Ready for autumn? These are the most important deadlines and tasks for employers

The summer holiday is gradually coming to an end and autumn is just around the corner... A period that often brings many new challenges, changes and important deadlines for employers. Amid the demands of daily business operations, it’s easy for important tasks to occasionally slip through the cracks. That’s why, in this blog post, we provide a chronological overview of the things you should put on your radar now, so that you can head into autumn well-prepared and stress-free.

Social sectoral supplementary pension for white-collar workers in the construction sector

Since 1 January 2023, there has been a sectoral supplementary pension scheme (SAP) for white-collar workers in the construction sector. From 1 January 2026, this will be converted into a social SAP, under which pension rights are also accrued during certain periods of inactivity. Employers who already offer an equivalent supplementary pension can be exempted from contributing to the social sectoral pension scheme. This exemption is not automatic: as an employer, you must formally declare that all white-collar workers concerned receive an equivalent pension and prove this with an actuarial certificate from the insurer. Both documents must be submitted by 15 September 2025 at the latest.

Phasing out of the DAC employment scheme in Flanders

The Flemish Government has decided to completely discontinue the Third Labour Circuit employment measure (DAC) from 1 October 2025. Employers who still have DAC workers must decide whether they can or want to retain them on a regular employment contract. If this is not possible using their own resources, the employer will have to dismiss these workers. You must notify the worker concerned of this dismissal by 30 September 2025 at the latest. 

Annual action plan for wellbeing at work

Every company must have a policy on prevention and wellbeing. This also includes the preparation of a concrete action plan. This plan is drawn up every year in implementation of a five-year global prevention plan. The annual plan must be drawn up no later than two months before the start of the service year. If the service year coincides with the calendar year – which is often the case – then the deadline is 31 October.
The plan must be submitted to the Committee for Prevention and Protection at Work (CPBW). If there is no such committee, it should be submitted to the trade union delegation or directly to the staff.

Using flexible workers during the autumn peak

During the traditional autumn peak, employers can bring in extra help from a pool of flexible workers: pensioners, students, flexi-job workers (workers employed under the Belgian flexi-job scheme) or association workers (workers employed under the Belgian verenigingswerk scheme), for example. Check in good time whether you can (continue to) count on them, as these employment categories often have caps on the number of hours worked or the permitted income.
Therefore, always check with your flexible workers how much more they are able to work. For students, you can check the remaining balance of hours with solidarity contributions yourself, and for flexi-job workers, you can verify whether they meet the conditions to work as a flexi-job worker via the Consult Citizen Data tool.

Year-end bonus

The year-end bonus is traditionally paid to employees in the autumn. If, as an employer, you are required by your sector to grant such a bonus, you must do so according to the agreements in your sector. At company level, you may always provide more favourable terms, such as a higher amount, broader assimilated periods, or an earlier payment date. If there is no sectoral obligation, check whether company-level agreements exist and respect them.

Seasonal gifts

When you think of autumn, you also immediately think of Sinterklaas, Christmas, and New Year. On the occasion of these holidays, you can give your employees a little extra in a parafiscally advantageous way (in some sectors, such as the diamond industry, this is even mandatory). Please note: specific rules from the National Social Security Office (NSSO) and the tax authorities apply. If you follow these rules, gift vouchers are not considered wages. If you want to grant a little extra, plan this in line with the year-end events, so that you can take full advantage of the favourable scheme.

Holiday carry-over

If a white-collar employee is unable to take their holidays before the end of the year due to a force majeure situation, you must pay out those days. The employee may also carry them over to the following two years. Because these days have already been paid, they do not have to be paid again at the time they are taken. Please note: this concerns the situation on 31 December and specific suspensions of the employment contract which are included in an exhaustive list. 

For example: a white-collar employee who starts maternity leave on 1 December 2025 and does not return until February 2026 will be paid for the untaken holidays from 2025. She can take these – if she wishes – as unpaid leave in 2026 and 2027.
However, carrying over holidays remains an exception. In principle, employees must take their holidays before the end of the year. It is therefore strongly recommended to encourage employees who still have many days left in the autumn to schedule them before 31 December this year.

Complying with the average working time requirement

As an employer, you must ensure that the average weekly working time is respected. This means that both compensatory rest (inhaalrust) and working-time reduction (ADV) days must be scheduled in good time. If employees have worked overtime, for example in the context of an extraordinary increase in work, you usually have to grant compensatory rest for this. By the end of the reference period – which is usually a quarter, but is often extended to a (calendar) year – all overtime must have been offset by compensatory rest.
The same applies to taking working-time reduction (ADV) days. These are granted in order to achieve the average weekly working time on an annual basis. If they are not taken in full within the reference period, the average weekly working time is exceeded, which is not permitted. In principle, working-time reduction (ADV) days cannot be carried over to a subsequent reference period.
Even when using flexible work arrangements – such as minor or major flexibility (specific systems of flexible working hours under Belgian employment law) – you must plan work schedules so that the average working hours are correctly met by the end of the reference period, which is often a year.

Replacement public holidays

If a public holiday falls on a Sunday or on another non-working day in the company, you are required as an employer to provide a replacement day of rest. By 15 December at the latest, a notice listing the replacement days for the coming year must be displayed on your company’s premises. A copy of this notice must be added to the company’s work regulations (arbeidsreglement, the mandatory internal rules on working conditions) and a second copy must be sent to the Belgian labour inspection service (sociale inspectie). If you do not set replacement public holidays, the holiday will automatically be replaced by the next working day. 

December settlement

Do you have white-collar employees who have started working fewer hours during the year, for example by switching to part-time work? Then you have to pay out unused holiday entitlements in December. Due to the reduction in working hours, these employees can take fewer holidays than they have accrued. They lose the opportunity to take those days as time off, but they do retain the right to be paid for them. This obligation does not apply to blue-collar workers. 

Reimbursement of VOV (Flemish Training Leave)

As an employer, you must submit your reimbursement application within three months before and three months after the start of the training. The start date is the one shown on the enrolment certificate. In the case of late enrolment, the enrolment date is considered the start date. This deadline is strictly enforced. For example, if the training started on 26 September 2025, you can submit the reimbursement application up to and including 25 December 2025.

Abolition of the starter job obligation

As of 1 January 2026, the government intends to abolish the starter job obligation (startbaanverplichting, a Belgian scheme requiring employers to hire a minimum number of young workers under 26), but this has not yet been finalized. This means that the obligation will still apply in 2025.

Moving towards pay transparency

In May 2023, the EU approved a directive requiring companies to provide greater transparency on their pay policy. The aim: to combat pay discrimination and reduce the gender pay gap. This directive must be transposed into Belgian legislation by 7 June 2026. It introduces new obligations with regard to information, recruitment and reporting. Large companies will have to report for the first time in 2027, based on pay data from 2026.

Although the Belgian legislature still has to work out the details, it is advisable to start taking steps towards transparency now. This way, you will be well prepared when the obligations come into effect.