Four months remain before 1 January 2027, and the bill that is meant to make the mobility budget mandatory still has not been voted.<\/p>\n\n\n\n
The draft bill was approved by the Council of Ministers on 9 January 2026. On the same day it was sent for opinion to the Council of State, the National Labour Council and the Central Economic Council. The two Councils issued their joint opinion on 29 April. Nothing has been made public since.<\/p>\n\n\n\n
We meet a great many companies that conclude they should wait for the final text before starting. That is a scheduling mistake, and this article explains why: what remains uncertain is not what takes time, and what takes time does not depend on the text.<\/p>\n\n\n\n
A point of procedure first, because it usually circulates the wrong way round. The Council of State’s opinion is not a step that follows the one from the social partners: all three bodies were seized at the same time, on 9 January. The legislation section’s opinion is not public at this stage, which is entirely normal, as those opinions are usually published as an annex to the parliamentary document when the bill is tabled.<\/p>\n\n\n\n
What remains, then: a second reading in the Council of Ministers, tabling in the Chamber, committee stage and the vote. Four months, parliamentary recess included.<\/p>\n\n\n\n
That timetable deserves to be read with some memory. In 2025, the obligation had already been dropped from the programme act. The scheme was initially meant to enter into force in 2026, then in 2027. We are not predicting anything, but we would not present 1 January 2027 as a certainty.<\/p>\n\n\n\n
None of which changes what follows. The companies concerned have every interest in being ready for that date, and the preparatory work keeps its full value even if the deadline slips again.<\/p>\n\n\n\n
The obligation would apply to any employer that has been making one or more company cars available to at least one employee for 36 months or more. The timetable would be staggered by size:<\/p>\n\n\n\n
One clarification that costs those who miss it: the threshold is counted on the company’s total headcount, not on the number of people who have a company car.<\/strong> This is the most frequent misreading we come across. A company with 80 employees, of whom only 12 drive a company car, is covered on 1 January 2027, not in 2028.<\/p>\n\n\n\n Note finally that the obligation bears on the offer, not on take-up. The employer will have to offer the mobility budget; the employee will remain free to take it or not.<\/p>\n\n\n\n The mobility budget in the workplace<\/a> allows an employee to exchange their company car, or their entitlement to one, for a budget they allocate freely across three pillars.<\/p>\n\n\n\n Pillar 1<\/strong> funds an environmentally friendly company car. Since 1 January 2026 that notion has narrowed: only a zero-CO2 car still qualifies.<\/p>\n\n\n\n Pillar 2<\/strong> covers sustainable mobility in the broad sense. Bicycles, scooters and electric mopeds, public transport passes and tickets, organised collective transport, carpooling, car sharing, taxis and car rental up to 30 days a year, combined mobility services, parking costs linked to public transport, a kilometre allowance, a pedestrian premium. And, under conditions, housing costs, rent or mortgage interest, for those living within a 10 kilometre radius of their main place of work.<\/p>\n\n\n\n That last criterion is more contested than it looks. The main place of work can, in some cases, be the home itself, in particular where the employee works remotely most of the time and the employer recognises it as such. The 10 kilometre condition is then satisfied automatically, and this is one of the reasons housing costs now take up such a large share of pillar 2. We devoted a full analysis to this question: Mobility budget, housing costs and remote work<\/a>.<\/p>\n\n\n\n Since 2026, vehicles funded under this pillar must also be zero emission.<\/p>\n\n\n\n Pillar 3<\/strong> pays out the balance in cash, once a year, less a special social security contribution of 38.07 % borne by the employee.<\/p>\n\n\n\n The size of the budget derives from the employer’s total cost of ownership of the car the employee gives up. Since 1 January 2024, the employer chooses between a calculation on actual costs and a flat-rate calculation, and that choice applies to all employees for three years. In 2026, the budget must fall between 3,233 euros and one fifth of gross annual pay, with an absolute cap of 17,244 euros.<\/p>\n\n\n\n If the scheme is still unfamiliar, our mobility budget FAQ<\/a> answers the fifteen questions that come up most often, and our analysis of the NSSO figures<\/a> gives a sense of how the scheme is actually used in Belgium.<\/p>\n\n\n\n The joint opinion of the National Labour Council and the Central Economic Council, issued on 29 April 2026, sets out several requests. These are recommendations: the government has not responded to them, and none appears as such in the draft bill.<\/p>\n\n\n\n Capping housing costs at 50 % of the budget.<\/strong> The wording of the opinion deserves close reading: the limitation would apply to “new mobility budgets granted from the date the law enters into force”. Budgets already running would therefore not be affected. Today, no limit exists at all.<\/p>\n\n\n\n A broader pillar 2 offer.<\/strong> Current law only requires the employer to offer a single spending option to be compliant. The Councils strongly recommend opening a company-level dialogue in order to offer several, matching employees’ real needs, and announce monitoring to be evaluated during 2029. No amount, no percentage, no quantified floor: it is a recommendation on method.<\/p>\n\n\n\n Dated easings.<\/strong> Combustion-engine sharing solutions would remain allowed until end 2029, the electric offer being considered insufficient. Employers would be able to exclude, until end 2029, certain clearly defined categories of employees in itinerant roles for which a car is required.<\/p>\n\n\n\n A threshold that is not workable as drafted.<\/strong> The Councils note that there is no NSSO size code corresponding to 15 employees, and ask for clarification on the moment at which headcount is assessed, and on what happens to the obligation if it later falls back. That technical detail says a good deal about how finished the text is, four months from the deadline.<\/p>\n\n\n\n A percentage set by arbitration has a structural flaw: it gets renegotiated at every legislature, with nobody able to say whether it is too high or too low, for want of a yardstick. Why half, and not 40 or 60 %?<\/p>\n\n\n\n We have proposed reversing the logic. Rather than capping housing from above, guarantee mobility from below, through a floor of real mobility spending that the budget must cover first. That floor can be costed on prices that already exist: a Brupass XL season ticket, an electric bike on lease, a reserve for one long-distance train journey. Around 300 euros a month.<\/p>\n\n\n\n The full reasoning, with the detail of the calculation and the comparison with the statutory minimum, is in our analysis Mobility budget and housing costs: a mobility floor rather than a cap<\/a>.<\/p>\n\n\n\n A percentage gets negotiated. A floor gets calculated.<\/p>\n\n\n\n Here is the heart of the matter. What remains uncertain in the reform concerns parameters: the fate of housing costs, the breadth of the pillar 2 offer, a few temporary exclusions. Parameters can be changed in an afternoon. What takes months, by contrast, depends on none of those arbitrations.<\/p>\n\n\n\n The mobility budget is calculated on the total cost of ownership of the vehicle the employee gives up. Until that figure exists, job category by job category, you cannot announce anything to anyone.<\/p>\n\n\n\n This is not a trivial accounting exercise. You need to bring together lease rentals, fuel or electricity, insurance, taxes, maintenance and parking, and settle on a realistic annual mileage assumption. Many companies discover in the process that their car policy costs appreciably more, or sometimes less, than they believed. That is useful information well beyond the mobility budget.<\/p>\n\n\n\n Allow two to three months if the data sits scattered across leasing, finance and HR, which is the case almost everywhere.<\/p>\n\n\n\n This is the most underestimated workstream, because it looks like drafting when it is in fact decision-making.<\/p>\n\n\n\n It is also where the answer lies to the two objections we hear most often from employers who have not yet taken the step. Those objections never take the form of waiting, but of a very concrete worry.<\/p>\n\n\n\n “I don’t want the mobility budget. What do I do if a sales rep takes it and can no longer get to my clients?”<\/p>\n\n\n\n “My junior consultants will take it to fund their housing, fine. And the day they have an assignment 100 kilometres away, on an industrial estate?”<\/p>\n\n\n\n Those fears are well founded and describe situations we have seen. The social partners have in fact identified them: they ask that employers be allowed, until end 2029, to exclude certain clearly defined categories of employees in itinerant roles for which a car is required.<\/p>\n\n\n\n But they also rest on a misunderstanding worth clearing up. The bill on the table will oblige the employer to offer a budget, not to let each employee dismantle their own ability to work.<\/strong><\/p>\n\n\n\n And above all, what many are waiting for the text to settle can already be settled with a policy and some communication. The solutions we put in place are usually quite simple, and not one of them requires waiting for anything.<\/p>\n\n\n\n No policy can anticipate every possible case, and it would be exhausting to try. That is why we systematically write a principle clause into the policies we draft:<\/p>\n\n\n\n An employee’s choice may in no way prevent them from doing their job.<\/strong><\/p>\n<\/blockquote>\n\n\n\n One line, and the two situations above are settled without ever having to be foreseen. It places responsibility for the trade-off where it already sits, with the person making it, and it spares the employer from having to adjudicate every individual case.<\/p>\n\n\n\n It has a second merit, more important than it looks: it leaves freedom where freedom belongs. If an employee chooses to drive to a client on their own motorbike, electric or not, or in their sports coup\u00e9, that is their business and not their employer’s. What concerns the employer is that the work gets done, not how each person gets there. A well-written policy sets an obligation of result, not a catalogue of authorised means.<\/p>\n\n\n\n Finally, it avoids starting with prohibition. An employer can always restrict later, for extreme cases, once they have actually observed some. Starting with restriction amounts to closing doors before knowing which ones were useful, and that is how you end up with a long, rigid policy that is already out of date on the day it is published.<\/p>\n\n\n\n The clause is worth nothing if nobody has read it. Communication has to reach everyone entitled to the budget, and it counts above all at two moments: when the scheme is introduced, and at the end of the lease contract, when the choice is genuinely on the table.<\/p>\n\n\n\n The second moment is the one most often forgotten. Yet it is the only one at which the employee actually decides, sometimes three years after first hearing about the mobility budget. Information given only at launch produces decisions made from memory, on outdated figures.<\/p>\n\n\n\n Some trade-offs are simple and take care of themselves. Others are not: the employee who moves house, the one whose role changes, the one hesitating between keeping a car and switching to a combination of modes. Those cases deserve time, because they are where the bad surprises come from.<\/p>\n\n\n\n And there has to be follow-up afterwards. Do not assume everything is fine because nobody is complaining: go and look. A trade-off that causes problems is easy to correct if spotted early, and becomes a tiresome case if it surfaces six months later.<\/p>\n\n\n\n To which are added the more conventional questions: what happens on departure mid-year, on a change of role, a promotion or a move to part-time; what is offered to someone who has no car today but would be eligible; how a running lease contract is handled when the employee switches; what becomes of an unspent budget at year end.<\/p>\n\n\n\n Each is decided once, written down, and becomes hard to walk back once announced to the teams. Better to settle them calmly in September than under pressure in January.<\/p>\n\n\n\n This is the point most often missing from the discussion, and it defuses a good part of the fear. Taking the mobility budget does not mean giving up on cars altogether. Pillar 1 funds one, and the balance remains available for the rest.<\/p>\n\n\n\n Many people come out ahead, in fact. A smaller, lighter car, together with a speed pedelec for appointments within a 30 kilometre radius, is often better than a large saloon. The role stays covered, the cost falls, and mobility gains options. Not everyone wants to put their entire budget into a car. It is exactly the reasoning we set out on sizing vehicles and batteries<\/a>: the right vehicle is often one notch below the one you were about to order.<\/p>\n\n\n\n These three solutions stand on their own. Three points of framework are nonetheless worth knowing, because they widen the room for manoeuvre.<\/p>\n\n\n\n The employer composes the pillar 2 menu, and that is true today.<\/strong> The official mobility budget website is explicit: the employer chooses which spending options to offer, in line with their own mobility policy, the only obligation being to offer at least one among the sustainable transport modes. Housing costs appear on the list, but nothing requires them to be offered. An employer whose people work on poorly served industrial estates also has every reason to include car sharing and short-term rental, allowed up to 30 days a year.<\/p>\n\n\n\n The lever on access will change in nature.<\/strong> Today, an employer can refuse access to the mobility budget for certain roles, on objective criteria. The reform will remove that option, but will in exchange allow the employer to make pillar 1 compulsory for certain roles, on an objective, non-discriminatory and proportionate criterion based on the nature of the role and a legitimate business interest. That is a finer instrument than a ban: the vehicle is guaranteed where the role requires it, and the balance of the budget stays free.<\/p>\n\n\n\n And business travel remains funded from the employee’s budget.<\/strong> This is the point most often misunderstood, and the one that resolves the industrial estate example. The budget derives from the total cost of the company car, which served business trips as much as anything else. An employee who allocates their entire budget to housing has therefore knowingly consumed the means of getting to a client. The employer does not have to compensate, and would be wrong to do so by reflex: they would pay twice for the same mobility. They may<\/em> make pool vehicles available. They are not obliged to.<\/p>\n\n\n\n The problem, however, does not go away. It is simply not a legal problem, it is an operational one: if the assignment does not get done, it is the company that loses it. And that, no text will solve on its behalf.<\/p>\n\n\n\n Transport passes, bike leasing, shared mobility, kilometre allowance, housing costs. These are not lines in a work rules document: they are contracts to negotiate with suppliers, flows to connect to payroll, supporting documents to collect and check, and often a management platform to select and configure.<\/p>\n\n\n\n This is by far the longest workstream, and it is also the one that determines whether the scheme actually gets used. A mobility budget whose pillar 2 is reduced to a single option is legally compliant and of no interest to the employee. That is precisely what the social partners are pointing at.<\/p>\n\n\n\n These three workstreams run in parallel. None depends on the final text. All three take two to three months. It is September.<\/p>\n\n\n\n The companies that come out of this best are not those that waited longest for the text, they are those that started with their own numbers.<\/p>\n\n\n\n We support very different employers on this, each with their own constraints: consultants permanently on the road, poorly served industrial sites, workforces spread across the three Regions. The implementations at Brightwolves<\/a> and at Speos<\/a> give a sense of what the work involves in practice.<\/p>\n\n\n\n One observation recurs everywhere: the mobility budget cannot be handled in isolation. It touches the car policy, therefore the fleet, therefore vehicle renewal and, for many companies, the electrification of the vans running alongside. A company that overhauls its company car policy without looking at its van fleet at the same time does the same job twice, a year apart.<\/p>\n\n\n\n The second observation is about time. A company that runs these three workstreams alone spends a quarter on them, largely because it discovers the questions as it goes and decides several of them twice. Those questions, however, are broadly the same from one employer to the next: we have already met them, settled them and written them down elsewhere. That is precisely what we support<\/a>, and the gain lies less in compliance than in the weeks saved.<\/p>\n\n\n\n The risk, for a Belgian employer with 50 employees or more, is not misapplying a law whose details are not yet known. It is arriving in January with a legal obligation, a public deadline, and no cost data with which to build an offer.<\/p>\n\n\n\n The legislative timetable may still slip. A company’s ability to answer its own employees is built now.<\/p>\n\n\n\n Legislative status checked on 26 August 2026: draft bill only, no bill tabled in the Chamber, no publication in the Belgian Official Gazette.<\/em><\/p>\n","protected":false},"excerpt":{"rendered":" Four months remain before 1 January 2027, and the bill that is meant to make the mobility budget mandatory still has not been voted. The draft bill was approved by the Council of Ministers on 9 January 2026. On the same day it was sent for opinion to the Council of State, the National Labour […]<\/p>\n","protected":false},"author":3,"featured_media":4069,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-4078","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-post"],"acf":[],"yoast_head":"\nThe framework, for those starting from scratch<\/h2>\n\n\n\n
What is not settled<\/h2>\n\n\n\n
On the 50 % cap, our position is not neutral<\/h2>\n\n\n\n
The three workstreams that do not depend on the text<\/h2>\n\n\n\n
1. Know what your car policy actually costs<\/h3>\n\n\n\n
2. Write the car and mobility policies<\/h3>\n\n\n\n
1. A principle clause in the policy<\/h4>\n\n\n\n
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2. Clear communication, at two specific moments<\/h4>\n\n\n\n
3. Support for the complex choices, and follow-up<\/h4>\n\n\n\n
And the mobility budget works perfectly well with a car<\/h4>\n\n\n\n
Three points of framework, for completeness<\/h4>\n\n\n\n
3. Build the pillar 2 offer, and its management tool if there is one<\/h3>\n\n\n\n
What we see in the field<\/h2>\n\n\n\n
What we take from this<\/h2>\n\n\n\n
\n\n\n\nSources<\/h2>\n\n\n\n
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