Global Mobility Tax

Belgium | Global Mobility Tax | Mandatory Mobility Budget: period of acclimatisation

Summary

As announced in previous posts, employers will have the obligation to offer a Mobility Budget to all employees who are entitled to a company car. The initial and theoretical date of entry into force (of the revised legislation and mandatory character of the federal mobility budget) is 1 January 2026. However it is expected that 2026 will be a year of acclimatisation and transition, allowing companies to get ready and implement the mobility budget by 1 January 2027. For small and medium sized enterprises with 15 to 50 employees, extra implementation time would be granted until 1 January 2028. Companies with less than 15 employees would even be fully exempted from this obligation. The good thing is that companies still have more time to prepare for this important Comp & Ben shift in 2026, which will require attention from their HR, payroll and legal teams.

Getting ready for the launch of the mandatory mobility budget

What is the mobility budget?

Introduced in 2019, the Mobility Budget is a flexible and tax-efficient compensation scheme designed to promote sustainable commuting. It allows employees who are entitled to a company car to exchange it—or opt not to take one—in return for a flexible budget. This budget can be spent across three pillars:

• Pillar 1—Eco-friendly company car: Leasing or purchasing of (lower category) zero-emission vehicle (i.e. 100% electric company car as from 1 January 2026)
• Pillar 2—Sustainable transport (soft mobility) solutions & housing: Fiscal and parafiscal beneficial means of public transport (for the employee and/or family), shared mobility, bicycles, and even fiscal and parafiscal beneficial reimbursement of housing costs (rent or mortgage interest) if the employee lives within 10 km of the workplace
• Pillar 3—Cash-out: Any unspent budget at the end of the year can be paid out as cash, subject to a special social security contribution of 38.07% in the hands of the employee

In the longer term, the government may even aim to extend the Mobility Budget to all employees, not just those entitled to a company car, ultimately making it a universal obligation for employers. How in
that situation the mobility budget will be created for employees not benefitting from a company car is currently unknown.

Why is the mobility budget now relevant more than ever before?

While this has not yet been transposed into law and key details still remain unclear, the direction is clear: at some point, employers will no longer have the option to choose whether or not to implement the Mobility Budget. Despite the absence of new legislation in this respect, organisations that have not yet taken preparatory action in 2025, can now still act to get ready and consider which elements they want to include in their employee mobility solution. There is still a bit more time to prepare for it, at least during 2026.

Council of Ministers gives further bearing

Currently, no draft texts are publicly available and it is to be seen what the final outcome of the legislative process will be in the upcoming months. However, at the end of 2025, the council of ministers agreed on certain points regarding the implementation of the mandatory mobility budget. What was agreed upon?

• Timing: The federal mobility budget will become mandatory for companies that offer one or more company cars during more than 36 months. When exactly will the budget become mandatory? This will depend on the size of the company. Companies with 50 employees or more (i.e. large companies) would be required to effectively implement the mobility budget as of 1 January 2027. For small and medium-sized enterprises (SMEs) with 15 to 50 employees, there would be a one year extension, meaning that they would need to implement the mobility budget by 1 January 2028. However, for companies with less than 15 employees, there would be a full exemption. Other exemptions to the mandatory mobility budget would be foreseen for well-defined specific situations, notably for companies in difficulties and companies who are in the process of collective dismissal.
• Pillars: it is anticipated that, based on objective criteria, companies will be able to require certain categories of employees to choose for an electric company car within pillar 1 of the mobility budget. These criteria must be justified and directly related to the nature of the job performed and/or the legitimate interests of the company. Think about functions that require the permanent availability and use of a company car. It is not clear (and still needs to be decided) to what extent there will be changes to the potential choices that can be made in pillar 2.

How can Vialto Partners support?

• Monitoring legislation: Vialto Partners closely tracks all legislative developments. You will receive timely updates and alerts when new obligations are published. We interpret legal uncertainties and provide clear guidance.
• Policy drafting: We can assist in drafting/reviewing and (re)shaping your Mobility Budget & Company Car policy, ensuring it complies with legal requirements and aligns with your remuneration and employee mobility strategy. This can include general policy, individual agreement annexes, and guidance on combination with existing cafeteria plans.
• Strategic consulting: Employers have flexibility in defining the benefits offered under pillar 2 of the Mobility Budget. Not all options are mandatory. We will help you tailor the scheme to your workforce’s real mobility needs and your company’s strategy, maintaining consideration for employees who require a company car as a working tool.
• Payroll support: Our payroll experts can either review your existing payroll setup or handle the full implementation of the dedicated payroll account required for the Mobility Budget. We ensure a seamless integration that meets both legal and operational requirements. We can organise workshops for your teams to explain the Mobility Budget, answer questions, and facilitate internal alignment.

Contact us

For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:

Martijn De Meulemeester
Director

Filip Van Praet
Director

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