Payroll Newsletter Q4 2025

1. The replacement of public holidays that occur in the weekend in 2026

With respect to the replacement of public holidays that occur during the weekend in 2026, we would like to point out that if the company wants to fix another replacement date, the decision must be taken at company level and needs to be communicated with the employee, before 15 December 2025.

A copy of the notice must be annexed to the work rules and must be sent to the Social Legislation Inspectorate.

2. Business travel expenses

Expenses proper to business travels could be reimbursed by the employer to the employee on a lump sum basis under certain conditions.

If an employee (or a director) does not receive a company car and uses his/her own vehicle for business travels (i.e. no commuting), the employer may grant the employee a lump sum allowance to cover the expenses proper to the use of the own
vehicle for professional purposes.

The reimbursement of these business travel expenses can be done in two ways:

1. Reimbursement upon expense notes based on the actual expenses incurred;
2. Reimbursement by means of a fixed mileage allowance of €0.4312 per kilometer (amount as of 1 October 2025).

This lump sum mileage allowance is adjusted quarterly by the Belgian government. Alternatively, an annual mileage allowance may be applied. For the period from 1 July 2025 to 30 June 2026, the applicable rate is €0.4449 per kilometer.

3. Group insurance/hospitalisation insurance request for notification

If you have set up an extra-legal/employer group insurance (employer pension scheme) or hospitalization insurance for your employees, please inform us if the payroll is being processed by Forvis Mazars in Belgium. 

We require this information to process the payroll administration as completely and correctly as possible. With respect to the employer contributions to the group insurance, we also need to include a special social security contribution (equal to 8.86% on the paid premiums) in the quarterly Belgian social security return for the 4th quarter of 2025.

4. Adjusted ceiling wage educational leave/Flemish training leave as of September 2025 & reimbursement request educational leave Brussels - deadline 31/12/2025

An employee who takes educational leave is entitled to the payment of his/her normal salary. This is, however, limited to a cap, unless the employer agrees to maintain the normal salary. 

The salary cap is adjusted annually on 1 September. As of 1 September 2025, the monthly capped gross wage is €3,714.

Furthermore, for the employer whose employee(s) take(s) paid educational leave and who has an establishment unit in the Brussels-Capital Region, the request for a reimbursement for the hours of paid educational leave taken by an employee must be filed by 31 December 2025 at the latest (for the 2024 - 2025 school year). 

Should you need assistance with such a request, do not hesitate to contact us at payroll@zd-be.forvismazars.com 

5. Prognosis indexation percentage for January 2026

Each year in January, salaries are adjusted to the cost of living for employees of companies subject to Joint Labor Committee 200 (JLC 200). In Belgium, this is referred to as the indexation of salaries.

This indexation is a mechanism whereby salaries are linked to the evolution of the flattened health index. The monthly salary is more specifically increased by a percentage equal to the inflation rate of the previous calendar year. The indexation system as foreseen by JLC 200 is applicable to all employees falling under the scope of this Joint Labor Committee.

Based on current forecasts, we expect that the indexation percentage for January 2026 will be approximately 2.05%. 

We will inform you of the final index percentage by early January 2026 at the latest.

6. Wage withholding taxes – Overtime – Exemption of the payment: adjusted regulation due to extension of the increased maximum number of overtime hours

The Belgian government has extended the temporary cap on overtime hours eligible for a tax reduction. The cap, which was increased from 130 to 180 hours, was initially set to apply from 1 July 2023 to 30 June 2025. However, the Program Law of 18 July 2025 has now extended this increased cap until 31 December 2025, with retroactive effect from 1 July 2025.

If you have employees who perform overtime and receive a surcharge, this increased cap may apply, allowing for additional tax reduction.

If you have any questions about this topic or need tailored advice, please do not hesitate to contact us at payroll@zd-be.forvismazars.com 

7. New regulation concerning employment of foreign (third-country) employees as from 1 January 2026 – Flemish Region

The Flemish Government has principally approved a new set of rules for the employment of foreign workers, set to take effect on 1 January 2026 (pending final confirmation). 

Applications submitted before this date will still be processed under the current framework, but changes are on the horizon.

What’s changing?

• Targeted talent: The new policy prioritizes highly skilled professionals and medium-skilled workers in critical roles, while restricting access for highly educated individuals seeking lower-qualified positions.
• Stricter compliance: The concentric approach is clarified, requiring employers to first seek talent locally and within the EU before considering non-EU candidates. Grounds for refusal are tightened to prevent abuse and fraud, including stricter checks on employer practices and document authenticity.
• Sector flexibility: The Minister will have the authority to temporarily exclude certain sectors from the shortage occupation list.
• Focus on skills: Low-skilled economic migration will be excluded, except for temporary seasonal work.
• New fees: A retribution fee of up to €200 will be introduced for single permit applications and renewals (taking effect as from a later moment).

Are you planning to hire EU or non-EU employees in Flanders, or do you want to ensure your HR policies are fully compliant with the new rules? 
Contact stijn.sablon@forvismazars.com or bart.vanlaere@forvismazars.com 

8. Lump-sum expense allowance – Foreign business trips – Adjusted amounts as from 1 August 2025

A new list of daily allowances for employees and company directors traveling abroad for business is published, effective from 1 August 2025. These updated rates, which vary by country, are recognized by the tax and social security authorities as tax- and social security free reimbursements for actual business expenses — provided they do not exceed the official daily amounts or are reimbursed based on expense notes. The daily allowances cover meals, drinks, local transport, and incidental expenses, but does not include accommodation or travel to and from the destination.

Key changes and practical impact

Compared to the previous list, many countries have seen changes in their daily allowances—some increased (e.g., Germany, Ireland, UK), others decreased (e.g., France, USA, Japan), while some remain unchanged. Both the tax and social security authorities generally follow these rates, but there are some differences in how additional expenses and accommodation are treated. Employers should ensure they apply the new rates for all business trips starting on or after 1 August 2025.

Action required:

Please review your company’s travel policies and update your expense procedures to reflect these new rates. For any advice, contact us on payroll@zd-be.forvismazars.com 

9. Federal mobility budget: coming your way in 2026

The federal mobility budget is about to redefine corporate mobility policies. What was long considered unattainable - reducing the dominance of the company car - is now becoming a tangible reality.

Driven by the rise of remote work, the need to avoid traffic congestion and a growing commitment to sustainability and green mobility, the federal mobility budget is gaining significant traction. As of 2026, substantial regulatory changes are expected, offering HR professionals a unique opportunity to rethink and optimize their mobility strategies.

A shift toward sustainability and alternative mobility

Employees entitled to a company car have, for several years now, the option to exchange it for a mobility budget. This allows them to use the value of their company car for an electric vehicle or other eco-friendly alternatives, such as an (electric) bicycle, shared mobility services, or a public transport subscription. Under certain conditions, even rent payments or mortgage repayments can be covered by the mobility budget.

Currently, employers can still decide whether or not to offer this mobility budget to their employees. However, this will change as of 1 January 2026. The federal government agreement includes a general obligation for employers to provide a mobility budget. This means that employers who already offer company cars will also be required to offer the mobility budget. While we are still awaiting the official publication of the revised rules in the Belgian Official Gazette, now is the time to start preparing.

Three pillars

When an employer implements the mobility budget within the company, employees can exchange their company car - or their entitlement to one - for a mobility budget. This budget can be freely allocated across three pillars, depending on the options made available by the employer:

• Pillar 1: the employee may opt for an environmentally friendly company car.
• Pillar 2: any remaining budget after Pillar 1 can be used for a wide range of sustainable transport options, such as a bicycle, (organised) public transport, car sharing, etc. Employees living within 10 km of their workplace may also use the budget to cover rent or mortgage interest and capital repayments.
• Pillar 3: if the budget is not fully spent under Pillars 1 and/or 2, the remaining amount is paid out in cash, after withholding a special employee contribution.

How to prepare?

Once the final rules are published, companies must be ready to act. Proper preparation is therefore essential.

Implementing the mobility budget not only involves administrative formalities and the drafting of several legal documents, but also includes being prepared regarding how to determine the total cost of ownership (TCO), the design of a broader mobility policy tailored to your company, and how to communicate this to your employees. Using a mobility platform can also be a helpful tool, particularly for managing the options under Pillar 2.

Legal assistance

Our labour law team is happy to assist you in all matters regarding the implementation of a mobility budget. Please do not hesitate to contact stefanie.devestel@forvismazars.com or kim.matthys@forvismazars.com

10. New due diligence obligation to combat illegal employment in Flanders (Effective 1 January 2026)

From 1 January 2026, the Flemish Government will introduce a new due diligence obligation aimed at combating the illegal employment of foreign nationals. In addition to the federal framework of measures against illegal employment, additional measures are being introduced for Flanders in the form of a duty of dilligence that goes even further than the federal measures already in force. 

This regulation will only apply on the clients operating within certain high-risk sectors, such as construction, cleaning, meat processing and courier services. A six-month “tolerance” period will follow the official implementation date.

Under these additional rules, contractors are not only required to obtain a written declaration from their direct subcontractors confirming that they do not – and will not – employ illegally residing foreign workers, but must also exercise proactive due diligence to prevent such employment. In practice, this means contractors must be able to demonstrate that they have requested specific information from their direct subcontractors: 

• the identification and contact detail of employees or self-employed workers;
• as well as personal data relating to the residence and employment status of any foreign workers, whether employed or self-employed.

The contractor is not liable if he meets the following two conditions:

1. written declaration;
2. compliance with the duty of dilligence: the necessary information is available or, if the information is not available, the inspectorate was notified.

However, if it appears that the contractor was aware of the illegal employment by his subcontractor, he will be held jointly liable. The social inspectorate can provide proof of prior knowledge using all possible means of evidence.

It is important to note that this obligation does not apply to projects valued under €30,000 (excluding VAT) with no subcontractors, or those under €5,000 (excluding VAT) involving a single subcontractor.

All contractors and professional clients operating in the affected sectors should begin aligning their internal processes now to ensure compliance by the time the regulation takes effect.

Our labour law or global mobility team would be happy to assist or advise you.

11. Wage norm 2025 - 2026 (officially set at 0% in the Royal Degree of 12 September 2025)

The Belgian government has set the wage norm for 2025 - 2026 at 0%. This means that the average labour cost per employee over the period 2025 - 2026 may not increase compared to 2023 - 2024.

What remains possible?

• Individual salary increases are allowed if they do not raise the company’s average labour cost.
• Seniority increases, scale progressions and promotions remain possible.
• Bonuses such as profit-sharing premiums or the CAO 90 bonus schemes may still be granted.
• Automatic indexation of salaries will still be applied.

Meal vouchers

The government agreement foresees, as of 1 January 2026, that the maximum employer contribution to meal vouchers can rise to € 8.91 per meal voucher. It is not yet clear whether this increase will fall outside the wage norm.

Sanctions

Non-compliance with the wage norm may result in fines ranging from € 250 to € 5,000 per employee, capped at 100 employees.
Should you require our assistance regarding this matter or do you have questions concerning possible salary optimisations, contact us on payroll@zd-be.forvismazars.com 

12. Exemption from wage withholding taxes for your employees - 2025

Wages earned by certain young employees will be exempt from Belgian wage withholding tax in the fourth quarter of 2025, provided specific eligibility criteria are satisfied.

This exemption applies to young employees who meet the requirements set out in Article 36, § 1, first paragraph, points 1° to 3°, of the Royal Decree of 25 November 1991 on unemployment regulations. These conditions include:

• No longer being subject to compulsory education;
• Completion of specific studies, such as a full curriculum in higher or lower secondary technical, artistic, or vocational education, an alternating training program, or possession of a secondary education certificate based on a limited curriculum;
• Having terminated all obligations associated with any study, apprenticeship, or training program, including those involving a full curriculum.

To qualify, the employment contract must commence in October, November or December 2025; this measure does not extend to recruitments initiated in September 2025. Additionally, the employee’s monthly taxable income must not exceed €4,875 for the 2025 income year.

Please note: The exemption is only available if the young employee has not been employed by another employer in 2025 and has not received remuneration during that period.

The exemption is effective from the month of recruitment (October, November or December 2025) through to the end of the calendar year. From 1 January 2026 onwards, wage withholding tax will apply to all wages. 

In case you would have qualifying young employees or you are planning to hire one and have questions, please do not hesitate to contact us on payroll@zd-be.forvismazars.com 

13. Providing modified data regarding your employees and your fleet

To ensure accurate payroll processing, it is important that all employee-related information remains up to date. 

We kindly ask you to inform us immediately of any changes concerning the employee’s vehicle fleet, family status, address, benefits in kind (such as mobile phone, laptop, etc.), group insurance and/or hospitalization insurance.
If needed, we may request additional details at the time of the adjustment. 

Thank you for helping us maintain accurate records and ensuring a smooth payroll process. 

14. Important year-end information for the Belgian payroll

December Payroll

• Deadline: Submit December payroll data by 5 December 2025.
• Vacation Days: All legal vacation days for 2025 must be taken before year-end (unless force majeure).
• If no data is received by 5 December remaining vacation days will be processed based on current records; unreported days will be treated as worked. Therefore, ask your employees to take their remaining vacation days or inform if they should be paid out.

Payroll modifications for 2025

In February 2026 Forvis Mazars will have to prepare and file the Belgian annual tax forms 281.10 for all your employees based on the income of the previous year (i.e. 2025). The employees will require this tax form in order to prepare and file their individual income tax returns. 

We are already aware of the payments that have been processed through the payroll in 2025. At this point, what we still require is information on all relevant payments that you have made to your employees that have not been processed via the payroll.

In order to prepare the annual tax forms correctly without extra administrative costs, we kindly ask you to provide us with the amount of the reimbursements of expenses proper to the employer outside of the payroll per employee and per type of reimbursement.

15. Deadlines