Belgium
FAQ
General
What is required for testing and development?
Testing and development requires access to a test FDM. This can be provided either as a virtual FDM or as a test hardware FDM. Access to these test devices is available via the Zwartedoos SDK, which must be obtained from Zwartedoos.
Test FDMs are intended solely for development and integration testing and cannot be used in production environments.
FDM
Does each cash register system require its own Fiscal Data Module (FDM)?
Yes. Each cash register system must be connected to its own dedicated Fiscal Data Module (FDM). An FDM is exclusively linked to a single cash register system and may not be shared between multiple cash register systems or establishments.
What happens if the EFR has no connection to the FDM?
As required by Belgian legislation on registered cash register systems, receipt issuance depends on a successful FDM response containing a valid digital signature. If such a response is not received, the EFR will return an error.
Does the FDM require an Internet connection?
The Fiscal Data Module (FDM) does not require a permanent internet connection to operate. It can continue to receive, sign, and store transactions while offline by buffering them internally.
When an internet connection becomes available again, the FDM will automatically transmit the buffered data to the FPS Finance servers.
The offline buffering period is limited and configured by the financial authority. By default, this period can extend up to approximately 10 days, after which the FDM may refuse to sign new transactions until data transmission is restored.
Where must the FDM be physically located?
According to Article 59, due to its nature and function, the Fiscal Data Module (FDM) must always be physically located within the business and linked to the cash register system.
This may be at:
- the address of the establishment (recommended)
- the administrative address
- the fiscal domicile of the company
- any other location within the EU
An FDM may not be shared between multiple establishments - at least one FDM per establishment is required.
Does the FDM need to be in the same network as the EFR in order to work?
Currently, yes.
Does each FDM require configuration by FPS Finance before it can be used?
Yes. An FDM must be registered in the FPS Finance GKS e-service by the relevant stakeholders during the production and delivery phases and linked to a specific cash register system at enterprise and establishment level. Upon commissioning, the FDM establishes a secure connection with the FPS Finance cloud service to be verified and receive the required certificates and fiscal parameters.
Certification
Does any change to a certified POS require recertification?
Changes to an already certified cash register system require starting a new certification procedure, with FPS Finance deciding how much re-testing is needed. Notify FPS Finance ≥ 1 month before commercialization of the new version in Belgium.
When must changes be reported before releasing a new version?
Changes to a certified cash register system must be reported at least one month before the new version is marketed in Belgium.
Can we roll out a critical bug fix immediately, or do we need to wait for FPS Finance approval?
If the update is only to correct a critical bug, it may be applied immediately (it’s the exception to the normal pre-approval process). For non-critical changes, FPS Finance must decide within the statutory review period and the update may only be commercialized after approval.
Is there a cap on functional updates per year?
Yes. Except for critical bug fixes, updates related to functionalities defined in the decree must be limited to 12 updates per calendar year.