Payroll Newsletter Q3 2025

1. Eco vouchers of 2026 - conversion before 31 October 2025

The collective labour agreement concerning eco vouchers for employees falling under Joint Labour Committee 200, has been concluded for an indefinite period. Consequently, as an employer, to be compliant with Belgian law, in principle, you have to grant eco vouchers to your employees in June 2026.

However, it is also possible to reward your employees by granting another equivalent benefit instead of eco vouchers. Another equivalent benefit can be e.g. the implementation of meal vouchers or increasing the nominal value of the current meal vouchers, implementation of a collective medical expense / hospitalization insurance, …

The implementation process depends on the presence or absence of a trade union delegation within your company. Employers who want to convert their eco vouchers of 2026 into another equivalent have time until 31 October 2025 to do so.

New employers must do this utterly on 31 May of the first year of granting eco vouchers.

Please note: Changes to the eco voucher system has been under discussion. The current federal coalition agreement included the intention to gradually phase out certain vouchers – such as eco vouchers – in consultation with the social partners, while increasing the value and spending possibilities of meal vouchers. Should any changes be formally confirmed, we will of course inform you in due time.

In case you would like our advice or assistance relating to this conversion, please contact us at payroll.be@forvismazars.com

2. New parental leave for foster parents in Belgium

Foster parents can take up to 4 months of full-time leave, 8 months of half-time leave, 20 months of 1/5th leave, or 40 months of 1/10th leave with employer approval. The leave can begin once the child is registered as a family member in the local population register or foreign register in the commune in which the employee resides. 

To qualify, foster parents must provide proof of the child's age and the event leading to the parental leave. The right to parental leave is granted for children under 12 years old, or under 21 if the child has a disability. The leave can be taken as long as the child remains in long-term foster care.

This new law ensures foster parents receive the support needed to provide a stable environment for children in their care. More information will be available on the ‘National Employment Office (NEO)’ website as soon as the law has been approved, however this will be after the foreseen timing of 1 July 2025. For further assistance, do not hesitate to reach out to our labour law consultants.

3. New mileage allowance effective 1 July 2025

Starting 1 July 1 2025, employers must apply new amounts for the flat-rate mileage allowance for employees using their personal vehicles for professional travel. This allowance will be indexed quarterly to better respond to fuel price fluctuations.

Applicable Amounts for 2025:

• 1 January - 31 March: €0.4290/km
• 1 April - 30 June: €0.4320/km
• 1 July - 30 September: €0.4309/km

An annual indexation is also planned, with an amount of €0.4451/km for the period from 1 July 2025 until 30 June 2026 (subject to confirmation of the Belgian authorities).

As an employer, you can choose to apply the flat-rate system on an annual basis. You must then apply it for the entire period from 1 July 2025 until 30 June 2026. During this period, you cannot switch to the quarterly flat-rate system. This will only be possible from 1 July 2026 at the earliest.

Employers must cover the professional travel expenses of their workers. If your sector does not specify anything, you can choose between the quarterly or annual allowance, but you must adhere to your choice for the entire relevant period.

For more information, please contact our labour law or employment tax consultants.

4. Stricter tax audits on wage withholding tax exemptions 

Update June 2025

Wage withholding tax exemptions are a valuable cash-flow incentive for employers. They allow a portion of wage withholding taxes to be retained by the employer without impacting the employee’s net salary.

However, as the fiscal burden of these exemptions continues to rise, the Belgian tax authorities have significantly intensified their audit activity, leading to unprecedented levels of reclaimed benefits.

Key Developments

• In 2024, the Belgian tax authorities reclaimed a record €193 million in exemptions, nearly double the amount of 2023.
• Approximately 70% of all payroll tax audits resulted in corrections.
• The primary focus was on exemptions related to shift and night work (€123 million reclaimed) and R&D activities (€58 million reclaimed), affecting companies, universities and research institutions.
• Stricter application of rules, including proportional application required when shift teams differ in size or workload (‘bis regime’) and mandatory and timely registration of R&D projects with BELSPO.

What does this mean for employers?

Companies must be prepared for more frequent, in-depth and retroactive tax audits - even if previous filings were accepted without issue.

Key action points:

• Ensure complete and traceable documentation for each applied exemption
• Respect procedural and timing obligations, especially in R&D filings
• Anticipate retroactive audits and maintain records accordingly

Next Steps

If your company is applying, or planning to apply, wage withholding tax exemptions, a prior compliance review is highly recommended. 

We would be happy to explain this further and provide you with a tailored approach specific to your company situation.
Our tax incentives team is available to provide a comprehensive overview, answer any questions you may have and tailor a solution that aligns with the needs of your organization.
Furthermore, if assistance would be required with tax audits, our tax team can assist your company with these audits.

Please let us know if you are interested in exploring these opportunities further so that we can reach out to you to schedule a meeting.

5. Program law 27 May 2025: changes to employer social security contributions 

Based on the draft program law, Belgium is planning to implement as from 1 July 2025 a structural reform to its social security system by introducing a cap on the employer’s share of social security contributions for high salaries. This reform is part of a broader effort to rebalance the cost of employment in Belgium, particularly in relation to high-wage earners.

What is planned to be changed?

For employees with gross annual salaries above €340.000 (or €85.000 quarterly), the employer’s social security contributions will be capped on this threshold.

The cap will be applied on a quarterly basis, and the employer’s social security contributions will therefore be limited to this threshold if an employee’s gross salary exceeds it.

Importantly, the draft program law also stipulates that no contribution reductions or exemptions - such as first-hire reductions or sector-specific discounts - may be applied to the salary portion exceeding the cap. These advantages remain valid only within the capped base.

What does this mean for your organisation?

Once accepted, this measure is expected to generate cost savings for companies employing executives or senior professionals with high compensation packages. While the impact may be limited to a relatively small segment of the workforce, it provides a tangible opportunity for employers to optimise total labour costs, enhance net remuneration through reallocation, or reinvest savings in retention strategies.

If you have any questions please do not hesitate to contact our employment tax specialists at Forvis Mazars. 

6. End-of-career time credit – delay between entitlement and payment of benefits from 1 July 2025

The collective labour agreements (CLAs) that currently allow employees to take end-of-career time credit with NEO interruption allowances before the age of 60 have expired on 30 June 2025.

Therefore, any employee wishing to receive this allowance before turning 60 must ensure their end-of-career time credit has started before 1 July 2025.

Important: this refers to the actual start date of the time credit. It does not refer to the date of the request to the employer, nor the submission date of the NEO application via Break@Work.

In case of further questions, please get in touch with us.

7. Student work: no withholding tax for 650 hours

The law of 10 April 2025 (published in the Belgian Official Gazette on 8 May 2025) has extended again the system allowing students to work up to 650 hours per calendar year under the reduced solidarity contribution scheme, with one or more employers.

This 650-hour ceiling applies retroactively, from 1 January 2025 and concerns student employment contracts under Title VII of the Law of 3 July 1978 on employment contracts.

The law also specifies that wages paid to students for these 650 reported hours (provided they are exempt from social security contributions under Article 17bis, §1 of the Royal Decree of 28 November 1969) are not subject to wage withholding tax.

8. Temporary private use of a “holiday car”

According to the ‘Office for Advance Tax Rulings (OATR)’, the personal use of this temporary company vehicle is considered a taxable benefit, calculated on a flat-rate basis and prorated according to the duration of the vehicle's availability (as per Article 36, §2 of the Belgian Income Tax Code 1992).

During the period the “holiday car” is made available, the employee must fulfill some conditions and if these conditions are met, the benefit in kind related to the regular company car would be suspended.

According to FAQs 13 and 14 on personal use of company cars, the taxable benefit may be reduced proportionally, provided the agreement includes a clause requiring vehicle return under such circumstances.

9. Extension of relance time hour

The government has confirmed that the relance overtime scheme will be extended until 31 December 2025. Initially, the system was due to end on 30 June 2025.

Employers can continue to grant up to 120 voluntary overtime hours per employee in 2025. These hours remain exempt from Belgian social security contributions and wage withholding tax.

At this stage, we're only talking about a simple extension, the 120-hour cap remaining unchanged. However, there are clear indications that the government intends to go further. A proposal to increase the limit to 240 hours is expected to be introduced in Parliament after the summer.

The law has not yet been published in the Belgian Official Gazette, but it will enter into force retroactively as of 1 July 2025, allowing employers to continue applying the regime without interruption.

The voluntary overtime hours can however be applied in the meantime. Please note that a surcharge is due for these hours and although formalities are not complex, the written agreement is mandatory.

If you have any questions please do not hesitate to contact us or anyone our labour law team.

10. Importance of using the structured message invoices 

We would like to highlight the importance of using the correct structured message when processing payments for the payroll related invoices we provide. This is particularly relevant for invoices issued by authorities (social security- and tax authorities, etc.), insurance providers, mandatory affiliations (e.g. prevention and protection at work), meal voucher providers, and similar entities.

To ensure smooth and timely processing of these payments, it is essential that the structured message is always included. This message is formatted as follows:

+++XXX/XXXX/XXXXXX+++

The structured message plays a crucial role in allowing your payment to be automatically matched to your client account and confirming that the payment has been correctly executed.

Omitting this message may result in delays in processing your payment. Payments without a structured message require manual intervention, which can lead to longer processing times or additional follow-up from the provider. In both cases, this may result in penalties or late payment interest.

Thank you for your attention to this matter.

11. Deadlines 

(*) Depending on the complexity of the income tax return, in accordance with the instructions of the Belgian tax authorities.