James
James
  • Home
  • News
  • What will 2026 bring for you as an employer?

News |  

16.12.2025

What will 2026 bring for you as an employer?

Have a question about this article?
Contact us here!

The end of the year is the time to look ahead. As of 2026, the socio-legal landscape will change dramatically. All kinds of European and federal measures bring new obligations and opportunities for you as an employer: from wage transparency and duty of care to adapted rules on overtime, flexi-jobs and mobility budget.

In this article, we compile the most important news, so you can start the new year with knowledge of what's to come and get your business ready for what's to come.

 

1. Wage transparency: ready to open up?

Due to a European directive to be issued no later than June 7, 2026 must be converted into Belgian law, you as an employer will have to be open about the remuneration structure within your company. Concretely, the following obligations imposed:

  • Procurement of transparency regarding pay scales and the criteria that determine wages.
    • The criteria used should objective and gender neutral be, since one of its aims is to address the gender pay gap.
  • Responding to questions of employees and applicants regarding wages:
    • Employees have the right to request pay data for similar positions;
    • Applicants have the right to know in advance which pay and which pay scale they should expect
  • Periodic report on the pay structure and possible pay gaps:
    • For enterprises >150 employees start this commitment on June 7, 2027;
    • For enterprises >100 employees start this commitment on June 7, 2031;
    • For enterprises with <100 employees the directive does not impose a reporting requirement. However, it does leave the choice among member states, allowing Belgian lawmakers to introduce the decision as yet.

Although this has yet to be translated into Belgian regulations, it is already clear: all this will be a strong impact have on your remuneration policy as an employer. With the new year approaching, this is the time to think ahead and proactive steps. This is how you turn a commitment into a strategic asset in the ‘war for talent.

 

 

2. Duty of care: how to avoid costly surprises?

As of Jan. 1, 2026, the duty of care becomes a reality. Do you as a (sub)contractor works in immovable state out and work directly with a party that is non-EU citizens (employees and/or self-employed workers)? Then as of 2026 you are partly responsible for the legality of that employment/collaboration.

 

What does this mean?

  • You should provide certain documents to request With your direct subcontractor (e.g. signed cooperation agreement, passport, residence permit, LIMOSA, A1, work permit, etc.).
  • Are the documents not delivered on time or are incomplete? Then you should ask for the missing data in order.
  • Does your direct subcontractor not respond to this? Then you have the obligation to pay the social inspection informed about this.

The government is currently developing a online application, which will collect the necessary data through other databases (e.g. NSSO). While waiting for the availability of this application, you should provide the documents request directly with your subcontractor.

 

Are you not fulfilling these obligations?

Then here will also sanctions in return:

  • Either a prison sentence from 6 months to 3 years and/or a criminal penalty from 4,800 to 56,000 euros per person involved;
  • Either a administrative fine from 2,400 to 28,000 euros per person involved.

 

Want to know more about this? Then be sure to check out our previous article: Stricter rules around employment of non-EU citizens in construction sector from 2025.

Or view the information website of the Flemish Government. You will find sector-specific videos and a checklist with clear roadmap.

 

3. Possible extension of innovation premium until December 31, 2026.

It looks like it will also be possible next year to award an innovation bonus to creative workers who have a new and innovative idea have made. No social or tax contributions are due on this premium.

 

 

4. Federal coalition agreement unraveled: what steps to take when?

A number of social law measures from the coalition agreement are already in the pipeline and may already have a impact have on you as an employer.

Because the final legal texts have not yet been published, some changes may not take effect on Jan. 1, but may follow later. In any case, the direction is fixed.

 

Overview of changes during 2026:

 

Overtime  Planned changes: 

  • Doubling of the number relance-overtime  
    • These overtime hours are fully exempt from social security and BV.
    • Going from 120 to 240 hours per year.
  • Permanent arrangement for 180 overtime with tax discount 
    • NSSO contributions are due for these overtime hours, but a tax rebate applies. 
    • The temporary arrangement for 180 overtime hours with tax reduction will be made permanent.
    • Distribution: 120 ‘regular’ voluntary overtime and 60 ‘regular’ involuntary overtime.
  • Additional flexibility for hospitality industry 
    • If a registered cash register system is used, the maximum is increased to 450 voluntary overtime hours per year, of which 360 are relance overtime.
  • Voluntary overtime will be reserved for: 
    • Full-time employees 
    • Part-time employees working part-time for at least 3 years - provided there is a temporary increase in work.

 

 

State of affairs:  

  • The current system has been extended until 31/12/2025. Logically, therefore, the planned changes should take effect from 1/01/2026.
  • However, the federal government approved a preliminary draft law stating that the anticipated changes will take effect on 1/04/2026.
  • Hhe current system is being additionally extended until 31/03/2026 in order to bridge the period until the new system comes into force.
Flexi-jobs  Planned changes: 

  • The maximum allowed flexi hourly wage in the hospitality rises from 17 to 21 euros.  
  • The annual limit For unlimited additional earning increases from 12,000 to 18,000 euros.
  • For full-time employees, the ban on employment at associated companies deleted.
  • Expansion of flexi-jobs to all sectors (with ability to opt out) 

 

State of play: 

  • The above changes were confirmed in the budget agreement of Nov. 24, 2025. The expected effective date is January 1, 2026. An exception applies to the extension of flexi-jobs to all sectors: this change is provided for the summer 2026. However, there is no concrete date yet. 
  • Also for this topic, no final legal texts are available as of today, so there is a chance that the changes may not be made until later in 2026 will go into effect.  
Indexation of wages  Planned changes: 

  • Introduction of cents index jump:
    • Employees receive no index on the portion of their gross pay > 4,000 euros (in 2026 and 2028) 
    • Half of this notional index does have to be paid: this amount should be transferred to the state treasury.

 

State of play: 

  • These changes were confirmed in the Nov. 24, 2025 budget agreement. The government plans a first ‘disguised’ index jump in 2026.
  • There are no final legal texts yet, so the entry into force possibly not until later in 2026 follows.
  • Today, the plans are at loose screws: for example, wages in PC 200 - one of the largest joint committees in our country - are indexed as early as January. In other sectors, this happens later in the year. Thus, if the new rules do not come into effect until later in 2026, there is a risk of a difference in treatment to arise. Also, for the time being, no account was taken of sectoral differences: some sectors index only once a year, others several times a year to even monthly. For now, it remains coffee-gazing: without final legal texts, it is unclear how and when these measures will take effect.
Mobility Budget  Planned changes: 

  • Would mandatory be from 1/01/2026 For employees who are entitled have on a company car.

 

State of play: 

  • The introduction of the mobility budget is postponed: SMEs with 15 to 50 employees get postponement until January 1, 2028. All other businesses must be in rule against no later than January 1, 2027.
  • The exact interpretation and practical application remain for now unclear.
Meal vouchers  Planned changes: 

  • Increasing the maximum employer contribution from 6.91 to EUR 8.91 by check from 1/01/2026 

 

State of play: 

  • The required legislation on social field has already been published: 
    • The maximum employer contribution for meal vouchers exempt from NSSO contributions rises to 8.91 euros per check from Jan. 1, 2026.
  • For a full entry into force, it is still wait on: 
    • Legislation regulating the modalities for tax deductibility (4 euros instead of 2 euros deductible); 
    • Legislation excluding meal vouchers from the salary standard.
Extension of withholding obligation  Planned changes: 

  • The withholding obligation - which already exists today for tax and NSSO debts - is extended to social contributions from independent (sub)contractors.

 

State of play: 

  • This extension will apply from mid-2026 - the exact date is not yet known.
Federal Learning Account (FLA).  Planned changes: 

  • Abolition of the FLA.

 

State of play: 

  • The FLA was delayed until 1/01/2026 with a view to its abolition.
  • On 10/12/2025, the bill i.v. abolition approved.
Trial clause  Planned changes: 

  • During the first six months of the employment contract, employer and employee may terminate the contract with a notice period of only one week.

 

State of play: 

  • The coalition agreement stipulates that the trial period will end no later than 31/12/2026 would be reinstated. 
  • No final legal texts have been published yet, so it is most likely only later in 2026 will go into effect. 
Disability  Planned changes: 

  • A procedure should be provided in the labor regulations outlining how to contact with incapacitated workers will be preserved; 
  • Employees can only 2 times a year Taking one sick day without a medical certificate; 
  • The ‘wait time’ for initiating proceedings medical force majeure is shortened from 9 months to 6 months.
  • Herval gives only after 8 weeks resumption of work again entitled to guaranteed pay.
  • Elimination of neutralization of guaranteed pay in the case of progressive work resumption.
  • Solidarity contribution To replace current accountability contribution:
    • Amounts 30% of sick pay for the 2 months following the month of guaranteed pay.
    • Not required for SMEs with < 50 employees.

 

State of play: 

  • These changes would take effect on January 1, 2026.
  • On today, a bill was introduced, yet to be approved. 

 

 

What does this mean for you as an entrepreneur?

Although for a lot of announced measures no (final) legal texts yet are available, it is clear that 2026 for employers will be various socio-legal changes entails. The impact on your human resources will be felt in several areas.

It remains important to maintain the follow up further developments, so as an employer you will not have any surprises. Our pro accountants & experts are, of course, ready to help you inform and to advise.