on the EUR-Lex national transposition record [EUR-Lex transposition notifications for Dir. 2025/25Official data], and nothing has been published in the Belgisch Staatsblad / Moniteur belge that we have read.

What the 3 July 2026 draft covers

The Council of Ministers' own announcement says the draft transposes Directive (EU) 2024/2810 on multiple-vote share structures, and Article 2, point (5) of Directive (EU) 2025/25, described there as the prior control of the instrument of constitution and amendments to the articles of association [Belgian Council of Ministers decision of 3 July 2026Implementation note].

That description matches the Directive. Article 2, point (5) replaces Article 10 of Directive (EU) 2017/1132 with a new Article 10 on preventive control. Member States must provide for preventive administrative, judicial or notarial control, or a combination, of the instrument of constitution and statutes of companies listed in Annexes II and IIB, at formation and on any amendment [Directive (EU) 2025/25, Art. 2(5), inserting Art. 10(1)]. Annex IIB is the partnership annex. The Belgian entries in it are the vennootschap onder firma / société en nom collectif and the commanditaire vennootschap / société en commandite, and those are the two forms the announcement names.

The practical change in Belgium is narrow and specific. Companies requiring an authentic deed already go through a notary. A VOF/SNC or CommV/SComm can in principle be formed by private deed, with no prior check. The draft closes that gap.

What the draft does not cover

Nothing else in the Directive. The announcement mentions no EU Company Certificate, no digital EU power of attorney, no once-only principle, and no register interconnection [Belgian Council of Ministers decision of 3 July 2026Implementation note]. Those are Articles 16b to 16g and they still have to be transposed separately, by 31 July 2027.

The announcement also does not say which authority will carry out the preventive control, what has to be filed, or what it will cost. The text of the draft has not been published. Until the bill is tabled in Parliament there is nothing further to read.

Why this page still says nothing is in force

A preliminary draft approved by the Council of Ministers is a government decision to send a text to the Council of State. It creates no obligation on anyone. Three things would have to happen before Belgium's row on the transposition table changes: Parliament adopts the law, it is published in the Belgisch Staatsblad / Moniteur belge, and we read it there. Belgium notifying the measure to the Commission would move the row to "notified", which is a weaker statement than "verified" and is not the same thing as complete transposition.

The dates that bind Belgium regardless

These come from the Directive itself and do not depend on national action:

National law must cite the Directive when the transposing measure is officially published [Directive (EU) 2025/25, Art. 4(4)]. That requirement is how this page will catch it.

What companies in Belgium should do

Nothing is obliged yet. If you run a VOF/SNC or a CommV/SComm, the one thing worth knowing is that forming or amending one by private deed is on its way out, and the timing depends on the parliamentary calendar rather than on the 2027 deadline. Beyond that, what is worth doing now — checking your register entries, mapping who may act for you, ignoring premature "compliance" offers — is the same in every Member State and is set out in What to do, by when. The EU-wide instruments themselves are covered in the power of attorney explainer and the certificate explainer.

How this page gets updated

The daily watch re-checks the EUR-Lex transposition record [EUR-Lex transposition notifications for Dir. 2025/25Official data] and the Belgian federal government's own announcements. The next step to watch for is the Council of State opinion, then the bill reaching the Chamber. When Belgium notifies measures, this page reports it within days, and moves to "verified" only once we have read the measure in the official gazette. If you know of a published Belgium measure we have missed, send the gazette reference to hello@eudipoa.com. The full 27-country picture: the transposition table.