The Nagoya Protocol on Access and Benefit-sharing is the latest protocol to the Convention on Biological Diversity (CBD). Its implementation can lead to two fundamentally different processes: a market-oriented self-regulatory approach, which emphasizes the self-regulating capacity of the economic actors involved, or a normative institutionalist approach, which focuses on the norms and formal rules of institutions that not only support and frame, but also shape and constrain the actions of the players acting within them. This paper analyzes the challenges related to the implementation of the Nagoya Protocol in the specific case of Belgium, and evaluates the possibility of moving from a self-regulatory to an institutional approach of implementation, which we argue is necessary to achieve the objectives of the Protocol. This move is analyzed in the specific multi-level governance context characterizing the Nagoya Protocol, which has a natural tendency towards a market-oriented self-regulatory approach.