What changes on 1 January 2027 for employers?
Last updated: October 2026
"What do I need to sort out by January?" Employers ask us that every autumn. This year the answer is less simple than usual, because not everything announced for 1 January 2027 is actually in a law.
For you, that distinction matters most. What is settled, you prepare for. What has not yet been passed, you keep an eye on, without putting time and money into it now as if it were certain.
In this article: what will definitely change, what the cent index means for your wage costs, what is still waiting for a law, which dates to note and how to prepare.
In short: it is settled that the cent index will apply for the first time in Joint Committee 200 (JC 200) at the January 2027 indexation. Sectors now exclude or allow flexi-jobs once a year, an increase in meal vouchers falls under the wage norm again, the CO2 contribution for recent company cars goes up and the data in the Federal Learning Account will be erased. Mandatory time registration, a mandatory mobility budget and a longer solidarity contribution for sickness are planned, but had not yet been passed on 22 October 2026.
What will definitely change on 1 January 2027?
Five changes are settled. The cent index applies in sectors that index in January, such as JC 200. Flexi-jobs get an annual opt-out and opt-in, the wage norm exception for meal vouchers ends, the CO2 contribution for recent company cars rises and the data in the Federal Learning Account will be erased. In addition, as every year, a new quota of hours for student workers starts on 1 January. The table sets these settled changes alongside the planned measures, with their status on 22 October 2026.
| Measure | Status on 22 October 2026 | From |
|---|---|---|
| Cent index in JC 200 | Programme Act of 30 May 2026 | January 2027 indexation |
| Flexi-jobs: annual opt-out and opt-in | Act of 28 June 2026 | 1 January 2027 |
| Meal vouchers back under the wage norm | Exception applies only in 2026 | 1 January 2027 |
| Higher CO2 contribution for company cars from 1 July 2023 | Act of 25 November 2021, factor from 4 to 5.50 | 1 January 2027 |
| Federal Learning Account data erased | Act of 14 January 2026 | 1 January 2027 |
| Mandatory time registration | Preliminary draft bill, National Labour Council opinion of 30 September 2026 | planned for 1 January 2027 |
| Mandatory mobility budget | Preliminary draft bill, National Labour Council and Central Economic Council opinion of 29 April 2026 | planned for 1 January 2027 |
| Solidarity contribution for months 4 and 5 | Preliminary draft bill, National Labour Council opinion of 30 September 2026 | planned for incapacity starting from 1 January 2027 |
| Check-in and check-out on construction sites | Programme Act of 30 May 2026 | 1 April 2027 |
What does the cent index mean for your wage costs?
The cent index limits the indexation of fixed gross base salaries above €4,000 a month, converted to full-time. The part up to €4,000 is indexed as normal. On the part above it, indexation only applies once a wage moderation of 2% has been applied. In JC 200, which indexes once a year, you will see this for the first time in the January 2027 payroll.
The measure is in the Programme Act of 30 May 2026 and has applied since 1 June 2026 (FPS Employment, SD Worx, accessed 18 October 2026; NSSO, accessed 22 October 2026). Sectors that index more often apply it at their first indexation after 1 June 2026. Sectors with an annual indexation in January apply it at their next indexation: January 2027 (Liantis, SD Worx, accessed 18 October 2026).
You will only know the final indexation percentage for JC 200 at the end of December, once the last index figure of the year has been published (Acerta, SD Worx, accessed 18 October 2026). If that percentage is above 2%, the part above €4,000 only loses those first 2%. How indexation works per Joint Committee is explained in our article on wage indexation in 2026.
The wage moderation contribution
You do not keep all of what the cent index saves you. You pay half of that saving to the NSSO as a special wage moderation contribution (Liantis, SD Worx, accessed 18 October 2026).
This arrangement is temporary. From the quarter after the one in which the 2% moderation has been reached for all indexed wages, a provisional consolidated wage moderation contribution follows. It is calculated on all wages with an indexation mechanism, not only on wages above €4,000. A royal decree still has to set out the details. A second moderation period is planned from 1 January 2028, or from a date set by the King (NSSO, accessed 22 October 2026).
For the other contributions, see our overview of employer social security contributions.
Worked example: a white-collar employee on €5,000
Securex worked it out with three assumptions: a gross monthly salary of €5,000, an indexation of 2% and employer contributions of 25% (Securex, accessed 18 October 2026). The calculation follows the formula the NSSO gives for the special contribution.
| Step | Amount per month |
|---|---|
| Normal indexation: 2% on €5,000 | €100 |
| With the cent index: 2% on €4,000 | €80 |
| Less indexation for the employee | €20 |
| Saving including 25% employer contributions | €25 |
| Wage moderation contribution: half to the NSSO | €12.50 |
| What you save for now as an employer | €12.50 |
The actual percentage for January 2027 is not yet known. Even with a higher percentage, the part above €4,000 only loses the first 2%: the employee does receive the rest of the indexation. The amounts will therefore differ, the mechanism will not.
What changes for meal vouchers?
Two things. From 1 January 2027, an increase in meal vouchers falls under the wage norm again: the exception only applies to increases granted in 2026. And if you combine meal vouchers with a meal in the company restaurant, from then on you calculate with a reference cost price of €8.91 per meal instead of €6.91.
In 2026, an increase of up to €2 in the employer's contribution falls outside the wage norm, provided it is granted in 2026. Deciding in 2026 to increase meal vouchers only in 2027 therefore does not qualify for the exception. From 1 January 2027, the usual rules apply again (Acerta, Securex, accessed 22 October 2026).
That cost price only matters if you combine the two. According to the NSSO, there is no problem as long as the price in your company restaurant is not lower than the employer's contribution in the meal vouchers you grant, which is at most €8.91. If the price is lower, you must be able to show that the meal is sold at least at cost price. If you sell below cost price, the employee hands in a full meal voucher for that meal. If that does not happen, the meal vouchers for those days are treated as pay (NSSO, Securex, accessed 22 October 2026).
According to Acerta, the coalition agreement still provides for an increase in meal vouchers, but the date is not known (Acerta, accessed 18 October 2026).
You will find all the conditions in our articles on meal vouchers in 2026 and €10 meal vouchers.
What changes for flexi-jobs?
From 2027, a Joint Committee can only ask once a year to exclude flexi-jobs wholly or partly (opt-out) or to allow them again (opt-in), each time with effect from 1 January. The request must reach the NSSO by 30 September at the latest, and an opt-out only takes effect through a royal decree. For a change on 1 January 2027, the deadline was therefore 30 September 2026 (Acerta, NSSO, accessed 22 October 2026).
This is set out in the Act of 28 June 2026 containing various provisions on flexi-jobs (Acerta, Securex, accessed 18 October 2026). In 2026, sectors could still request an opt-out per quarter (NSSO, accessed 18 October 2026).
Do you work with flexi-jobbers? Then check in early January whether your sector or activity is wholly or partly excluded according to the NSSO list. That list can change on 1 January. What already changed in 2026 is covered in our articles on the new flexi-job rules and on flexi-jobs in all sectors.
What does 1 January mean for student workers?
For student workers, 1 January is above all a reset of the counter. The quota of 650 hours at reduced contributions applies per calendar year. On 1 January 2027, every student therefore starts again with 650 hours, regardless of how many hours they already worked in 2026. From the 651st hour, you pay the ordinary contributions.
That is how the NSSO's administrative instructions put it: the hours are counted per calendar year and can be spread freely over the calendar year (NSSO, NSSO, accessed 18 October 2026).
Sound familiar? A student wants to do a few more shifts in December but is already close to 650 hours. Shifts in December count for 2026. If you move them to January, they fall into the new quota. You will find all the rules in our article on student work in 2026.
What happens to training data?
The Federal Learning Account has been abolished since 1 January 2026. Sigedis, which managed the application, keeps the data entered until 31 December 2026 inclusive and erases it on 1 January 2027. If you recorded data in it that you need to demonstrate your training efforts, retrieve it well before 31 December 2026.
The abolition is in the Act of 14 January 2026, published in the Belgian Official Gazette of 21 January 2026 (Belgian Official Gazette, accessed 25 October 2026; Securex, Acerta, accessed 18 October 2026). Liantis also confirms the data will be kept until the end of 2026 (Liantis, accessed 18 October 2026).
The government is working on a successor, the Individual Learning Account, in which everyone would find their own diplomas and training from 2027. We have not yet found a legal text, and none of the sources describes a new obligation for the employer (Securex, Acerta, accessed 18 October 2026).
Your training obligations do remain. What you need to do is explained in our article on the training plan. The reform of Flemish training leave, for its part, has applied since 1 September 2026, per school year.
Which measures have not yet been passed?
Three measures often linked to 1 January 2027 were not yet law on 22 October 2026: mandatory time registration, the mandatory mobility budget and the extension of the solidarity contribution for sickness to the fourth and fifth month. For all three there is a preliminary draft bill. Their start date may still shift and the details may still change.
Mandatory time registration
The government wants every employer to record working time from 1 January 2027 using a system that is objective, reliable and accessible. Employers that have nothing in place by then would have until 31 March 2027. A traditional time clock would not be needed (Securex, Acerta, accessed 18 October 2026). But as Securex writes, "This date is currently not yet in a final law."
The National Labour Council gave its opinion on the preliminary draft on 30 September 2026, without agreement between employers and unions (National Labour Council, Opinion No. 2.499, Acerta, accessed 22 October 2026). You will find everything about the plans in our article on mandatory time registration in 2027.
Mandatory mobility budget
Employers with at least 50 employees that have been providing company cars for more than 36 months, continuously or not, would also have to offer a mobility budget from 1 January 2027. Employers with 15 to 49 employees would get an extra year. Employers with fewer than 15 employees would fall outside the obligation (Acerta, SD Worx, accessed 18 October 2026).
There is a preliminary draft bill. The National Labour Council and the Central Economic Council issued a unanimous opinion on it on 29 April 2026, calling for administrative simplification (National Labour Council and Central Economic Council, Opinion No. 2.485, accessed 22 October 2026). In May 2026, no bill had yet been tabled (Securex, accessed 18 October 2026).
Solidarity contribution for months 4 and 5
Employers with at least 50 employees pay a solidarity contribution for employees aged 18 to 54 at the start of their incapacity for work, during the second and third month of that incapacity. It applies to incapacity that started on or after 1 January 2026, and does not apply to temporary agency workers, flexi-jobbers and student workers, among others. The NSSO collects it together with the contributions for the third quarter after the quarter in which the incapacity began (Liantis, Securex, accessed 18 October 2026). As a result, no contribution had yet been collected at the end of September 2026 (National Labour Council, Opinion No. 2.500, accessed 22 October 2026).
A preliminary draft bill aims to extend that contribution to the fourth and fifth month, for incapacity starting on or after 1 January 2027. The National Labour Council issued a unanimous opinion on it on 30 September 2026. At that point, the minister had not yet decided which bill the text would go into (National Labour Council, Opinion No. 2.500, accessed 22 October 2026). How the contribution works today is explained in our article on the solidarity contribution and return to work.
Which dates should you put in your diary?
Not everything falls on 1 January. Above all, note 31 December 2026 for the Federal Learning Account data, January 2027 for the indexation in JC 200 and 1 April 2027 for registration on construction sites. If the plans go ahead, 31 March 2027 for time registration and 1 January 2028 for the mobility budget at smaller employers will be added.
| Date | What | Status |
|---|---|---|
| 31 December 2026 | Retrieve the Federal Learning Account data before this date | settled |
| 1 January 2027 | New quota of 650 hours per student worker | settled |
| 1 January 2027 | Meal vouchers back under the wage norm, reference cost price of €8.91 in the company restaurant | settled |
| 1 January 2027 | Annual flexi-job opt-outs and opt-ins take effect | settled |
| 1 January 2027 | CO2 contribution with factor 5.50 for company cars from 1 July 2023 | settled |
| January 2027 | Indexation in JC 200, with the cent index | settled |
| 1 January 2027 | Time registration, mobility budget from 50 employees, solidarity contribution for months 4 and 5 | planned |
| 31 March 2027 | End of the transition period for time registration | planned |
| 1 April 2027 | Check-in and check-out on construction sites with immovable property works from €500,000 excluding VAT | settled |
| 1 January 2028 | Mobility budget also for employers with 15 to 49 employees | planned |
The higher CO2 contribution is not a plan: it has been laid down since 2021 in the Act of 25 November 2021 on the fiscal and social greening of mobility (Belgian Official Gazette, accessed 23 October 2026). It applies to company cars bought, rented or leased from 1 July 2023. The multiplication factor applied to the calculated contribution rises from 4 to 5.50. The non-indexed minimum amount, which you also pay for an electric car, rises from €25.99 to €28.57 (NSSO, Acerta, accessed 22 October 2026). Do not confuse it with the mandatory mobility budget: that also concerns company cars, but has not yet been passed.
The extended registration on construction sites is in the Programme Act of 30 May 2026 and, according to the NSSO, takes effect on 1 April 2027 (NSSO for employers, NSSO for citizens, accessed 18 October 2026).
How should you prepare?
Start with what is settled. Most actions are a check or a decision, not a new system. Only time registration may call for a new tool, and that is exactly the measure that has not yet been passed. The five steps below follow the order of the deadlines.
Step 1. Before 31 December 2026, retrieve the data you entered in the Federal Learning Account, if you need it.
Step 2. Still want to increase meal vouchers outside the wage norm? Then grant the increase in 2026. If you combine them with a company restaurant, check that the price of a meal is not lower than your employer's contribution in the meal vouchers.
Step 3. List, per Joint Committee, the employees whose fixed gross base salary, converted to full-time, is above €4,000. In JC 200 and other sectors that index in January, they will receive the limited indexation in January 2027, and you will pay the special wage moderation contribution for them.
Step 4. Do you work with flexi-jobbers or student workers? In January, check the list of sectors for flexi-jobs and schedule your students with their new quota of hours.
Step 5. Keep track of the three planned measures. For time registration, you can already look at which system suits you, without committing to details that the law still has to set.
What employers should remember
- The cent index applies in JC 200 for the first time in January 2027. The part of the fixed base salary above €4,000 does not get the first 2% of indexation, and you pay half of what you save to the NSSO. A contribution on all indexed wages follows after that.
- Meal vouchers fall under the wage norm again from 1 January 2027. If you combine them with a company restaurant, the price of the meal must not be lower than your employer's contribution in the vouchers, unless you can show the cost price.
- Flexi opt-outs and student worker hours run per calendar year, with 1 January as the starting point.
- Time registration, the mobility budget and the longer solidarity contribution are not yet law. Keep track of them, but do not treat them as certain yet.
How Recruit helps you
The start of a new year always brings changes to your payroll administration. Recruit handles them on one platform.
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
- Clocking app - Your staff clock in and out via the clocking app, so you record hours worked correctly right now. The law is not final yet, but this way you are prepared
- 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
Is mandatory time registration already law?
Not yet. There is a preliminary draft bill, and when we checked on 22 October 2026, the date of 1 January 2027 was not yet in a final law. The government is planning a system that is objective, reliable and accessible, with time until 31 March 2027 for employers that have nothing in place yet.
Does the cent index apply to all my employees?
No. Only the part of the fixed base salary above €4,000, converted to full-time, is indexed in a limited way. Salaries up to €4,000 are indexed as normal. Note, however, that the consolidated wage moderation contribution that follows later is calculated on all indexed wages.
Do I have to increase meal vouchers?
Not always. If your sector requires an increase, you follow your sector's rules. If not, you decide yourself (Acerta, accessed 18 October 2026). Bear in mind that an increase you grant from 1 January 2027 counts towards the wage norm again.
Will small businesses have to offer a mobility budget?
According to the plans, not for employers with fewer than 15 employees. Employers with 15 to 49 employees would follow a year later, on 1 January 2028. This is a preliminary draft: the rules may still change.
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.