ILA 2027: does anything change for employers?
Last updated: October 2026
An employee asks how many training days they have left. Last year, you might have looked that up in the Federal Learning Account. Since 1 January 2026, you can no longer record anything there, and what you kept in it will disappear at the end of this year.
At the same time, you read that an individual learning account, the ILA, is coming in 2027. Will you have to record training in it all over again? Based on everything known today: no. Your training obligations do, however, remain in place.
In this article: what the ILA would be, what has already changed for employers, what to do with your FLA data before 31 December 2026, which obligations remain and how to keep track of training yourself from now on.
In short: the Federal Learning Account has been abolished since 1 January 2026 and, according to FPS Employment, there is no longer a legal obligation to record training. You can still view and download your FLA data until the end of 2026. The ILA has been announced for 2027, as a platform for citizens in which the employer records nothing, but on 23 October 2026 we had not yet found a published cooperation agreement or law. The individual training right and the training plan still apply.
What is the Individual Learning Account (ILA)?
The Individual Learning Account (ILA) is the digital platform that the federal government is announcing for 2027. Every citizen would be able to find their own training, diplomas and certificates there. It would succeed the Federal Learning Account, but with a different logic: it would no longer be the employer recording training, but the citizen (Securex, Liantis, accessed 23 October 2026).
Citizens aged 15 and over, the European minimum age for work, would get an overview of their training, diplomas and certificates through a secure application (Acerta, Flemish Government, document in Dutch and French, accessed 23 October 2026). Liantis writes that certificates from recognised training providers would be added automatically. Citizens could upload a certificate from a non-recognised provider themselves. The data would be linked to government databases and to the regional employment services (Liantis, accessed 23 October 2026). According to the Employment policy note of January 2026, (future) employers would also be able to use the ILA, but the data would come from recognised providers and from citizens themselves (Chamber of Representatives, DOC 56 1282/003, 20 January 2026).
Here's the key point: the ILA has to take shape in a cooperation agreement between the federal government, the regions and the communities. On 27 March 2026, a draft of that agreement was before the Flemish Government. The explanatory note to that draft gives no start date (Flemish Government, document in Dutch and French, accessed 23 October 2026). In November 2025, the Flemish Minister for Employment, Zuhal Demir, told the Flemish Parliament that Flanders had not been involved in developing the ILA since the start of the legislative term (Flemish Parliament, report in Dutch, accessed 23 October 2026).
On 23 October 2026, we found no agreement published in the Belgian Official Gazette. The 2027 date comes from the federal government's announcement, as reported by Securex and Liantis: an announcement, not a fixed date.
What changes for employers?
For recording training, most of the change already happened on 1 January 2026. Since that date, you no longer record anything in the Federal Learning Account, which the Act of 14 January 2026 abolished (Belgian Official Gazette of 21 January 2026; careerpro.be, Securex, accessed 23 October 2026). According to FPS Employment, there is no longer any legal obligation to record training either, apart from what your sector-level collective labour agreement (CLA) requires (FPS Employment, accessed 23 October 2026). The ILA would not change that in 2027.
One nuance. Article 55 of the Act of 3 October 2022 is still on the statute book. An employer that grants the training right without a sector-level CLA, through an individual training account, keeps a form per employee, including the training credit and the number of training days taken. That employer also informs the employee of the balance at least once a year. Only the choice between that account and the FLA has been removed: that choice applied until the end of 2025 (Act of 3 October 2022, Article 55, accessed 23 October 2026).
FPS Employment does, however, regard the internal training account scheme as having ended with the abolition of the FLA. If in doubt, ask your social secretariat how it applies this.
| Until the end of 2025 | Since 1 January 2026 | From 2027 (announced) | |
|---|---|---|---|
| Recording training | in the FLA or in your own system | no obligation according to FPS Employment, unless your sector-level CLA requires something; Article 55 on the training account is still in the law | as in 2026; the ILA adds nothing for the employer, as far as we know |
| Who records? | the employer | the employer that works with a training account | the employer with a training account; in the ILA, the citizen, with certificates from recognised providers added automatically |
| Tool | Federal Learning Account | FLA for viewing only | Individual Learning Account |
| Training right and training plan | apply | apply | apply; a reform has been announced |
The other changes for employers around the turn of the year are in our overview of what changes on 1 January 2027.
What to do with your FLA data before 31 December 2026?
Download it if you need it. Until the end of 2026, you can still view two things in the FLA: the number of training days your employees were entitled to on 31 December 2025, and the training you recorded up to and including that date. Entering new data or changing anything is no longer possible (careerpro.be, Social Security portal, accessed 23 October 2026).
You download the data via federallearningaccount.be, with your eID or itsme. Sigedis also makes it available through a web service and in batch. Your social secretariat or another authorised representative can view it on your behalf, and your employees can see their own training account on mycareer.be (careerpro.be, Social Security portal, accessed 23 October 2026).
Do not wait until the last day. Under the Act of 14 January 2026 (Article 9), Sigedis keeps the data until 31 December 2026 inclusive, and it is destroyed on 1 January 2027 (Securex, Acerta, accessed 23 October 2026). FPS Employment, careerpro.be and the social security portal speak of permanent deletion on 31 December 2026 (FPS Employment, accessed 23 October 2026). So retrieve it well before 31 December.
If you used the FLA, each employee's balance on 31 December 2025 is the most useful figure: it is your starting point for continuing to track the training credit. Using the FLA was optional: you could also keep your own training account (Acerta, accessed 23 October 2026). If you kept your own training account, start from that balance.
Which training obligations still apply?
All the substantive ones. Abolishing the FLA changes nothing about your employees' individual training right, nor about the training plan. The FLA was only the tool for recording training. What you have to offer depends on the size of your business and on your sector (Securex, accessed 23 October 2026). How to draw up the plan and which timetable to follow is explained in our article on the training plan.
The individual training right
In a business with 20 or more employees, every full-time employee is entitled to 5 training days a year, unless your sector-level CLA sets a different number, with a minimum of 2. If your business has 10 to fewer than 20 employees, it is at least one day per full-time employee. Below 10 employees, there is no individual training right, unless your sector imposes one (FPS Employment, Securex, accessed 23 October 2026).
You count those thresholds in full-time equivalents, based on average employment over a reference period, not in headcount. With many part-time or temporary staff, the difference can be large. With 10 to fewer than 20 employees, you also set each year, before 30 September, how many training days your employees are entitled to that year (Act of 3 October 2022, Articles 50 and 58, FPS Employment, accessed 23 October 2026).
The 5 days are an average over five years. The first period runs from 1 January 2024 to 31 December 2028. Days not taken carry over to the next year, and at the end of the period the counter goes back to zero (FPS Employment, accessed 23 October 2026).
The training plan
From 20 employees, you draw up a training plan every year. The works council or the union delegation gives its opinion by 15 March at the latest. If there is no works council or union delegation, you submit the draft directly to your employees by 15 March at the latest. The plan is adopted before 31 March (Act of 3 October 2022, Article 36, FPS Employment, accessed 23 October 2026). Within a month of it coming into force, you file a copy via transfert.emploi.belgique.be (FPS Employment, accessed 23 October 2026).
What your sector can impose
A sector-level CLA can set a different number of days, but not fewer than 2 days, and not fewer than what was already granted if that was more than 2 days. It also contains a growth path and the list of training that counts, and it may have its own rules on recording (FPS Employment, accessed 23 October 2026). If that CLA has been made generally binding and you do not follow its training rules, you commit an offence under the Social Criminal Code (FPS Employment, accessed 23 October 2026). So check first what your Joint Committee provides.
How many training days for part-time or temporary work?
A share of the full entitlement. If someone does not work full-time or not for the whole year, you calculate the training days with the formula A x B x C. A is the number of days for a full-time employee in your business, B the employee's working arrangement, C the number of months in service divided by twelve. Every month started counts as a full month (FPS Employment, accessed 23 October 2026).
Even a temporary worker who is only in service for a few months builds up a share in this way. If temporary staff are on your own payroll, you therefore have many short periods to track. If they work through a temp agency, that tracking lies with the agency (see below). What else applies to student workers is explained in our article on student work in 2026.
Worked example: four employees in 2026
Assumptions: a business with 20 or more employees in full-time equivalents, with no sector-level CLA setting a different number of days. A is therefore 5.
| Employee | A x B x C | Training days in 2026 |
|---|---|---|
| Full-time white-collar employee, in service all year | 5 x 1 x 12/12 | 5 |
| Part-time employee 4/5, in service all year | 5 x 0.8 x 12/12 | 4 |
| Half-time employee, in service since 10 September | 5 x 0.5 x 4/12 | 0.83 |
| Full-time temporary worker, only in July and August | 5 x 1 x 2/12 | 0.83 |
The half-time employee counts four months, because September is a month started. The result is sometimes less than one day. The law allows you to express a training day in hours, based on a normal working day of a full-time employee (Act of 3 October 2022, Article 50, accessed 25 October 2026). The formula does not say how to round: set that in your own tracking, or follow what your sector-level CLA provides.
In law, every entitlement is individual: you cannot give one employee's days to another. A collective arrangement is only possible through a CLA (FPS Employment, accessed 23 October 2026).
Temp workers
For a temp worker, the obligation lies with the temp agency, because the agency is the legal employer. If you, as the user company, have a temp worker attend training, you do so voluntarily, on top of what the temp agency has to do (FPS Employment, page in Dutch: the French version of the FAQ does not cover this point, accessed 25 October 2026). You can read more about this three-way relationship in our article on temporary agency work in Belgium.
What else is the government planning for training rights?
A reform, but it has not yet been carried out. The coalition agreement of 31 January 2025 aims to keep the individual training right, but to make it more flexible and partly organise it collectively, focusing on the employees who need training most (Securex, Acerta, accessed 23 October 2026). Under that agreement:
- Short contracts would be excluded: including flexi-jobs, seasonal workers and students.
- Accrued training rights would no longer be converted into pay.
- The special rules for small businesses would remain: no training right below 10 employees, a lighter scheme from 10 to fewer than 20.
In January 2026, the Employment policy note reported that a preliminary draft bill to implement this measure was being prepared (Chamber of Representatives, DOC 56 1282/003, 20 January 2026). Today, the remaining training credit still counts as an acquired benefit in the event of dismissal with payment in lieu of notice (FPS Employment, accessed 23 October 2026). When we checked on 23 October 2026, we found no law implementing the plans. Until there is one, the rules above apply.
How do you keep track of training without the FLA?
In your own records. According to FPS Employment, you no longer have to record training, but you do need the data. An employee can always ask for the status of their training credit, and you have to make sure your employees can take, on average over five years, the days they are entitled to (FPS Employment, accessed 23 October 2026). Keep that overview with your personnel records, alongside your social documents.
We recommend recording, per employee, the date and duration of each training course, whether it was formal or informal, and the credit balance. If you work with an individual training account, follow the Article 55 form. Start from the balance on 31 December 2025, taken from the FLA or from your own training account.
When a contract ends, that overview matters twice over. In principle, the employee should have received all the days they are entitled to before the end. In the event of dismissal without serious cause, the employee may still take the accrued credit. That does not apply to dismissal for serious cause, or if the employee resigns (FPS Employment, accessed 23 October 2026). According to FPS Employment, the employee may also take the credit when the contract is ended by mutual agreement (FPS Employment, FAQ, accessed 25 October 2026).
Do you expect employees to take certain training courses, for example on safety? Disciplinary sanctions for those who do not must be set out in your work regulations (FPS Employment, accessed 23 October 2026).
How should you go about it?
These five steps get you ready for 2027. Start with your FLA data, which has a hard deadline of 31 December 2026. You have more time for the rest, but it pays to have your own tracking ready before you draw up the training plan for 2027.
Step 1. Before 31 December 2026, download your FLA data: the balance per employee on 31 December 2025 and the training recorded.
Step 2. Work out which rules apply to you: your number of employees in full-time equivalents, your sector-level CLA and whether you need a training plan.
Step 3. Set up your own tracking, per employee, with the balance on 31 December 2025 as the starting point.
Step 4. Calculate the entitlement of part-time and temporary employees with the formula A x B x C.
Step 5. Keep an eye on the ILA and the training right reform. Only a legal text will tell you what really changes in 2027.
What employers should remember
- No more obligation to record training since 1 January 2026 according to FPS Employment, unless your sector-level CLA requires something. Article 55 on the individual training account is, however, still in the law.
- Download your FLA data before 31 December 2026: after that, it is gone.
- The ILA has been announced for 2027, as a platform for citizens in which the employer records nothing. There is only a draft cooperation agreement; on 23 October 2026, we had found no published agreement or law.
- The training right and training plan remain: an average of 5 days from 20 employees, unless your sector-level CLA sets a different number (at least 2), at least one day from 10 to fewer than 20. Those who do not work full-time or the whole year get a pro rata share.
How Recruit helps you
An employee's training right depends on the size of your business and your sector, but also on the contract, the working arrangement and the period of service. Those last details are set out in every contract.
With Recruit:
- Accurate payroll - Pay aligned with your Joint Committee and the legislation in force
- Flexible staff paid correctly - Students, flexi-jobbers and temporary staff, each according to their status
- Dimona and social documents - Immediate employment declaration and records kept
- Digital contracts - Every employment recorded with its own period and working arrangement
- Training rights handled by us - For your temp workers, Recruit is the legal employer. We track their training rights, so you do not have to keep any records for them
- Personal support - On weekdays from 9am to 5pm, and for priority matters a personal account manager directly on the line
Try Recruit or contact our HR experts for tailored advice.
Frequently asked questions
Do I have to record training in the ILA as an employer?
Not according to current announcements. In the ILA, the employer would record nothing: the citizen would do so, and certificates from recognised providers would be added automatically (Securex, Liantis, accessed 23 October 2026). As long as there is no legal text, that may still change.
Do training days transfer to a new employer?
No. The law does not provide for training days to transfer from one employer to another, and a CLA cannot depart from that (FPS Employment, accessed 23 October 2026).
Does Flemish training leave count towards training rights?
No. Flemish training leave is separate from the individual training right: those days do not count towards the 5 days (FPS Employment, accessed 23 October 2026).
Do I risk a penalty if I do not follow the rules?
It depends on the rule. For the statutory training right and the training plan, the law does not currently provide for a penalty, although a criminal provision may follow later. If a sector-level CLA made generally binding imposes training rules, however, you commit an offence under the Social Criminal Code if you do not follow them (FPS Employment, training right, FPS Employment, training plans, accessed 23 October 2026). Training that is needed to do the job, and that you must offer under a law or a CLA, must also be free of charge for the employee.
What if I do not download my FLA data in time?
Then it is gone for good. Employees who want to know which training they took or how many days they are entitled to will have to contact their (former) HR department (FPS Employment, accessed 23 October 2026). Without that data, you reconstruct the balance yourself.
The information in this article is provided for general guidance only and does not replace professional legal advice. Labour legislation changes regularly. Always consult the legislation in force or contact an HR expert for advice suited to your situation.