Belgium Pay Transparency Law: EUPTD Transposition Status
Local term: loontransparantie / transparence salariale
As of 28 September 2026: Belgium has not published a federal bill covering private-sector employers. It asked the European Commission for a six-month extension in June 2026. Regional transposition so far covers parts of the public sector only.
Status snapshot
| Status | No draft yet |
|---|---|
| National instrument | No federal bill published. Belgium requested a six-month extension in June 2026. The French Community and Flanders have transposed parts for their public sectors. |
| Official source | No draft legislation published at last check (28 September 2026). |
Pay gap reporting required before the Directive
Pay structure analysis report
| Who reports | Employers with 50+ employees |
|---|---|
| How often | Every two years |
| What is reported | Analysis of pay and benefits by gender, job grade and other characteristics |
| Published or internal | Internal. Discussed with the works council |
| Legal basis | Gender Pay Gap Act of 22 April 2012 |
| Official guidance | Gelijkheid Vrouwen-Mannen: de loonkloof (FPS Employment) |
Social balance sheet
| Who reports | Companies filing annual accounts with the National Bank of Belgium |
|---|---|
| How often | Annually |
| What is reported | Staff costs and headcount broken down by gender |
| Published or internal | Public, filed with the National Bank of Belgium |
| Legal basis | Gender Pay Gap Act of 22 April 2012 and company accounting rules |
When Directive (Article 9) pay gap reporting starts
Article 9 reporting covers seven indicators: the mean and median gender pay gap, the mean and median gap in variable pay, the proportion of women and men receiving variable pay, the proportion of women and men in each pay quartile, and the gender pay gap by category of workers.
Not yet legislated.
Things to work on now
- Priority for Belgium. Keep your biennial pay structure analysis (50+ employees) up to date. It is the closest existing process to Directive reporting.
- Priority for Belgium. If you employ public-sector staff in Flanders or the French Community, check the regional rules that already apply.
- Use the Directive as your baseline. The Directive sets minimum requirements (Articles 4 to 10) that national law must include, so preparation is not wasted.
- Job architecture. Build or review gender-neutral job evaluation so you can group roles into categories of workers doing work of equal value (Article 4).
- Data readiness. Check your HR and payroll systems can produce the Article 9 indicators, including variable pay and gaps by category of workers.
- Contracts and recruitment. Review pay secrecy clauses and pay history questions now, as these changes carry little cost.
- Review date. Set a date to check for a published bill, as national timelines can move quickly.
Legislative timeline
- 2024French Community partially transposes for its public sector
- June 2026Federal government requests a six-month extension
- 12 June 2026Flemish Parliament ratifies partial (public sector) transposition
Frequently asked questions
Has Belgium transposed the EU Pay Transparency Directive?
Belgium has not published a federal bill covering private-sector employers. It asked the European Commission for a six-month extension in June 2026. Regional transposition so far covers parts of the public sector only.
When does gender pay gap reporting start in Belgium?
Some reporting already applies under national law: employers with 50+ employees produce a pay structure analysis every two years, and companies filing annual accounts include pay by gender in their social balance sheet. Reporting under the Directive (Article 9), including gaps by category of workers, is not yet legislated in Belgium.
What should employers in Belgium do now?
Keep your biennial pay structure analysis (50+ employees) up to date. It is the closest existing process to Directive reporting. If you employ public-sector staff in Flanders or the French Community, check the regional rules that already apply. The Directive sets minimum requirements (Articles 4 to 10) that national law must include, so preparation is not wasted.