Pay transparency: Belgian transposition incomplete
Sources consulted as of 30 septembre 2026 do not establish that general federal transposition for the private sector is complete. Belgium’s request for six months concerned infringement proceedings and did not change the European deadline.
In his reply of 15 juin 2026, point 03.10 of the proceedings, the Minister of Employment confirms that work is continuing and no precise timetable can be announced. He distinguishes a request to suspend the infringement procedure deadline for six months from an extension of the transposition deadline.
The minister notes that Belgian legislation on discrimination and the pay gap remains applicable. He explains that, in principle, an untransposed directive does not directly create obligations between private parties. Do not present this delay as permission to discriminate or extend this analysis to public employers.
An analysis dated 17 septembre 2026 still reports no federal draft legislation and highlights the possible effects of interpreting national law in line with the directive: https://pkfbofidi.com/loontransparantie-belgie-zonder-omzettingswet/. Federated entities have notified partial measures, but these do not establish full federal transposition. Before stating that a new Belgian obligation applies to a client, check the published text and its scope.