Training plan 2026: what to do before 31 March?
Last updated: August 2026
Every year the same deadline comes round without making any noise. By 31 March your training plan has to be settled. And that does not mean writing it up on the day: by then it must already have been submitted, discussed and finalised.
The deadline is often discovered in February, when only a month is left to consult the works council and get the document over the line. Yet the draft has to reach the council at the start of March.
A simple administrative formality? Not quite. This is a legal obligation with a three-date calendar, a minimum content requirement, and an individual entitlement expressed in days for every worker.
In short: from 20 workers onwards you must draw up an annual training plan, settled by 31 March, after the works council has given its opinion by 15 March. Every full-time worker is entitled to 5 training days per year. Between 10 and 19 workers no plan is required, but the individual entitlement of one day still applies.
Is your company affected?
It all depends on your headcount, and the thresholds are not the same for the training plan and for the individual entitlement. A company of fifteen people escapes the plan but still has to grant one training day per worker. Here is how it breaks down (FPS Employment, accessed 31 August 2026).
| Headcount | Annual training plan | Individual entitlement per worker |
|---|---|---|
| Fewer than 10 workers | Not required | No obligation |
| From 10 to 19 workers | Not required | Minimum 1 day per year |
| 20 workers and more | Mandatory, by 31 March | Minimum 5 days per year |
These obligations stem from the Act of 3 October 2022 containing various labour provisions. The individual entitlement stood at 4 days in 2023 and rose to 5 days from 2024. A collective labour agreement concluded within your Joint Committee and made binding by Royal Decree may change that number, but never below two days.
That is the first thing to check before building anything: your sector may already have set its own regime. Our article on collective labour agreements and sectoral agreements explains how to identify what applies to you.
What must the training plan contain?
The content is not left to you entirely. The law imposes a minimum base, and the rest is your call. A plan that simply lists three technical courses without saying what they are for does not meet the condition.
The mandatory minimum content
Your plan must include formal and informal training, explaining how these contribute to the training effort defined at sector level. It must also provide for training that addresses the shortage occupations in your sector.
Three groups call for particular attention: workers aged 50 and over who belong to the at-risk groups, workers of foreign origin and workers with a disability. The plan also has to incorporate a gender dimension.
Outside that base you choose your training freely. The educational content is a matter for your own judgement: what the law frames is the existence of the plan and the coverage of the required elements.
Formal or informal training?
The distinction matters, and it often works in your favour: part of what you already do counts as training. Formal training is the kind you spot easily, with a course, a module or a session that has a programme and a trainer. Informal training covers learning on the job, guidance from an experienced colleague, or the supervised discovery of a new tool.
Training on well-being at work also counts, under the Act of 4 August 1996.
In practice, part of your onboarding process for a new employee already qualifies as informal training. You do still have to describe it in the plan for it to count.
What calendar must you follow?
Three dates, in this order, and the first one is the one people forget. The draft plan has to reach the works council at least fifteen days before the meeting at which it will be examined, which in practice places the deadline in early March. The council issues its opinion by 15 March at the latest. The final content is settled by 31 March.
Where there is no works council, the draft goes to the trade union delegation. Where there is no trade union delegation either, the plan is communicated directly to the workers, by 15 March at the latest. This distinction is worth pausing on, because it explains why 15 March is sometimes presented as the submission date: with a consultation body, 15 March is the date of the opinion; without one, it is the date by which your workers must receive the plan. So there is no company set-up that is exempt from consultation.
Once the plan is settled, two obligations remain. It is filed with FPS Employment through an online application, within one month of its entry into force. And it is kept within the company, where workers can consult it on request, in the same way as your other social documents.
Do you have to start from scratch every year? No. The plan is annual, but nothing stops you from reusing a structure that works and updating the content. What has to be redone every year is the consultation.
What to have ready for early March
The date that pinches is not 31 March: it is the submission date, in early March. Submitting a draft assumes it already exists, and a draft is not written the night before. Three elements need to be gathered beforehand, and none of them depends on a lawyer.
The first is your actual headcount at the reference date: that is what determines whether you are affected and at what level. The second is the review of the past year: which training actually took place, for whom, and how many days that represents per worker. The third is the applicable sectoral framework, since an agreement in your Joint Committee may change the number of days.
With those three elements, drafting the plan becomes a matter of putting it into shape. Without them it becomes improvisation, and the works council will spot that immediately.
Finally, your consultation arrangements are best kept consistent with what your work regulations already provide, since they organise how workers are informed on other matters.
Five days per worker: how do you count them?
The entitlement is expressed in days per full-time worker per calendar year. For everyone else it is calculated pro rata according to their employment and working pattern. A half-time worker therefore opens a right reduced by half, and someone who joins during the year is calculated in proportion to the period worked.
One mechanism softens the exercise: unused days are not lost. They are carried over to the following year, without reducing that year's entitlement. So the worker can build up a balance.
In return, the average counts over time. Over a five-year period, every worker must have received an average of at least five days per year. At the end of those five years, the count starts again from zero.
Working it out for a team, case by case
Take a company with 24 workers, so subject both to the plan and to the five-day entitlement. Here is what is open for three different profiles in 2026.
- A full-time worker present all year: 5 days
- A half-time worker present all year, 50% pro rata: 2.5 days
- A full-time worker who joined on 1 July, six-month pro rata: 2.5 days
That gives 10 days for those three people. If the first worker still has 2 unused days from 2025, they are carried over without reducing the 2026 entitlement, which brings the total to organise to 12 days.
On top of that comes the averaging requirement, assessed over five years. For the period 2026 to 2030, that means 25 days for the first worker, five per year on average. Do not apply that calculation backwards to earlier years: the individual entitlement was 4 days in 2023 and did not yet exist in 2022.
Pro rata and carry-over therefore combine, and it is the total that counts, not the figure for the current year.
If you employ flexible staff, the pro rata follows actual employment: a worker who strings short assignments together does not open the same entitlement as a full-timer over a complete year. It is the same logic as for their pay, which follows the pay scale of the user's Joint Committee.
What do you risk if there is no plan?
The answer is surprising: no formal penalty is provided for as things stand. FPS Employment states this explicitly, while noting that a criminal provision remains possible in future (FPS Employment, accessed 31 August 2026).
That does not mean the obligation has no effect. It plays out on different ground: internal social dialogue. A missing plan becomes a point of tension in the works council, an argument for the unions, and a documentary weakness during an inspection about something else entirely.
There is also a direct consequence for your workers: the individual entitlement to five days exists independently of the plan. Having no plan does not remove the right, it simply deprives you of the tool for organising it.
What happens to the Federal Learning Account?
It is going, and that abolition is now definitive. The Federal Learning Account, the federal platform that was meant to record the training taken and the credit held by each worker, has been abolished since 1 January 2026. After three postponements of the registration requirement, the abolition was formalised by the Act of 14 January 2026 containing various social provisions, published in the Belgian Official Gazette of 21 January 2026 (Securex, accessed 31 August 2026). Registering training and managing entitlements no longer run through that application.
Sigedis, the body that managed the application, keeps the data already entered until 31 December 2026 inclusive and deletes it on 1 January 2027. If you recorded useful data there, this is the year to retrieve it.
A successor is indeed planned, and it shifts the logic. From 1 January 2027, the Individual Learning Account takes over: a digital platform where every citizen consults and records their own training, certificates and diplomas throughout their career, and independently of their employer. Its implementation is being prepared during 2026, through cooperation agreements between the federal level and the Regions.
What should you do in the meantime, in 2026? Keep your own record. The training obligation remains fully in place, only the federal registration tool has gone, and its successor addresses the worker rather than you. An internal record of days taken per worker therefore remains the only way to demonstrate that the entitlement has been respected.
That record does not need to be sophisticated. Four columns are enough: the worker, the date, the name of the training and the number of days. Add the nature of it, formal or informal, since that is the distinction your plan has to reflect. It then serves two purposes at once: feeding next year's plan, and proving that the individual entitlement was respected if the question comes up.
What employers should remember
- Two different thresholds. The training plan applies from 20 workers; the individual entitlement starts at 10 workers, at one day, and moves to five days from 20.
- Three dates, not one. Draft submitted at least fifteen days before the meeting, opinion by 15 March, plan settled by 31 March. Without a consultation body, the plan is communicated to workers by 15 March at the latest.
- The content is framed: formal and informal training, shortage occupations, a gender dimension, attention to workers aged 50 and over, workers of foreign origin and people with a disability.
- Check your Joint Committee first. A sectoral agreement may change the number of days, without going below two.
- No formal penalty as things stand, but a missing plan remains a source of social friction, and your workers' individual entitlement exists without it.
- The Federal Learning Account is abolished since 1 January 2026, definitively confirmed by the Act of 14 January 2026. Data accessible until 31 December 2026 inclusive and deleted on 1 January 2027, when the Individual Learning Account takes over.
How Recruit helps you
A training plan is built on data you should already have: who works for you, under which arrangement, and since when. That is exactly what Recruit keeps up to date for you.
With Recruit:
- Headcount always current - Knowing how many workers you employ, the figure that triggers the obligation
- Working patterns tracked - Full-time, part-time and short assignments, the basis of the pro rata calculation
- Dimona and social documents - Immediate employment declaration and supporting documents kept, available for your annual obligations
- Accurate payroll - Pay aligned with your Joint Committee, including during training days
- Personal support 24/7 - A dedicated contact who knows your file and your sector
Try Recruit or contact our HR experts for tailored advice.
Frequently asked questions
How is the threshold of 20 workers calculated?
The threshold determines both the obligation to have a plan and the move to five days of individual entitlement. The rules for calculating headcount are set out in article 50, §2 and §3, of the Act of 3 October 2022 containing various labour provisions. If your headcount is close to the limit, have the applicable method confirmed for your situation before concluding that you are exempt.
Can I reuse last year's plan?
The structure yes, the process no. The plan is annual: you may reuse a template that works, but the works council must be consulted again every year, within the three-date calendar.
Does welcoming a newcomer count?
Part of the onboarding qualifies as informal training, and that does count. You still have to describe it in the plan and keep a trace of it: informal training with no documentation cannot be relied on.
Are unused days lost at the end of the year?
No. They are carried over to the following year without reducing that year's entitlement. The requirement concerns the average: at least five days per year on average over five years, after which the count starts again from zero.
What happens if I do not file my plan?
No formal penalty is provided for at this stage. Filing with FPS Employment nevertheless remains mandatory, within one month of the plan's entry into force, and its absence will be visible if your file is examined for another reason.
Does the Federal Learning Account still exist?
No, it has been abolished since 1 January 2026, which the Act of 14 January 2026 confirmed. The data already entered remains available until 31 December 2026 inclusive and is deleted on 1 January 2027. On that same date the Individual Learning Account takes over: a platform the worker manages themselves. During 2026, keep your own record of training days per worker.
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.