HR deadlines 2026-2027: what Belgian employers need to know now

The next six months will be anything but quiet for HR in Belgium. Mandatory working time recording and a mandatory mobility budget offer could apply from 2027, and the European Pay Transparency Directive should already have been transposed by 7 June 2026.

Many of these rules are not final yet. Still, waiting is not a good idea: if you get your pay policy, working time recording and procedures in order now, you won’t have to scramble to adjust later. In this article, we set out what is fixed, what is coming and why it pays to start working on it now.

The European Pay Transparency Directive had to be transposed into Belgian law by 7 June 2026 at the latest. For the private sector, that did not happen: the federal government has not yet tabled a draft law, so talks in the National Labour Council have not started. Belgium has asked the European Commission to hold off infringement proceedings for six months, but the Commission has ruled out any general postponement of the directive. Flanders and the French Community have already transposed it for their own public staff.

What does this mean for you as an employer? As long as there is no Belgian law, strictly speaking no new obligations apply. But the principle of equal pay for equal work or work of equal value already applies today, and since 2012 Belgian companies with 50+ employees have had to carry out a pay gap analysis every two years. And you know what is coming, because the directive is fixed:

• Recruitment: applicants must be told the starting pay or pay range before the interview. Employers may no longer ask candidates about their current or previous pay.
• Right to information: employees can request their own pay level in writing, plus the average pay by gender for employees doing the same work or work of equal value. Employees cannot request the salary of one specific colleague.
• Transparent pay policy: the criteria for pay and pay progression must be objective, gender-neutral and accessible.
• Gender pay gap reporting: under the directive, companies with 250+ employees report annually and those with 150–249 employees every three years, both for the first time by 7 June 2027 (covering 2026). Companies with 100–149 employees follow from 2031, every three years. Companies with fewer than 100 employees do not have to report. How this will work in Belgium depends on the transposition law.

The government wants every employer to record the daily and weekly working time of their employees from 1 January 2027, with a transition period until 1 April 2027 to get the system up and running.

What does it include (for now)?

• Free choice of system: a time clock is not required. An app, software or another reliable system is also possible.
• Recording deviations only: employers with fixed or variable work schedules may limit themselves to recording deviations, provided the actual working time can be derived from them.
• Exceptions: according to the current text, managerial staff, employees in positions of trust, sales representatives, home workers (including teleworkers) and employees with a mobile role are excluded.

The text may still change. The National Labour Council issued a split opinion on 30 September 2026. Employers consider the timing unfeasible and are asking for at least one year after publication. Unions, on the other hand, want stricter rules, such as electronic recording, recording breaks and no general exceptions. The government still has to approve the draft, and Parliament has to vote on it.

In the meantime, sector-specific rules already apply, such as digital attendance registration in the cleaning sector and the registration obligation for flexible working hours.

The mobility budget has existed since 2019, but is currently voluntary. The government wants to change that. Employees entitled to a company car would always be able to exchange it for a mobility budget from 2027. As an employer, you would then be required to offer it.

What does it include (for now)?

• Who and when: employers with at least 50 employees from 1 January 2027, employers with 15 to 49 employees from 1 January 2028. Smaller employers are excluded.
• Only with company cars: the obligation only applies to employers who have provided company cars for more than 36 months.
• Three pillars: the employee spends the budget on an environmentally friendly car, on sustainable mobility such as public transport, a bicycle or housing costs near work, and receives the balance in cash (subject to a special social security contribution).

Nothing is final here either: there is only a preliminary draft law. The social partners issued a unanimous opinion on 29 April 2026. Their message: make the system simpler before making it mandatory. Among other things, they ask to link the employee thresholds to existing social security data, to cap housing costs at 50% of the budget, and to temporarily exclude (until the end of 2029) employees who would be required to choose a car under pillar 1.

Pay transparency, working time recording and the mobility budget have one thing in common: the details are not yet fixed, but the direction is. And if you wait until the laws are published, you have a problem. Developing a job classification, reviewing a pay policy or rolling out a new registration or mobility system is not something you do in a few weeks.

If you start now, you turn obligations into an advantage: a fair and clear pay policy, clear agreements on working time and a flexible mobility offer also make you a more attractive employer.

A project like this often comes on top of your HR team’s day-to-day work. Skill&Will provides experienced HR professionals for temporary support, from project management to execution. That way, your own team keeps running and you still meet the deadlines. Get in touch with us and we’ll look at what you need together.

This article reflects the situation as of 14 October 2026 and does not constitute legal advice. Several measures are still preliminary drafts and may change.