Regulation (EU) 2022/2554, the Digital Operational Resilience Act, applies from 17 January 2025. The FSMA’s notice of 17 February 2026 records what that date produced in Belgium: in 2025, companies subject to DORA filed a register of agreements with third-party ICT providers, and in 2026 only a limited set of companies must file again. An unchanged register can be confirmed. A changed register is updated or replaced. A general counsel at a Brussels financial firm who still has an ICT contract without the register fields is not waiting on a strategy paper. The supervisor has already run the exercise once.
The cybersecurity calendar sits next to it, and it is not the same statute. The Centre for Cybersecurity Belgium states that the Law of 26 April 2024, transposing Directive (EU) 2022/2555, entered into force on 18 October 2024. Entities at assurance level Essential had until 18 April 2026 to obtain a Basic or Important verification, and they have until 18 April 2027 to obtain Essential certification from an accredited conformity assessment body. The 18 April 2026 verification date has passed. The live date for an Essential entity is 18 April 2027. DORA is the sector rule for financial entities. The NIS2 law is the horizontal rule for the entities the Centre has in scope. A brief that treats them as one “cyber” hire is two files.
Competition demand is a published list, not a mood. The Belgian Competition Authority’s priorities paper for 2026, published on 27 February 2026, names five sectors: agri-food, digitalisation and telecommunications, healthcare, basic services, and sport, media and entertainment. The same paper records a public consultation, in press release 42/2025 of 15 October 2025, on fiber commitments offered by Proximus/Fiberklaar and Telenet/Wyre, and an ex officio investigation, in press release 33/2025 of 31 July 2025, into the draft cooperation between Proximus and Orange Belgium on fiber in Wallonia. A project counsel seat on one of those files is a dated response. It is not a standing competition department.
The AI Act calendar moved in 2026, and the move matters for what a Brussels company should staff now. The European Commission states that the Act entered into force on 1 August 2024 and applies from 2 August 2026, with exceptions: prohibited practices and AI literacy from 2 February 2025, and governance plus general-purpose model obligations from 2 August 2025. Regulation (EU) 2026/1744, in force on 27 July 2026, moved Annex III high-risk rules to 2 December 2027 and Annex I high-risk rules to 2 August 2028. A general counsel who briefed “high-risk compliance by August 2026” briefed a date the amendment removed. The work that did land on 2 August 2026 is transparency, literacy, and the start of enforcement. The high-risk build is a 2027 and 2028 file.
The bars that can take the independent version of that work are counted, and they are two orders, not one. The French-language Brussels Bar, on its own figures page, lists 3,657 lawyers on the roll as of 1 July 2026, plus 937 trainees, 531 members of other EU bars, and 136 lawyers from bars outside the EU. The Dutch-language order, on its own page, counted 4,133 lawyers on 26 March 2026: 2,755 on the tableau, of whom 2,661 have a principal office and 94 a branch, plus 838 trainees, 244 on the EU list, 141 on the B list, and 155 honorary lawyers. Those two totals are not added here. The roll and the tableau are different cuts from the trainees, the EU lists, and the honorary list. The Institute of Company Lawyers, established by the Law of 1 March 2000, states that it has more than 2,300 members. That is the employed bar. It is not a slice of either roll.