Psychologist software in Belgium: what it must do

Psychologist software in Belgium is the tool that keeps the patient file required by law, produces your clinical documents and protects this health data under the GDPR. If you are a clinical psychologist working under the first-line (première ligne) agreement, it must also let you note in the file what the INAMI agreement asks for, even though sessions are attested in a separate application.

Before choosing: your practice setting

Your needs depend first on your status. According to the FPS Public Health, every clinical psychologist has needed an accreditation (agrément) from their Community since 1 January 2020, and the visa, an authorisation issued by the FPS, is what allows you to practise. You are then a healthcare professional, subject to the Quality Act and the Patients' Rights Act.

The INAMI number only matters if you work under the agreement. INAMI states that it is assigned when you join one or more mental health networks, and that it is not needed for work outside this agreement. In private practice only, your software has nothing to handle on the INAMI side.

What the law requires, and what the software must allow

The Commission des Psychologues summarises the file rules on its page Le dossier patient (in French). Here is the grid we draw from it. The left side comes from the texts; the right side is our advice for choosing a tool.

• A well-kept, secure file: patients have an undeniable right to a carefully kept and securely stored patient file (Act of 22 August 2002, art. 9 §1). The software: strong password and two-factor login, encryption, backups, automatic lock after inactivity.
• Minimum content: the Quality Act (art. 33) lists the information to include where relevant and within the limits of your competence. The software: a patient sheet and session notes flexible enough to cover your items, without forcing irrelevant medical fields. Details are in our article on the psychologist's patient record in Belgium.
• Electronic form: art. 34 of the Quality Act provides for an electronic file, but according to the Commission no royal decree has been adopted yet. Paper is still allowed. The software: if you go digital, pick a tool that exports, so the future decree is easy to follow.
• Long retention: at least 30 and at most 50 years after the last contact (art. 35). If you stop practising for good, the Commission provides for the file to go to a colleague with the patient's consent. The software: a full export readable without the tool (PDF or text), per patient and for the whole practice, including after your subscription ends.
• Access and copy: the patient may consult the file and get a copy, with an answer within 15 days; data about third parties is excluded (art. 9 §2 and §3). The software: pull out one patient's file in minutes, and spot passages about a third party.
• Personal notes: since 4 March 2024, the Commission states that all personal notes are part of the file the patient can access. The software: be wary of a "private notes" tab sold as hidden from the patient. Legally, those notes are still in the file.
• Processing agreement: the Belgian Data Protection Authority notes that processing must be set out in a contract with mandatory clauses (GDPR art. 28.3), and that the processor may not use another processor without your prior written authorisation. The software: a signed or accepted data processing agreement, with the list of the vendor's own sub-processors (hosting, SMS, email, AI).

For the processing register, breach notification or the DPO question, see our guide to the GDPR in Belgium for psychologists and therapists.

What the first-line agreement changes for your admin

If you work with a mental health network, the model agreement between the network and the psychologist published by INAMI adds specific duties. Those that affect your tools:

• One file per patient: the psychologist keeps an individual patient file for each beneficiary, in line with the Patients' Rights Act (art. 11, 8°).
• The functional assessment: the function of psychological treatment for mild to moderate problems is only reimbursable on the basis of a functional assessment (bilan fonctionnel) (art. 7, 1°), preferably drawn up during or after the first session (art. 5 §3). The text states that the functional assessment belongs to the patient (art. 7).
• What goes in the file: if the patient objects to the GP completing the assessment, the psychologist adds the written refusal to the file (art. 7, 2°). If the patient has no GP, the psychologist notes it in the file and refers them to a GP (art. 7, 3°).
• Contact with the GP: the agreement says there should be communication with the GP who holds the global medical file (DMG), subject to the patient's consent (art. 9, 4°).
• Attestation: the psychologist attests services through the secure web application, using the pseudocodes in annex 1 (art. 11, 9°). This application is provided by the health insurers through the non-profit ASBL IM (art. 13).
• The deadline: attestation must happen by the 5th day of the third month after the month of the service; after that, the session can no longer be billed (art. 13).
• Evidence and accounts: supporting documents are kept in your files, and fees appear under a separate heading in your accounts (art. 13).

In practice: your clinical tool must hold the functional assessment, the written consent or refusal, the note that there is no GP and the letter to the doctor. Attestation goes through the ASBL IM web application. Some practice management software adds a session counter per agreement, but check what it really does. The INAMI first-line page gives an agreement in force since 1 April 2024, and the model agreement runs until 31 December 2026: ask your network which version applies in 2027.

Who does what: splitting tasks between your tools

Here is a realistic split.

• File and session notes: clinical tool or practice software with a file module. Delta: yes.
• Documents (functional assessment, letter to the GP, confirmation of care, reports): clinical tool or word processor. Delta: yes, written in your own wording.
• Calendar, online booking, SMS reminders: scheduling tool. Delta: no.
• Invoices and receipts for private sessions: practice or accounting software. Delta: no.
• Attesting first-line sessions: ASBL IM web application, possibly helped by practice software. Delta: no.
• Accounting, separate heading for fees: accountant or accounting software. Delta: no.

Two examples of tools used in Belgium. According to its website, easyPsy targets psychologists under INAMI agreement: calendar, session notes, session counter per network, pseudocode suggestions, invoices and pre-filled certificates for health insurers; files stored in the European Union (Ireland), with a few services such as SMS and email using providers outside the EU, processor role under article 28 and free export, including after cancellation. Listed prices: Découverte plan at €0, Silver at €19.99 incl. VAT per month, Gold at €29.99 incl. VAT per month. According to its website, Corilus CareConnect Essential offers a patient file that can be shared with other carers, an eHealth connection (MyCareNet, Vitalink), an optional link with the Helena Pro Calendar and optional e-invoicing (€14.19 per month), for €50.20 per month incl. VAT with hosting included; the page says data is "in the Cloud" without naming the country. These are real strengths on the management side. A clinical tool such as Delta sits alongside, for notes and documents.

Fictional example: Camille's setup, a psychologist under agreement

Fictional example. Camille is a self-employed clinical psychologist in Namur. She holds her accreditation and visa, works two days a week with the adult network and the rest of the time in private practice.

• Calendar: an online calendar with reminders, with no clinical notes in it.
• Attestation: every Friday she attests her first-line sessions in the ASBL IM web application. On the first working day of each month, she checks that no session from two months earlier is still pending.
• Private invoices: invoicing software linked to her accountant, with agreement fees under a separate heading.
• File and documents: a clinical tool hosted in Europe, with a signed processing agreement and an export tested at purchase.

What she writes in the file of Julien, 34 (fictional example), after the first session:

• Request: sleep problems and irritability since a reorganisation at work.
• Functional assessment: drawn up in session 1; goals agreed with Julien: get back to a stable sleep pattern, be able to raise his workload with his manager.
• GP: Julien has none. Noted in the file, referral to a GP suggested.
• Consent: Julien agrees to a letter being sent to his future DMG doctor; written consent attached to the file.
• Next session: review the sleep diary.

Camille writes these lines knowing Julien can read them. For consistency she starts from templates, such as our clinical document templates.

12 questions to ask the vendor

• Where is the data hosted, in which country, and with which hosting provider?
• Does that host hold a health data certification or a recognised security standard?
• Will you provide a data processing agreement under article 28 of the GDPR?
• Who are your own sub-processors (SMS, email, AI) and where do they process data?
• Is data encrypted in transit and at rest? Is two-factor login available?
• Can I export the whole practice, and one patient's file, in a format readable without your tool?
• What happens to my data if I cancel, or if you close, given that I must keep it for 30 to 50 years?
• If the tool uses AI: is data used to train a model? Is audio kept?
• Are "private" notes separate from the file? If so, how do I hand them over when a patient asks for a copy?
• Can I attach a signed document (consent, written refusal) to the file?
• For the agreement: what exactly does the tool do (counter, pseudocodes, link with the ASBL IM application), and what is left for me?
• What is the total price including VAT, options and SMS, and is there a commitment?

Common mistakes

• Putting clinical notes in the calendar: the reason for consultation ends up in a tool not designed for health data.
• Believing "private" notes are out of the patient's reach: they have always been part of the file, and since March 2024 the patient can consult them.
• Never testing the export: a file kept for 30 years cannot depend on a single vendor.
• Choosing without a processing agreement: you remain the controller, and it is up to you to ask for it.

Why Delta fits this case

Delta is the clinical assistant for mental health professionals, more than a scribe: it keeps the memory of each patient and drafts your session reports, letters, certificates and assessment reports, while scheduling, invoicing and attestation stay in the tools built for them. For Belgium, data stays in Europe, in France, on infrastructure certified for health data.

In practice, Delta transcribes what is said in session, or you dictate your observations afterwards, and you can add written notes. It generates the session report according to your approach, updates the follow-up summary and drafts letters, certificates and reports in your own wording. The patient's name and identifying details are pseudonymised before the AI, no audio file is kept, and data is never used to train a model. Delta does no scheduling, no invoicing, no INAMI forms and no attestation in the ASBL IM application.

Learn more: Delta for psychologists, what is Delta and, for a wider view of practice software features, our guide to psychologist practice software. A free plan exists (10 sessions per month); Pro costs €35 per month incl. VAT with no commitment, or €29 per month billed annually.

Sources

• Commission des Psychologues, Le dossier patient (Act of 22 August 2002 art. 9, Quality Act art. 33 to 35), accessed 3 November 2026. The Justel site could not be opened: legal articles are cited from this page.
• INAMI, model agreement between the mental health network and the clinical psychologist or orthopedagogue (in force 1 April 2024, valid until 31 December 2026).
• INAMI, providing first-line psychological care through a mental health network.
• FPS Public Health, Clinical psychologists (accreditation and visa).
• Data Protection Authority, Notions of controller and processor (September 2018).