Updated: January 8, 2026
Note for international readers: This article focuses on Belgian-specific mobility budget legislation. If you’re an expat or work for a multinational based in Belgium, this applies to your Belgian operations.
Since Minister Crucke’s announcement in late December, Belgian companies have been asking many questions about the mandatory mobility budget. Here’s a complete breakdown of the situation.
📋 Executive Summary
- Political agreement announced on December 23, 2025
- Expected publication: Q1 2026 (January-March)
- Entry into force: 2027 (>50 employees) and 2028 (15-50 employees)
- Exemption: Companies < 15 employees
- Key condition: Company cars for at least 36 months
⏰ Timeline: Where Do We Stand?
December 23, 2025: Political agreement
Minister Jean-Luc Crucke (Mobility) announced a government agreement on the mandatory mobility budget.
Important: This is only a political agreement, not yet a legal text.
January 2026: Finalization of the text
The legal text is currently being finalized in the cabinet of Minister David Clarinval (Employment).
Q1 2026: Expected publication
Remaining steps:
- Text finalization (ongoing)
- Passage through the Council of Ministers (formal approval)
- Submission to the Chamber of Representatives
- Parliamentary work
- Vote in the Chamber
- Royal assent
- Promulgation
- Publication in the Belgian Official Gazette ← moment when the law legally exists
Realistic timeline: End of January at the earliest, March more likely.
🎯 Who Would Be Concerned?
Two cumulative conditions
To be required to implement a mobility budget, your company must meet both conditions:
CONDITION 1: Company cars for 36 months
You must have been providing company cars for at least 36 months (3 years).
💡 Good to know: This rule already exists for the current voluntary mobility budget. It is simply being carried over for the mandatory requirement.
Examples:
- ✅ Fleet for 5 years → Condition met
- ✅ Fleet for 3 years and 1 month → Condition met
- ❌ Fleet for 2 years and 6 months → Not yet concerned
- ❌ Never had company cars → Not concerned
CONDITION 2: Number of employees
The threshold is based on the TOTAL number of employees in the company, not just those with a company car.
Three categories:
| Number of employees | Obligation | Entry into force |
|---|---|---|
| < 15 | ❌ NOT mandatory | Never |
| 15 to 50 | ✅ Mandatory | January 1, 2028 |
| > 50 | ✅ Mandatory | January 1, 2027 |
💼 Concrete Examples
Example 1: Company with 80 people, fleet for 5 years
- ✅ > 50 employees
- ✅ Fleet for 5 years (> 36 months)
- → Mandatory January 1, 2027
Example 2: Company with 35 people, fleet for 4 years
- ✅ 15-50 employees
- ✅ Fleet for 4 years (> 36 months)
- → Mandatory January 1, 2028
Example 3: Company with 120 people, fleet for 2 years
- ✅ > 50 employees
- ❌ Fleet for only 2 years (< 36 months)
- → NOT concerned (as long as 36 months not reached)
Example 4: Company with 12 people, fleet for 10 years
- ❌ < 15 employees
- ✅ Fleet for 10 years
- → NOT concerned (SME exemption)
Example 5: Company with 60 people, never had cars
- ✅ > 50 employees
- ❌ No company cars
- → NOT concerned
🤔 What Remains Unclear (January 2026)
Several points will only be clarified upon publication of the text in the Belgian Official Gazette:
1. Exact employee count
Question: What reference date? Annual average or snapshot on December 31?
Impact: A company fluctuating around 50 employees could be concerned or not, depending on the calculation method.
2. Sanctions
Question: What happens in case of non-compliance with the obligation?
Impact: Fine? Administrative sanction? Nothing specified for now.
3. Implementation deadline
Question: Must the mobility budget be operational on January 1, 2027/2028, or is there a grace period?
Impact: Determines the urgency of preparation.
4. Company crossing a threshold
Question: If a company goes from 49 to 51 employees in June 2027, which timing applies?
Impact: Can create complex situations.
📊 Sources & Methodology
This analysis is based on:
- Securex Lex4You (December 26, 2025) – Detailed legal analysis
- Minister Jean-Luc Crucke’s announcement (December 23, 2025) – Political agreement
- Existing legislation – Current law on voluntary mobility budget
- Official Council of Ministers communiqué (December 23, 2025)
Important note: The legal text has not yet been published. This information is based on political announcements and analysis by legal experts. Changes remain possible until publication in the Belgian Official Gazette.
🚀 How to Prepare?
If you are concerned (>15 employees + 36 months fleet)
1. Analyze your situation (now)
- Count your current employees
- Check since when you have company cars
- Determine which category you fall into
2. Assess the impact (Q1 2026)
- How many employees have a company car?
- What is the current TCO cost of your fleet?
- Which employees would be interested in the mobility budget?
3. Prepare implementation (once text published)
- Choose a management platform (Link2Fleet, MBE, etc.)
- Calculate individual mobility budgets
- Prepare the internal communication plan
- Train your HR teams
4. Launch (6 months before deadline)
- Employee communication (3 months prior)
- User training (2 months prior)
- Tests and adjustments (1 month prior)
- Official launch (D-day)
If you are not yet concerned
But could be soon:
- Monitor the publication of the text
- Track the evolution of your workforce
- Anticipate if you’re approaching a threshold
❓ FAQ
Will the mobility budget be mandatory for ALL employees?
No. The obligation relates to implementing the mobility budget in the company. Employees remain free to choose between:
- Keeping their company car
- Opting for the mobility budget
Can I start now without waiting for the obligation?
Yes! The mobility budget has existed on a voluntary basis since 2019. You can introduce it now if you meet the current conditions (36 months fleet).
Advantage: You get ahead and learn before the obligation.
What happens if I go from 49 to 51 employees?
That’s not yet precisely known. The text will need to clarify whether:
- The obligation applies immediately
- There is a grace period
- It’s based on an annual average
Do consultants/temps count in the thresholds?
That’s not yet known. The text will likely specify whether to count:
- Only permanent contracts
- Permanent + temporary contracts
- Full-time equivalents (FTE)
- All employees
I’m an expat working in Belgium – does this apply to me?
Yes, if you work for a Belgian company (or Belgian branch of an international company) and have a company car, the mobility budget rules apply to you just like Belgian employees.
The budget can be used for:
- Belgian public transport (SNCB/NMBS, STIB/MIVB, De Lijn, TEC)
- International train connections (Thalys, Eurostar within limits)
- Bike rentals and shared mobility in Belgium
📢 Next Steps
I will follow this matter closely and update this article as soon as:
- The text is published in the Belgian Official Gazette
- Official clarifications are made
- The administrations provide specifications
Follow me on LinkedIn for the latest information.
💬 Questions?
Do you have specific questions about your situation?