Be Aware - June 2026

Belgium is one of the few countries where nearly all workers are covered by a system of automatic indexation of remuneration. But there is no generally applicable legislation so nearly all joint committees have a collective bargaining agreement on indexation, using various systems.

Some joint committees index pay every year on a specific date, for instance on 1 January for the national auxiliary joint committee for white-collar employees (n° 200). Other joint committees increase salaries by 2% each time the consumer price index increases by 2%, for instance the joint committees for the chemical industry (n° 111 and n° 207).

The indexation has an impact on the budget for the Belgian state for three reasons:

• A higher remuneration because of indexation means a higher calculation basis for the taxes and social security contributions employers pay.
• Remuneration of staff employed by the Belgian state is also subject to an automatic indexation.
• Most social security benefits paid by the Belgian state, notably retirement pensions, are also subject to automatic indexation.

Although the coalition agreement stipulated the government would – by the end of 2026 at most – update the automatic indexation, on 28 May 2026 Parliament approved a Programme Act with a substantial impact on the indexation mechanism. The Official Journal of 1 June 2026 includes the publication of this Programme Act, which entered into force on that date.

While indexations used to be easy from an administrative point of view, the new Programme Act definitively changes this.

 

The scope of the Act

The scope of the Programme Act is very wide and covers all employees in the public and private sector covered by the Belgian social security regime.

The changes don’t, however, apply to workers with reference remuneration not exceeding EUR4,000 gross per month. The reference remuneration is “the indexed fixed monthly basic remuneration” either according to the remuneration scales or the contractual remuneration if latter is higher.

In Parliament the Minister confirmed this means “the structural and unconditional minimum” of the remuneration package. Parliamentary Works state holiday pay and the 13th month payment are excluded for assessing this threshold. They also confirm premiums for weekend work are excluded. The same holds for variable remuneration depending on uncertain factors for instance commissions for sales representatives.

Benefits in kind (eg a company car) are excluded as well, as these are not indexed in the first place.

For part-time employees, this threshold of EUR4,000 is assessed on a hypothetical full-time basis. Under the Programme Act, an employee working on a half-time basis earning EUR3,000 gross per month therefore earns EUR6,000 and exceeds the threshold.

 

Key principles

If an employee earns more than EUR4,000 gross per month, as of 1 June 2026:

• The first EUR 4,000 is in principle still indexed according to the existing rules, but subject to a maximum of 2% indexation.
• The portion of salary above EUR4,000 is temporarily no longer indexed as of 1 June 2026.
• This temporary suspension of the indexation ends when the amount of the employee’s remuneration reaches the initial amount of the remuneration, indexed by 2% by adding the indexations allowed under the Programme Act. At that moment, the normal indexation mechanism resumes in full.

The moment when step three is reached depends on the indexation mechanism used and inflation, so for now this moment is still unknown.

The Programme Act stipulates a similar rule for a temporary suspension of the indexation of most social security benefits.

 

Rule when normal indexation exceeds 2%

If the normal indexation exceeds 2%, the full remuneration is indexed by a percentage equalling the difference between the normal indexation and 2%. This comes on top of the indexation by maximum 2% applied to the first EUR4,000 gross.

For example, if an employee earns EUR10,000 gross per month and the indexation is 2.2%, the indexation under the Programme Act equals the sum of EUR20 (0.2% of EUR10,000) and EUR80 (2% of EUR4,000). The difference between the uncapped remuneration would be EUR120 gross per month.

 

Two moderation periods

The Programme Act stipulates a first moderation period starting on 1 June 2026 and ending when the 2% cap is reached. As inflation in Belgium currently stands at around 3.4% per year, this first moderation period will generally last less than one year.

The Programme Act stipulates a second moderation period starting on 1 January 2028.

The same mechanism for a temporary suspension of the indexation will apply during this second moderation period. The remuneration cap of EUR4,000 gross per month would nevertheless be indexed for this second moderation period.

 

New social security contributions

Not applying the automatic indexation in full has a negative impact for the employee, but also for the Belgian state. Limiting indexation also reduces the calculation basis of the tax withholdings and social security contributions.

The draft Act introduces a new temporary and a new definitive social security contribution to counter this effect. The new temporary employer contribution equals 50% of the cost saving for the employer resulting from the fact the remuneration is only partially indexed.

The Programme Act stipulates that for workers entering into service as of 1 June 2026, the Programme Act should be applied assuming this employee received the indexations applicable at the employer from the start of the moderation period involved.

If an employee joins an employer under the national auxiliary joint committee (n° 200, where there is an annual indexation on 1 January) in March 2027, the new social security contribution for the “non-applied” indexation on 1 January 2027 will be due, even if the employer and the employee negotiated the remuneration in February 2027.

A future Royal Decree will determine the precise calculation modalities of this new social security contribution.

This new temporary social security contribution applies both to the cost savings resulting from the 2026 moderation period and those resulting from the 2028 moderation period.

The (partial) non-indexation during the 2026 and the 2028 moderation period can be effective as long as the employee remains in service. Each indexation is calculated on the remuneration as resulting from the indexations in the past, hence partially skipping one indexation in the chain implies the remuneration will continue to be lower compared to if there had never have been any partial suspension of the indexation.

For the period after the second moderation, employers will have to pay a consolidated special salary moderation contribution. The Programme Act doesn’t set any end date for this contribution.

The Programme Act merely stipulates this consolidated contribution will only be due on the part of the remuneration exceeding the threshold of EUR4,000 gross per month (as indexed from time to time).

A future Royal Decree will determine the precise calculation modalities of both the temporary and the consolidated contribution.

 

Sanctions for infringement

The Programme Act stipulates that all covered employers should respect the restrictions on the indexation stipulated in the Act and that any agreement to the contrary is void.

But it doesn’t stipulate any sanction if an employer disregards the restrictions on the indexation and grants a full indexation.

This employer will then have to pay both the full indexed remuneration and the new social security contributions introduced by the Programme Act. It could also be that by granting a full indexation, the employer infringes the Salary Moderation Act of 26 July 1996, which can lead to administrative fines.

The rules concerning the payment modalities for this new contribution are the same as the ones for normal social security contributions. The non-payment of the new contributions can lead to the usual sanctions for non-payment of social security contributions.