As the summer holidays draw to a close, employers face a dense run of legal deadlines and reforms heading into 2027. This newsletter highlights eight matters that companies should put on the agenda now, moving from yearly obligations and points of attention to new and pending reforms that reward early preparation.
Internal rules on private investigations by 16 December
The Private Investigations Act of 18 May 2024 reshapes how organisations can investigate their own staff. From 16 December 2026, an investigator may only accept a workplace investigation into an employee if the company has written internal regulations that expressly authorise private investigations and set clear procedures for how they will run. For more information, check out our previous newsletter on this topic.
Working time registration as of 1 January 2027
From 1 January 2027, every private and public sector employer must operate an objective and reliable system to record each employee's daily and weekly working time, in line with recent case law of the Court of Justice of the European Union. Companies that do not yet have a suitable system by that date will have until the end of the first quarter, making 31 March 2027 the hard deadline.
Mobility budget for larger companies as of 1 January 2027
The government has approved a preliminary draft act implementing the first phase of the mobility budget reform, under which every employer that provides one or more company cars for a period of more than 36 months must offer affected employees a mobility budget. For companies employing 50 or more employees, this obligation is set to take effect on 1 January 2027.
Limitation of automatic indexation (‘index in cents’)
Since the first moderation period started on 1 June 2026, the limitation of the automatic indexation of salaries above €4,000 gross per month – the so-called ‘index in cents’ – has begun to take effect. In the coming months, more and more companies will be confronted with their first limited indexation, as each joint committee applies its own timing and formula. This will notably be the case for all companies within Joint Committee no. 200, which will see an automatic indexation of salaries on 1 January 2027. For more information on the impact of the ‘index in cents’ and accompanying wage moderation contributions, check out our previous newsletter on this topic.
Pay transparency
Belgium missed the 7 June 2026 deadline to transpose the European Union Pay Transparency Directive and national rules are expected in the coming months. The core elements are, however, already clear and companies should not wait for legislative action but start preparing now.
Replacement public holidays
As every year, companies must review which 2027 public holidays fall on a Sunday or a usual day of inactivity and schedule replacement days accordingly. It is mandatory to inform employees of these replacement days before 15 December 2026.
Bonus plans for 2027
With the final quarter approaching, it is time to shape performance bonus plans for 2027, whether a cash bonus, warrants or the non-recurring result-linked benefit under collective bargaining agreement no. 90 ('CBA 90'). A calendar-year CBA 90 plan must generally be filed by 30 April 2027, and, since 1 June 2026, all acts of accession must be filed online via www.bonusplannen.be.
Year-end gifts for employees
At year-end, companies may offer employees additional gifts beyond the usual year-end premium. Gifts given for occasions such as Saint Nicholas, Christmas or New Year are exempt from social security contributions and income tax, provided they stay within the prescribed limits. Each year, an employer may offer gifts up to a total value of €40 per employee, with a further €40 for each dependent child, allowing extra benefits while keeping full compliance.
Authors:
- Pascale Moreau, Lawyer - Partner at PwC Legal BV/SRL
