Immigration

Belgium | Flanders labour migration reforms approved for 2026 applications

Summary

The Flemish Government approved proposed changes to labour migration rules on 28 November 2025, which will apply to applications submitted from 1 January 2026. The framework will be stricter and more evidence-based, prioritising local and EU hiring and tightening checks on job content, shortages and qualifications. With publication and further implementing measures still pending, employers preparing 2026 work permit applications will need to align their processes with the new framework.

The detail

Zuhal Demir, the Flemish Minister for Education, Justice and Work, had proposed several significant changes to the labour migration policy in Flanders on the 9th of May to the Flemish government. This preliminary draft has now been approved by the Flemish government on the 28th of November 2025. These new rules will apply to applications being submitted as of 1 January 2026. For more details about the substance of the concept note, please see our previous alert.

Practical considerations for employers

The approved draft confirms a clear shift towards a more selective and evidence-based labour migration system. The Flemish Region places stronger emphasis on activating the local and European labour market first (concentric model), while continuing to allow labour migration where genuine shortages exist. At the same time, additional administrative safeguards are introduced to strengthen fraud prevention, improve case handling and protect migrant workers from abuse.

The decision also confirms that labour market indicators, recruitment efforts and the actual content of the role will play a more prominent role in assessing applications across categories. In this context, the following action points are relevant for employers:

1. Ensure the job content supports the category: Under the new framework, authorities will focus more strongly on the actual function performed. For highly skilled workers, this means that the role itself must qualify as highly skilled, regardless of whether the diploma was obtained in the same field as the function. Employers should therefore ensure that the Belgian employment contract clearly and accurately reflects the level and function-qualification of the position. This information does not have to be included in case of a secondment to Belgium, where there is no Belgian local employer.
2. Prepare for more thorough qualification checks: The approved decision allows authorities to verify the authenticity of foreign diplomas and qualifications. Employers should anticipate possible requests for additional information and ensure that relevant documents can be obtained from educational institutions or competent authorities abroad.
3. Reassess middle-skilled eligibility early: Middle-skilled labour migration will remain limited to occupations appearing on the Flemish shortage list, which is now based on objective labour market indicators and reviewed regularly. Furthermore, on the 8th of December a new shortage list was published, now reducing the list to 21 functions. For the ‘other’ category, the authorities have excluded lower-skilled roles (VKS 1 and 2) from labour migration altogether. Only middle-skilled functions will be considered for this category as of 1st January 2026.
   Employers should verify eligibility at an early stage and confirm that both the role and the candidate meet the required qualification and salary thresholds before initiating an application.
4. Anticipate additional application costs: The Flemish Government has approved the introduction of a retribution fee for work authorisation applications, including renewals. Although the exact launch date and payment modalities still need to be published, employers should already account for this additional cost for 2026. This retribution fee will most likely be introduced as of Q2 2026.
   This fee will only be required for single permit applications and not for work permit applications and will most likely amount to EUR 200 per application.
5. Introduction of work permits to the Unique Counter: The authorities also confirmed that the application of work permits will move to the unique counter in 2026. It still remains to be seen what the exact date will be of this introduction. This introduction will be done gradually, with a transitional measure, and the paper application will eventually be phased out.

What this means

With these new changes, the restrictive direction of Flemish labour migration policy has been formally confirmed. Although publication and further implementing measures are still pending, employers preparing applications for 2026 should already adapt their processes to align with the new framework.

We will continue to monitor the publication of further implementing measures and will keep you informed of any further developments. If you would like support assessing upcoming applications or adjusting your labour migration strategy, please do not hesitate to contact us.

Contact us

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

Ajshe Miftari
Director Immigration

Fabian Gielis Senior
Associate Immigration

Want to know when a Regional Alert is posted?

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.

© 2026 Vialto Partners. All rights reserved.