Belgium’s Autumn Agreement introduces several significant reforms to labour law. The package aims to modernise working conditions, improve the sustainability of employers’ labour costs, and support a more efficient framework for reintegration and working time. This article summarises the main employment-law elements: the cap on wage indexation, the reform of the reintegration procedure, mandatory time registration, the expansion of flexi-jobs, the reform of voluntary overtime, the easing of night work rules, and the abolition of the minimum one-third work-time requirement.
1. Capping Wage Indexation for Higher Salaries
The government will limit the automatic indexation of wages above €4,000 gross. Only the portion up to €4,000 will be indexed, while the part above that threshold will not. Employers will share part of the resulting cost savings with the government as they will need to pay half to the social security office.
This measure is technically very complex because Belgium does not have one single index system: sectors index at different moments and with different percentages . It also appears unlikely that the necessary legislation will be in force before January 2026, meaning many salaries may still be fully indexed during the next major index round. It is uncertain how the Government is planning to take this into consideration.
Key practical points for employers:
- The measure will not affect all sectors simultaneously due to diverse indexation calendars.
- Retroactive adjustments are legally impossible because they would interfere with workers’ acquired wage rights.
- HR and payroll providers will need clear calculation rules to avoid legal and operational uncertainty.
2. Reform of the Reintegration Framework for Long-Term Sick Workers
This was already on the table in the Summer Agreement, but has now been further clarified. Minister Vandenbroucke clarified that the plan intends to slow a projected increase of 100,000 cases of long-term sick workers by 2030 .
Core elements include:
- Employers with more than 50 workers will pay a “solidarity contribution” for long-term sick workers for up to four months (30% each month) if employees remain fully absent. This cost disappears when the employee returns to work even partially. Sick employees will therefore become more expensive for employers than is the case.
- Employers must implement an active reintegration and absenteeism policy, adapted to the size and sector of the company.
This policy must be integrated into the work regulations. - Reintegration must consider possibilities both inside and outside the company
- Employers must ask the internal prevention service to evaluate the worker’s “arbeidspotentieel” (remaining work capacity) after 8 weeks of absence. If there is potential, a formal reintegration process must start.
- Companies with >20 employees are punished under the Sociaal Strafwetboek (Niveau 2) if they fail to start the process within 6 months.
- The occupational physician must act from 1 month of sickness onwards, for every case (not only when asked)
- Medical force majeure procedure can be started after 6 months of incapacity (instead of the current 9)
- Mutualities will monitor workers more strictly
- Employees can ask for a preventive reintegration (which employers can refuse)
- Prescribing Doctors will be monitored to fight fraud
Employers who refuse to propose a reintegration plan without reasonable justification may face increased sanctions.
Prevention doctors and the RIZIV will conduct more result-oriented assessments. The compromise note outlines new monitoring tools, including stricter annual reviews and thematic controls focused on successful return-to-work trajectories .
Practical implications:
Employers must be prepared for stricter scrutiny, clearer documentation of reintegration efforts, and potential cost exposure if they do not engage proactively.
3. Mandatory Registration of Working Time
From 1 January 2027, all employers must implement a system allowing employees to record the hours they actually work. This follows European case-law stating that working-time rules are only enforceable when working time is objectively measured.
While a traditional time clock is not required, the system must be objective, reliable and accessible, and can include digital tools or even registration after the fact in some forms.
Practical considerations:
- Employers should begin assessing which system suits their operations.
- The measure increases compliance obligations even as the government otherwise aims to make working time more flexible.
- Trust-based arrangements—common in SMEs—will need to be formalised.
4. Expansion of Flexi-Jobs
This also already featured in the Summer Agreement. The government now confirms that flexi-jobs will be opened to all sectors, including the public sector, with the exception of artistic/creative professions. Sectors will also be able to opt out (by a decision of the Joint Committee).
Core conditions remain:
- A flexi-worker must be employed at least 4/5th elsewhere.
- Flexi-jobs offer reduced social contributions but are accompanied by strict eligibility rules.
This expansion offers employers a more flexible staffing tool but also increases the need for careful eligibility checks and payroll compliance.
5. Reform of Voluntary Overtime
Another item that comes from the Summer Agreement which decided to increase the annual quota of voluntary overtime to 360 hours per year, applicable across all sectors. For the first 240 hours, the gross pay equals the net pay because these hours are exempt from taxes and social security contributions.
Uncertainty remains for part-time workers, who may face additional conditions before being permitted to use these hours .
Registration of working time (see above) becomes necessary to safeguard these arrangements.
6. More Flexible Night Work Rules in the Distribution Sector
The government wants to make night work in the distribution and e-commerce sectors more workable.
The new rule provides that night-work premiums apply only between 23:00 and 06:00, rather than starting at 20:00. Work performed between 20:00 and 23:00 no longer requires a night premium. Also this item featured in the Summer Agreement but was adapted after criticism of the Council of State.
Additional elements:
- Workers already under the previous regime keep their acquired rights.
- Adjustments to work regulations can be made with the approval of only one trade union, significantly reducing the unions’ blocking power.
- The definition of the “distribution sector” now explicitly includes parcel companies such as Bpost, supermarkets and their supply chains, but a precise definition is still up for discussion.
- Also other companies like gas stations and night shops will enjoy this system.
These changes are intended to support late-evening logistics and e-commerce, which increasingly depend on flexible staffing.
7. Abolition of the One-Third Rule for Minimum Working Time
Under the current law, a part-time schedule generally had to include at least one-third of a full-time equivalent workweek. The Autumn Agreement abolishes this rule, replacing it with a minimum of one-tenth of a full-time week—approximately half a day. According to the Summer Agreement, the rule would have disappeared completely, but now the government has decided to impose a new minimum.
Companies will no longer have to include fixed rosters in the work regulations, and smaller, more flexible part-time arrangements become legally possible .
Practical effect:
Employers may now use very small part-time contracts without the need for “on-call” systems like those in the Netherlands, which the government explicitly rejected.
Conclusion
Companies will need to prepare for:
- new payroll complexities due to capped indexation,
- greater obligations (and potential sanctions) in reintegration,
- mandatory working-time recording by 2027,
- broader access to flexi-jobs,
- expanded voluntary overtime,
- more flexible rules for night work, and
- new possibilities for small part-time work arrangements.
These measures will require proactive compliance planning, adapted HR policies, and clear communication with employees. As some of the implementing legislation is still being drafted, the details of the discussed reforms are often still unclear.