On December 16, 2024, the Ministerial Committee for the fight against fiscal and social fraud approved the Action Plan Fight against Social Fraud 2025-2026, drafted by the responsible government members. Based on the Strategic Plan 2022-2025, this action plan outlines the priority measures to be taken in 2025 and 2026 to combat fraud in social contributions and/or benefits. However, given this action plan was developed during the period in which the government was in ‘current affairs’, no new policy actions were included in this plan.
The 2025-2026 Action Plan is built around the seven strategic objectives outlined in the Strategic Plan 2022-2025. This action plan includes a series of actions to tackle fraud in social dumping, social contributions and social benefits, ensuring the financing of social security, and which are aimed at achieving the strategic objectives. Some key elements of the action plan include program operations to combat social fraud, a strong focus on working conditions and workplace welfare, enhanced training initiatives, awareness and media campaigns, collaboration protocols, FCPs, spot inspections and an emphasis on data mining and information exchange.
In this alert, we will provide a high-level overview of each of the seven strategic objectives and the key actions to achieve them.
1. Reduce social fraud and social dumping by strengthening European and international collaboration
In the period 2025-2026, the Strategic Committee of the Social Intelligence and Investigation (SIIS) will focus on strengthening collaboration between national government services in an increasing number of thematic areas and topics. To this end, it will make use of the experience and knowledge both at national level (the various social inspection services and other government services such as Federal Public Service Finance, Immigration Office, Police, CFI, …) and at international level (the network of National Liaison Officers within ELA). By making use of a strong network of NLOs, the social inspection services will be able to build strong links and contacts with the national authorities of other Member States and will enable national social inspection services to organise cross-border collaboration more effectively and efficiently in sectors susceptible to fraud. The SIIS will further provide conceptual, logistical and technical support to collaboration meetings or projects, including staff visits between two or more Member States on specific topics.
A few of the following actions are -among others- laid down in the action plan to achieve this objective:
2. Ensuring the competitiveness of our companies and thus guaranteeing fair competition
This strategic objective mainly involves policy actions to be determined and implemented at the level of the responsible policy departments and evolves around the administrative enforcement -in addition to criminal enforcement- to prevent organised crime, primarily through preventive interventions and measures. The goal is to translate this objective into policy actions as soon as a new government is in place. The SIIS wants to obtain this objective by giving special attention to administrative enforcement.
3. Creating an inclusive labour market that guarantees occupational health and safety at work for all workers
The National Labour Council (NLC) emphasizes that combating discrimination is a key approach to promoting access to the labour market. The NLC highlights the connection between fighting discrimination and addressing social fraud. In this context, the relevant social inspection services utilize data mining techniques to combat discrimination within the available budgetary and legal constraints. Focus areas in this domain will be the recently legalised sex work sector under employment contract, the service voucher providers, the working time rules for Medical-Specialists in training and the temporary work agencies.
4. Strengthening the inspection services to ensure greater capacity and scope to act
This objective includes 6 operational goals. The focus is on increasing knowledge and sharing information as well as fighting against organised social fraud and social crime (human trafficking), undeclared work and contribution fraud (including social engineering, with a specific focus on courier services, gig- and sharing economy, sham internships, etc.), bogus statutes (sham self-employed and sham employed statuses), wrongfully awarding benefits and fictitious performances of healthcare providers. Several actions are set out in the action plan to achieve these goals, such as a joint integration path across the various social inspection services, the inspection of working hours, NEO spot inspections, targeted investigations among benefit recipients (with a focus on unemployment and incapacity benefits), investigations among beneficiaries of incapacity and healthcare benefits based on final NISSE decisions regarding ‘non-submission’, inspection of cumulative benefits (career break/time credit) with other income and of abuse of temporary unemployment (unemployment benefit).
5. Simplification of administration (including digitalisation) and legislation, and improvement of information to increase transparency, prevent unintended irregularities and combat social engineering
The social partners and social dialogue bodies stress the importance of administrative simplification and clear regulations. The High Council for the Self-Employed and SMEs (HCSSME) has called for these issues to be prioritized by the government. The GMC highlights that some violations arise from a lack of knowledge due to complex legislation and administrative procedures. Similarly, the National Institute for Health and Disability Insurance Service for the Evaluation and Testing of Medicinal Products (NIHDI MEIS) supports efforts to prevent administrative errors. Additionally, within the framework of the federal action plan for Administrative Simplification, administrations have the opportunity to submit proposals, though these are not part of the current action plan.
6. Increasing the risk of being caught and improving the effectiveness of sanctions
The HCSSME is in favour of focusing more on connecting the databases of the various government authorities and inspection services, thereby enabling more targeted inspections thanks to this data and the use of new technologies (datamining and -matching). The SIIS and social inspection services’ data-driven approach can help address this. The GMC also emphasises the need for proportional sanctions, considering the intentional nature of violations and prefers sanctions tailored to the specifics of each violation.
This objective can be attained by continuing the activities of the SIIS Working Group to draw up a multilateral Benelux Treaty on combating social fraud, automate information exchange with FPS Finance and collaborating and exchanging data with the police services.
7. Preventing social fraud
The two operational goals of this last objective are: gathering statistical data and conducting or commissioning studies on working conditions and the labor market at both macro and micro levels and continuing the sectoral approach by updating existing agreements and enhancing preventive tools. The SIIS wishes to achieve these goals by, amongst others, gaining a better insight into the scale and profile of social fraud and social dumping, implementing the Fair Competition Plans (FCPs) and spot inspections.
It will be up to the new government to tangibly address the objectives in the combatting of social fraud for the benefit of our society. Do note that, since the Strategic Plan 2022-2025 remains in effect until the end of 2025, this action plan is only valid until a new strategic plan is established by the new government.
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
Nadja De Bie
Senior Manager
Martijn De Meulemeester
Director
Simply follow our Vialto Alerts page on LinkedIn and posts will be displayed on your feed. To ensure you don’t miss one, once you’re on our LinkedIn page, click on the bell icon under the banner image to manage your notifications.
Further information on Vialto Partners can be found here: www.vialtopartners.com
Vialto Partners (“Vialto”) refers to wholly owned subsidiaries of CD&R Galaxy UK OpCo Limited as well as the other members of the Vialto Partners global network. The information contained in this document is for general guidance on matters of interest only. Vialto is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information is provided “as is”, with no guarantee of completeness, accuracy, timeliness or of the results obtained from the use of this information, and without warranty of any kind, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose. In no event will Vialto, its related entities, or the agents or employees thereof be liable to you or anyone else for any decision made or action taken in reliance on the information in this document or for any consequential, special or similar damages, even if advised of the possibility of such damages.
© 2025 Vialto Partners. All rights reserved.