Mortgage refinancing in Belgium 2026: free at the same bank?

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📅 Last updated: 17 May 2026
 ·  ⏱ Reading time: 11 min
 ·  🏷 Topic: Mortgage loan, internal vs external refinancing, Law of 3 May 2024
 ·  🇧🇪 For: Belgian homeowners with an existing mortgage loan

In 2024, the average Belgian mortgage interest rate for a 20-year loan was around 3.5% to 3.7%. By end of April 2026, the Belgian mortgage interest rate for a new residential mortgage loan at a fixed rate was typically between 3.2% and 3.4% for a 20-year term (NBB (National Bank of Belgium) MIR statistics for new loans, stat.nbb.be, accessed 2026-05-17; market barometers from Immotheker Finotheker and Cofidis.be confirm 3.37% as the current market level). Those who took out a loan in 2022 or 2023 at 3.8% or more are now looking at a rate gap of 40 to 60 basis points (hundredths of a percentage point) — a range just below or right at the 1 percentage-point threshold that Wikifin uses as a rule of thumb, which underlines the importance of an accurate personal calculation.

Until June 2024, every refinancing — whether with your own bank or a competitor — required a reinvestment fee (also known as an early-repayment fee or three-month-interest penalty) of three months’ interest plus a file fee, and in the case of switching to another bank, also notarial costs for the old release of mortgage and the new mortgage deed. The Law of 3 May 2024 closed the first of those cost items for borrowers who stay with the same bank. Since 10 June 2024, your lender may no longer charge a reinvestment fee for an internal refinancing, and the file fee is capped at €175. The question for 2026 is no longer “can I refinance”, but “is it worth it — and which path do I choose?”.

This article explains the new rules, provides the breakeven calculation to help you decide, and lists four pitfalls that undermine the ‘free’ promise in practice.

What changed since 10 June 2024?

The Law of 3 May 2024 containing various provisions concerning the economy (I) was published in the Belgian Official Gazette (BS) on 31 May 2024 (numac 2024005080) and entered into force on 10 June 2024, as explicitly stated in the law itself. Article 17 amends article VII.145 of the Code of Economic Law (WER) (internal refinancing via addendum); article 18 inserts § 1/1 into article VII.147 WER (right to switch for bundled insurance).


The new regime has three pillars, as summarised by FPS Economy (accessed 2026-05-17) and confirmed in the news.belgium.be communication (federal communication; HTTP 403 bot-block — open in browser; accessed 2026-05-17):

  1. No reinvestment fee for internal refinancing. If your bank adjusts the interest rate (and/or term) on your existing loan, it may no longer charge three months’ interest. For an external switch — to another bank — that fee remains legally possible.
  2. File fee capped at €175. That is half of the statutory maximum of €350 for a new credit agreement. The regulation draws that distinction because an internal adjustment is administratively lighter than a new dossier.
  3. Adjustment via addendum, not via a new contract. When your bank only changes the interest rate (or the term, or both), it must do so by an addendum (avenant) to your existing agreement — not by drawing up a new credit agreement. That administrative detail is what disables the reinvestment fee and the higher file fee.

The specific amounts (€175 and €350) were established by the Royal Decree of 27 September 2023 (BS 10 October 2023, numac 2023045896; in force 1 January 2024), which implements articles VII.141 § 2 and VII.145 sixth and seventh paragraph WER. The Law of 3 May 2024 subsequently added the addendum mechanism and the prohibition of the reinvestment fee.

What the law does not cover

Two common situations fall outside the new regime, as shown in the explanatory memorandum to the law and the analysis by Test-Aankoop (accessed 2026-05-17; source in Dutch):

  • You want to increase the borrowed capital (e.g. to finance a kitchen or solar panels). That is not an adjustment but a new loan — three months’ interest + full file fee + possibly a new mortgage registration.
  • You want to temporarily suspend interest repayment (e.g. paying no capital for a few months). That also requires a new credit agreement, not an addendum.

In other words: only those who adjust the interest rate or the term on the existing capital benefit from the new preferential scheme.

When is refinancing financially worthwhile?

Wikifin (source in Dutch — no English version available; accessed 2026-05-17), the financial education portal of the FSMA, sets out the classic rule of thumb: refinancing is generally only worthwhile if:

  • the difference between your current interest rate and the market rate is at least 1 percentage point, and
  • you have at least ten years of remaining term on your loan.

The logic: during the first half of a mortgage, you mostly pay interest, little capital. The longer your remaining term, the more interest you still have to pay and the more a lower interest rate ultimately yields. An interest rate gap of 0.5 percentage points on a loan that has five years left rarely offsets the transaction costs.

Concrete calculation example for 2026

Assume: a couple took out a mortgage of €250,000 for 25 years in 2023 at 3.80%. In May 2026, €215,000 is still outstanding and 22 years remain. An internal refinancing can lower the interest rate to 3.00%.

Scenario Monthly payment Total remaining interest One-off cost
Keep current loan (3.80%) €1,203 ± €102,600 —
Internal refinancing (3.00%, via addendum) €1,113 ± €79,000 €175 file fee

| External refinancing to new bank (3.00%) | €1,113 | ± €79,000 | 3 months’ interest + release of mortgage + new mortgage deed + file fee ≈ €4,000–€7,000 |


Gross saving over the full term: approximately €23,600 in saved interest (€102,600 − €79,000). With internal refinancing, almost all of that remains (cost: €175). With external refinancing, €4,000 to €7,000 quickly disappears in one-off costs — still a net gain, but the breakeven shifts by years. The figures are illustrative; calculation tools make a personalised simulation.




Decision tree: internal or external refinancing? Flowchart visualising the choice between internal and external refinancing. Rate gap ≥ 1 pp and ≥ 10 years remaining? yes First: ask your own bank offer OK no offer or poor offer Internal refinancing via addendum · €175 · no reinvestment fee External refinancing new deed · 3 mths interest · ≈ €4,000–7,000
Decision tree — internal vs. external refinancing in Belgium 2026.

Step-by-step: internal refinancing with your own bank

  1. Gather your loan file. Find your credit agreement, note the outstanding balance, the current interest rate, the remaining term, and the next interest-rate revision date (for a variable-rate formula).
  2. Request a market reference. Compare your interest rate with the average market rate — the NBB publishes monthly interest rate statistics — or request a no-obligation simulation from two to three competitors. That simulation costs nothing and gives you a credible comparison figure to take back to your own bank.
  3. Write to your bank with a concrete proposal. Send a registered letter or secure message: “I am requesting a revision of my interest rate under the scheme of article VII.145 WER as amended by the Law of 3 May 2024. My reference is a comparable offer elsewhere of X%.” That immediately shifts the conversation to the new legal framework.
  4. Critically evaluate the counter-proposal.

Your bank is not legally required to offer you the lowest market rate — it is free to set its internal interest rate. This is not a statutory obligation but follows from the contractual freedom of the lender (see also Hypotheekwinkel.be as market commentary; source in Dutch). If you receive an offer that is only halfway between your current rate and the market rate, the external option is probably financially better, despite the higher transaction costs.

  1. Request a written addendum. Accept only when you receive an addendum (avenant) — not a new credit deed. The invoice may only show “file fee max €175”, without a reinvestment fee. Also check that no “miscellaneous administrative costs” or “study fees” are billed alongside the €175.
  2. Keep the addendum. Add it to your original credit agreement. The mortgage registration remains the same — no new notarial intervention required.

External refinancing — what does it really cost?

If your own bank makes no reasonable counter-proposal, external switching remains an option. That is a new credit agreement, with the associated costs. According to hoeveelkostmijnhuis.be (source in Dutch) and the checklist on Wikifin (source in Dutch — no English version available; accessed 2026-05-17), the following items are involved:

Cost Amount (order of magnitude, 2026) Legal basis / note
Reinvestment fee to old bank Maximum 3 months’ interest on the repaid capital art. VII.147 WER (cap remains)
Release costs of old mortgage ± €600–€1,500 (notarial fee + deed costs) Notarial Royal Decree tariff — see notaris.be (source in Dutch)
New mortgage deed + registration duty 1% registration duty + notarial fee on the registered amount Federal registration duty for mortgage registration
File fee at new bank Up to €350 (statutory maximum for new credit agreement) art. VII.141 WER + Royal Decree of 27 September 2023 (in force from 1 January 2024)
Valuation costs ± €200–€500 Bank may require a new appraisal
Adjustment of outstanding-balance insurance Variable; sometimes freely transferable, sometimes new medical underwriting Depends on the policy (see below)

Total: easily €4,000 to €7,000 for an average loan, sometimes more if the mortgage registration needs to be extended. External refinancing is therefore truly worthwhile only when the rate gap is large and the remaining term is long.

Outstanding-balance insurance: the silent obstacle

Many borrowers forget that their outstanding-balance insurance (mortgage protection insurance) is often linked to the loan file at their current bank. When switching you can:

  • transfer the policy to the new bank, often without new medical questions, provided the policy allows it. For some policies this works — for others, particularly older or medium-term policies, it does not;
  • take out a new outstanding-balance insurance with the new bank, with new medical underwriting. Those who have become older or less healthy in the meantime may then face dramatically higher premiums or even an exclusion.

This point is sensitive: there is no statutory right to transfer an outstanding-balance insurance in the event of an external switch. What the law does regulate (art. 18 Law of 3 May 2024, § 1/1 art. VII.147 WER): those who hold an outstanding-balance insurance as a bundle package during the first third of the term have the right to switch insurer afterwards while retaining the conditional interest rate discount — a right to switch for bundled insurance, not a transfer right in the context of a bank switch. The FSMA has expressed as a policy wish that consumers should be able to keep their policy, but this has not yet been codified as a hard right for external refinancing. Ask about this point explicitly before finalising an external switch.

Four pitfalls that undermine the ‘free’ rule

The Law of 3 May 2024 does not apply automatically. In the following four situations you lose the benefit of the addendum and fall back on the ‘most expensive’ route:

  1. You increase the capital. If you want to borrow an additional €30,000 on top of your existing loan for a renovation, that is not a revision but a new loan. Three months’ interest + up to €350 file fee + possibly a new mortgage registration.
  2. You temporarily suspend interest repayment. Those who experience payment difficulties and ask their bank to collect no interest for a few months fall outside the “rate revision” category. In that case, ask about a deferral or moratorium arrangement — which has its own conditions — and not about refinancing.
  3. You sign a new credit deed instead of an addendum. Some bank branches offer, out of habit or administrative convenience, a new credit agreement instead of the legally required addendum. That alone activates the old reinvestment fee and the full €350 file fee. So always check whether the document says “addendum” / “avenant”, and not “new credit agreement”.
  4. You extend or shorten incorrectly. In addition to the interest rate, you may also change the term via an addendum. But if the bank takes the opportunity to also adjust other material conditions (collateral, formula), it can argue that it is a new agreement. Limit the adjustment to interest rate and/or term.

Practical checklist

  • [ ] Calculate your current rate gap against market references — at least 1 percentage point for it to be worthwhile.
  • [ ] Check your remaining term — minimum ten years for the breakeven to work.
  • [ ] Request a free simulation from two to three competitors (commits you to nothing).
  • [ ] Write to your own bank with an explicit reference to the Law of 3 May 2024 and the scheme under article VII.145 WER.
  • [ ] Insist on an addendum, not a new credit agreement.
  • [ ] Check that the invoice shows only “file fee” ≤ €175 and no reinvestment fee.
  • [ ] Find out how an external switch affects your outstanding-balance insurance — especially if you are older or less healthy than at the time of the original underwriting.
  • [ ] Draw up a breakeven table (internal gain vs external net gain after all costs) before making a final decision.
  • [ ] Keep all correspondence and the signed addendum with your credit agreement.


Sources & further reading

Primary sources (legislation and government):

Secondary sources (educational portals):

Market commentary (read critically):



Read also: the abolition of the federal mortgage interest deduction

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