Guide on Pay Transparency in Belgium (transparence salariale/loontransparantie) for Employers

Belgium has positioned itself as a proactive adopter of the EU Pay Transparency Directive, publishing its draft legislation on March 15, 2025. Building on its existing gender pay gap reporting framework, Belgium’s approach combines stringent transparency rules, aggressive pay gap remediation thresholds, and enhanced social dialogue mechanisms. This guide outlines the key requirements and strategic considerations for employers preparing for the June 2026 implementation deadline. 

For those new to the EU directive's fundamental principles, our comprehensive overview provides essential background before diving into Belgium's specific implementation.

Legislative Framework and Timeline

Belgium’s draft law integrates the EU directive into its Gender Pay Gap Law of 2012, expanding existing obligations while introducing novel requirements. Key milestones include:

• June 30, 2025: Conclusion of parliamentary committee debates on the draft law.
  
• December 2025: Expected final approval by the Federal Parliament.
  
• June 7, 2026: Full implementation deadline aligned with EU requirements.
  
  

Unlike the Netherlands’ minimalist approach, Belgium is pursuing “gold-plated” implementation, adding stricter rules than the directive mandates. Notably, the 5% pay gap threshold triggering corrective action is reduced to 3% in the Belgian proposal, reflecting the country’s ambition to lead on pay equity.

Belgium's approach differs significantly from other EU member states, as our country-by-country implementation tracker demonstrates.

Enhanced Transparency Obligations

Recruitment and Salary Disclosure

The draft law introduces sweeping changes to hiring practices:

• Employers must publish minimum and maximum salary ranges in all job postings, including those on third-party platforms.
  
• Collective bargaining agreements (CBAs) applicable to the role must be referenced in vacancy notices.
  
• Questions about candidates’ prior compensation history are banned during recruitment processes.
  

These requirements will force many organizations to abandon outdated recruitment approaches that perpetuate pay inequities.

Employee Rights to Pay Data

Employees gain unprecedented access to compensation information:

• Right to request written details of their individual pay components (base salary, bonuses, allowances) within 30 days.
  
• Access to gender-disaggregated median pay figures for their role and comparable positions.
  
• Protection against retaliation for discussing pay with colleagues or exercising transparency rights.
  

Tiered Reporting Requirements

Belgium’s framework introduces phased reporting aligned with EU thresholds but adds granular disclosure rules:

Employers with 250+ employees:

• Annual reporting starting June 2027.
  
• Must disclose gender pay gaps in base salary, bonuses, stock options, and non-monetary benefits.
  
• Include workforce distribution across pay quartiles by gender and job category.
  

Employers with 150–249 employees:

• Triennial reporting from June 2027.
  
• Disclose median gender pay gaps and proportion of women/men receiving variable pay.
  

Employers with 100–149 employees:

• Triennial reporting from June 2031.
  
• Report average pay gaps and justify disparities exceeding 3%.
  

All reports must be submitted to the Institute for the Equality of Women and Men and shared with employee representatives.

These new reporting obligations will require companies to integrate transparency metrics into their annual compensation review processes.

Pay Gap Remediation Protocol

Belgium’s 3% threshold for unexplained pay gaps triggers one of Europe’s most rigorous correction processes:

1. Mandatory Joint Pay Assessment

1. Employers must conduct a detailed audit with employee representatives within three months of identifying a gap.
   
2. Analysis must cover hiring practices, promotion rates, and allocation of variable pay.
   

2. Corrective Action Plan

1. Develop measurable targets to eliminate disparities within 12 months.
   
2. Submit progress reports quarterly to Works Councils and the Institute.
   

3. Financial Penalties

1. Fines up to €25,000 per violation for non-compliance.
   
2. Repeat offenders face publication of violations on a government “name and shame” register.
   

Organizations should conduct preemptive pay equity analyses to identify and address potential gaps before they trigger mandatory remediation.

Integration with Existing Systems

Belgium harmonizes the directive with two established mechanisms:

Biennial Pay Gap Analyses

• Already mandatory for employers with 50+ employees since 2012.
  
• Expanded to include intersectional analysis of pay gaps by age and nationality.
  

Gender Mainstreaming Reports

• Companies with 150+ employees must now include pay transparency metrics in their annual gender equality reports.
  
• Requires approval from both the Works Council and company management.
  

Enforcement and Social Dialogue

The Institute for the Equality of Women and Men gains enhanced authority:

• Conduct random audits of employer pay records.
  
• Issue binding orders to modify non-compliant pay structures.
  
• Maintain a public database of anonymized pay gap reports.
  

Works Councils see their role expanded to:

• Approve methodology for pay gap calculations.
  
• Monitor implementation of corrective action plans.
  
• Request external audits of pay structures at employer expense.
  

Forward-thinking organizations are already developing comprehensive business cases for transparency initiatives to secure leadership buy-in and budget allocation.

Strategic Preparation Steps

Pay Structure Alignment

• Map all roles using the BELGAM job classification system, Belgium’s standardized framework for equal work evaluations.
  
• Conduct preemptive pay audits to identify gaps exceeding 3%.
  

Recruitment Process Overhaul

• Implement software solutions to automate salary range disclosures in job postings.
  
• Train hiring managers on prohibited recruitment questions and bias mitigation techniques.
  

Data Infrastructure Development

• Upgrade HR systems to track and disaggregate compensation data by gender, age, and job category.
  
• Develop templates for EU-compliant reporting in French, Dutch, and German.
  

Social Partner Engagement

• Initiate dialogue with unions on pay structure reviews.
  
• Schedule mandatory training sessions for Works Council members on pay transparency rights.
  

Contextualizing Belgium’s Pay Equity Landscape

Belgium’s 2023 gender pay gap of 5.8% (versus the EU average of 12.7%) masks persistent disparities in senior roles and high-paying sectors. For example:

• Women hold only 22% of C-suite positions in Belgian multinationals.
  
• The gender bonus gap exceeds 25% in financial services.
  

The directive’s focus on variable pay transparency targets these entrenched inequities, requiring disclosure of stock option allocations and performance pay criteria.

Conclusion

Belgium’s implementation of the EU Pay Transparency Directive represents a paradigm shift in compensation management. By setting stricter thresholds than the EU minimum and empowering social partners, Belgium aims to accelerate progress toward pay equity. Compensation professionals must prioritize pay structure audits, data system upgrades, and proactive engagement with Works Councils. Organizations that embrace these changes early will not only ensure compliance but also strengthen their employer brand in Belgium’s competitive labor market.

With the draft law expected to finalize in late 2025, employers have a narrow window to prepare. Those who view transparency as an opportunity rather than an obligation will be best positioned to attract top talent and foster equitable workplace cultures.