Immigration 

Belgium |  Proposed changes by Flemish Minister Zuhal Demir on the Flemish labour migration policy

Summary

Zuhal Demir, the Flemish Minister for Education, Justice and Work, has proposed several significant changes to the labor migration policy in Flanders, in her ‘conceptnota’, introduced on the 9th of May to the Flemish government. The changes that were proposed by the Minister and her cabinet are aimed at attracting and retaining qualified talent in Flanders.

The detail

In Belgium, local governments have powers in respect of specific policy areas. This includes labor migration policy in the Flanders region. As a result, the Flemish Minister for Education, Justice and Work, has proposed several significant changes to the labor migration policy in Flanders. Below you will find a non-exhaustive list of the changes that were proposed by the Minister:

General changes

• An employer retribution fee will be introduced for work authorisation applications in Flanders from 1 January 2026, similar to the system used for professional cards. The proposed fee would amount to EUR 200 and will be subject to yearly indexation. This will apply to single permit applications, both first applications, as well as renewal applications. This contribution covers administrative costs and supports investments in additional capacity, high-quality case handling, and modern technology and IT systems. These improvements will enhance control mechanisms, improve fraud detection, and help protect foreign workers from exploitation, while also safeguarding Flemish companies from unfair competition.
• Intent to protect migrant workers from exploitation, by informing these individuals about their rights and duties in the labour market and society and strengthen their legal status. 

Changes in the highly skilled category

• A fast-track procedure (“fast-lane”) is proposed for highly skilled workers as of 1 May 2025, ensuring priority processing of applications within a maximum of 15 days, for this specific category of applications. The proposal also deems that a reference system is no longer needed, given this expedited processing time.
• Because the single permit process involves both regional (authorization for employment) and federal (authorization for residence) decisions, close cooperation with the federal Immigration Office is essential. Ongoing discussions aim to improve overall efficiency and shorten processing times, for example through the parallel handling of admissible applications.
• A work authorization in the highly skilled worker category will only be granted if the position to be filled matches the level of higher education required.

Changes in the lower- and middle skilled categories

• For lower-skilled (bottleneck) functions classified under VKS (Flemish Qualification Structure) level 2, it will no longer be possible to apply for a single permit. These roles will be excluded from the “other” category. We can derive from this that the ‘Other’ category remains possible for individuals with a VKS level 3 or 4, taking into account the below mentioned changes.
• To obtain a work authorisation under the “other” category, the employer must demonstrate that no suitable candidates were found on the local or European labour market. This includes clear, active, and targeted recruitment efforts and openness to workplace learning, while mentioning that proof of publishing the application in line with previous requirements, will not suffice on itself to fulfill the ‘labour market test’. 
• Salary requirements for the ‘other’ category will be raised to the level applicable to middle-skilled employees.
• For non-highly skilled workers, an average processing time of 30 days (with a maximum of 45 days during peak periods) will apply as of 1 January 2026.

Conclusion

Although these proposed changes are not yet a published Decree, they reflect a clear direction toward a more concentric model for labor migration in Flanders. It remains to be seen which proposed changes are actually transposed into legislation. We will continue to monitor the legislative developments closely and keep you informed about how these changes could affect your organization. Should you have any questions or need assistance navigating these upcoming reforms, please do not hesitate to reach out.

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 

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