Several important changes to Belgian employment law entered into force on 1 January 2026, and additional reforms are expected to take effect later in 2026. Employers should prioritise immediate compliance actions, in particular updates to internal work regulations, sick-leave and reintegration processes, and payroll systems, while preparing for upcoming reforms that may affect your obligations and HR policies:
1. Federal Learning Account (FLA) abolished: The Federal Learning Account reporting obligation has been formally abolished. Employers are no longer required to register training via a federal platform (more details here). ⇒ No action required, but training should continue to be documented in line with existing legal and internal rules.
2. Mandatory absence management policy: regardless your size, your internal work regulations must now include a procedure for maintaining contact with employees on sick leave (more details here). ⇒ Update work regulations following the applicable consultation procedure.
3. Medical certificate exemption reduced: Employees may now be absent without a medical certificate only twice per calendar year instead of three as previously (more details here). ⇒ Amend work regulations if this exemption is currently reflected there.
4. Reintegration obligations and sanctions strengthened: after 8 weeks of sick leave, employers must assess the employee’s work potential. For employers with 20+ employees, a reintegration procedure must be launched within 6 months where work potential exists. The reform accelerates and formalises mandatory reintegration timelines, while significantly increasing employer exposure to sanctions in case of inaction (more details here). ⇒ Implement clear internal tracking and escalation procedures.
5. Earlier medical force majeure termination: The procedure allowing employers to separate with long-term sick employees without notice or payment in lieu being due is simplified and may now be initiated earlier, i.e. after 6 months of uninterrupted sick leave (previously 9 months). ⇒ Review ongoing long-term sick leave cases.
6. Sick pay – relapse period extended: The relapse period is extended from 14 days to 8 weeks. No guaranteed salary (i.e. continued salary due for up to 30 days at the beginning of any sick leave) is due for relapses within that period. The extension of the relapse period reduces employers’ sick pay exposure in case of repeated sick leave. ⇒ Payroll processes should be adapted accordingly.
7. Meal vouchers – higher employer contribution: The maximum employer contribution increases to €8.91. This is not automatic. The increase expands the maximum tax-efficient benefit that employers may grant, subject to proper formalisation. ⇒ Implement via CBA or individual agreements if an increase is intended.
8. Other changes to note include new rules for end-of-career time credit applications and new quarterly solidarity contribution for certain long-term sick employees. These measures further reinforce the policy focus on longer careers and employer accountability in cases of long-term incapacity.
The following measures, which did not enter into force on 1 January but will take effect later this year, are also relevant for Belgian employers:
1. Introduction of a “right to rebound”: From March 2026, and subject to conditions, workers with a long professional career who resign from suitable employment will no longer risk a sanction by the unemployment authorities. Under the current rules, such a resignation may lead to a suspension of unemployment benefits for 4 to 52 weeks. Sanctions applicable to other cases of voluntary resignation will also be reduced. This reform reduces unemployment sanctions linked to voluntary resignation in order to encourage career mobility and reskilling.
2. Private investigations policy: Companies conducting internal investigations of employees must adopt a written policy by 16 December 2026 setting out the rules and conditions for such investigations. Non-compliance may result in exclusion of evidence in court proceedings (more details here). The new rules aim to formalise and safeguard internal investigations, with evidentiary consequences in case of non-compliance. Proactive employers are already drafting this policy.
3. Increase in the taxation of dividends and liquidation bonuses (from 15% to 18%): although this measure does not affect employees but independent consultants, it is relevant for the HR community as it will impact consultants operating through a personal management company. The measure will apply to dividends and liquidation bonuses paid as from 1 April 2026. Inter alia, this fiscal measure increases the cost of remuneration structures commonly used by independent consultants operating via management companies (more details here).
Finally, the implementation and entry into force of several long-discussed measures are still uncertain. This includes the wage indexation cap for salaries above €4,000 gross, that was announced in the government's budget agreement, but that has been postponed. Sectors with annual indexation in January must therefore continue to apply normal indexation where applicable (e.g. Joint Committee 200: 2.21%). The capped indexation is expected to enter into force later in 2026.
