EU's Pay Transparency Law in Action: Belgium Implementation of the Pay Transparency Directive
Belgium is moving forward in its efforts to implement the EU Pay Transparency Directive, with a target of end 2025/beginning of 2026. However, several details remain unclear as the country works to align its legislation with the Directive.
Currently, there is no legal requirement for a job evaluation system in Belgium. The gender pay reporting requirements in the Directive go beyond existing requirements in the country, but the specifics of the legislation bringing the Directive requirements into force are still unknown.
Employer federations are proactively working on tools to help employers comply with the Directive, and online guidance may also be published by the Ministry of Social Affairs and Employment. Representative bodies, such as the Works Council or the Committee for Prevention and Protection at Work, will have information and consultation rights but no veto right.
One of the key uncertainties is how pay elements will be defined in the implementation of the Directive. It is also uncertain whether the threshold numbers for reporting will be lowered or the deadlines for initial reporting and/or frequency of reporting will be brought forward.
For the purposes of the Directive's pay reporting thresholds, it is possible that the technical business unit will need to be considered, or the threshold may be assessed per legal entity. The implementation legislation in Belgium may provide for both company level and trade union representatives.
Another area of uncertainty is how the requirement for a joint pay assessment will be implemented. No details have been provided on this matter as of yet.
In a positive step towards transparency, legislation is being proposed to amend CBA nr 25 and CBA nr 38 to align with the Directive. However, information on how the Directive obligations will be enforced and potential sanctions is still awaited.
Belgium is also currently in the process of implementing the e-invoicing directive, with the Royal Decree published in July 2025 confirming that e-invoicing for B2B transactions between VAT-registered Belgian companies will become mandatory from January 1, 2026, using the Peppol network and Peppol-BIS standard. This move towards digitalisation is a promising sign of Belgium's commitment to modernising its business practices.
The Directive's definition of a worker is expected to be aligned with national laws in Belgium. The Ministry of Social Affairs and Employment may provide online guidance for the implementation of the Directive, offering further clarity and support to employers as they navigate these changes.
As Belgium continues to work towards implementing the Pay Transparency Directive, it is clear that there are still several uncertainties that need to be addressed. However, with the proactive efforts of employer federations and the Ministry of Social Affairs and Employment, it is hoped that these uncertainties will be resolved in the coming months.
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