The Flemish government has published a package of immigration measures that will take effect on 1 January 2026 and fundamentally change how companies engage foreign labour in Belgium’s northern region. Under the new rules, every company in a supply chain – from prime contractor to the last sub-contractor – will be liable if an illegal third-country national is discovered anywhere in that chain. “Declaratory” clauses in contracts are no longer enough; contractors must actively request and retain proof of valid work and residence status for all posted or hired workers. Failure to do so can trigger fines of up to €48,000 per undocumented worker and temporary suspension of the offending project.
At the same time, the Flemish Minister for Employment is closing several labour-migration pathways for lower-skilled roles. Occupations that cannot be shown to be in genuine shortage will again require labour-market tests, and employers must advertise vacancies for at least five weeks through regional job portals before they may file a single-permit application. Sectors that have relied heavily on non-EU seasonal or hospitality staff are expected to feel the immediate pinch.
The reforms align with Flanders’ policy of favouring highly-skilled and medium-skilled shortage occupations while urging employers to “recruit locally first.” For global mobility managers, the message is clear: plan Belgian assignments further ahead, budget for longer lead-times, and audit subcontractors’ compliance documentation. Multinationals running pan-European projects in construction, logistics or IT outsourcing will need new contractual clauses assigning documentation duties and indemnities throughout the chain.
![Flanders Tightens Chain Liability and Narrows Low-Skilled Work Permit Routes from 1 January 2026]()
Amid these fast-approaching changes, companies can lighten the administrative load by partnering with VisaHQ. The firm’s Belgium portal (https://www.visahq.com/belgium/) offers step-by-step guidance on single-permit applications, automated reminders for document renewals, and consolidated dashboards that make it easier to monitor subcontractors’ compliance – a useful safeguard when fines now reach €48,000 per undocumented worker.
Adding to the cost, the region signalled it will introduce a separate government processing fee – on top of the federal immigration levy – for single-permit applications later in 2026. Companies that routinely rotate staff through Belgian projects should revisit cost projections now, or risk unpleasant budget overruns next year.
Despite business-lobby requests for a transition period, officials confirmed on 17 December that no grace period will be granted. Applications filed on or after 1 January 2026 will be assessed against the tougher standards, while in-flight files will be processed under the current regime. Employers therefore have two weeks to lodge any final applications under existing, more flexible rules.
At the same time, the Flemish Minister for Employment is closing several labour-migration pathways for lower-skilled roles. Occupations that cannot be shown to be in genuine shortage will again require labour-market tests, and employers must advertise vacancies for at least five weeks through regional job portals before they may file a single-permit application. Sectors that have relied heavily on non-EU seasonal or hospitality staff are expected to feel the immediate pinch.
The reforms align with Flanders’ policy of favouring highly-skilled and medium-skilled shortage occupations while urging employers to “recruit locally first.” For global mobility managers, the message is clear: plan Belgian assignments further ahead, budget for longer lead-times, and audit subcontractors’ compliance documentation. Multinationals running pan-European projects in construction, logistics or IT outsourcing will need new contractual clauses assigning documentation duties and indemnities throughout the chain.
Amid these fast-approaching changes, companies can lighten the administrative load by partnering with VisaHQ. The firm’s Belgium portal (https://www.visahq.com/belgium/) offers step-by-step guidance on single-permit applications, automated reminders for document renewals, and consolidated dashboards that make it easier to monitor subcontractors’ compliance – a useful safeguard when fines now reach €48,000 per undocumented worker.
Adding to the cost, the region signalled it will introduce a separate government processing fee – on top of the federal immigration levy – for single-permit applications later in 2026. Companies that routinely rotate staff through Belgian projects should revisit cost projections now, or risk unpleasant budget overruns next year.
Despite business-lobby requests for a transition period, officials confirmed on 17 December that no grace period will be granted. Applications filed on or after 1 January 2026 will be assessed against the tougher standards, while in-flight files will be processed under the current regime. Employers therefore have two weeks to lodge any final applications under existing, more flexible rules.
