Pay transparency, mobility budget and more: the HR changes at a glance

In this article, we list the most important changes. For each topic, you’ll read what is changing, what it means in practice and where you should start today. That way, you immediately get the building blocks for your HR action plan for 2027.

1. Pay transparency: from “competitive salary” to a concrete pay range

With a European directive, Europe aims to tackle unequal pay between men and women. In Belgium, women still earn around 7% less than men on average, taking differences in working hours into account (IGVM, 2025). Belgium had to transpose the directive by 7 June 2026, but that deadline has passed without Belgian legislation. The main outlines, however, are already set (Directive (EU) 2023/970):

• Applicants see the salary or pay range before the job interview, and you can no longer ask about their previous salary.
• Employees can request the average pay for work of equal value, broken down by gender.
• Pay and pay progression are based on objective, gender-neutral criteria.
• If pay discrimination is suspected, the employer must prove that the difference is justified.
• From 100 employees, a reporting obligation on the gender pay gap applies. It is phased in: from 250 employees every year, starting in 2027. Between 150 and 249 employees every three years, also starting in 2027. Between 100 and 149 employees every three years, starting in 2031 (Art. 9 Directive (EU) 2023/970).

In practice, this is the biggest change for many SMEs in the years ahead. Their pay policy has often grown organically. A higher offer to win over a candidate, a raise after a good conversation, a benefit once granted to a single employee. Each decision was defensible on its own, but together they rarely form a system you can explain objectively. And that is exactly what the directive requires.

The first step? Group your roles into categories and record, for each category, what you base pay on.

2. Social inspection: make sure the basics are right

From our clients’ questions, we also notice that the social inspection services seem to be visiting more often. They look at both the application of labour law and wellbeing at work. During such an inspection, you must at least be able to present the following:

• Up-to-date work regulations with all work schedules, the mandatory annexes (such as those on psychosocial risks) and proof that they are available to everyone.
• Valid employment contracts for all your staff, including part-time employees, students and flexi-job workers.
• Proof of timely and correct Dimona declarations when employees join and leave.
• Social documents, such as individual accounts and payslips.
• Valid occupational accident insurance.
• The schedules of part-time employees and the record of any deviations from them.
• Control cards for (temporarily) unemployed employees.
• Your membership of an external service for prevention and protection at work.
• A general overall risk analysis.

Collecting these documents shouldn’t be a problem, but in reality we often see that they don’t fit together. Think of schedules that no longer match reality, or a remote work policy that doesn’t line up with the contracts. Your payroll provider keeps track of a lot, but the content of your regulations and policies remains your responsibility. Changing your work regulations also requires a formal procedure in which your employees have a say. So don’t wait until the inspector knocks on your door.

3. Mobility budget: an obligation in the making

With the mobility budget, employees exchange their company car, or their right to one, for a budget. They can spend it on an environmentally friendly car, on sustainable mobility and housing, or have it paid out in cash. On that last option, the employee pays a special contribution of 38.07% (RSZ, 2026).

Today, offering a mobility budget is the employer’s choice. On 9 January 2026, the federal government approved a preliminary draft bill to change that (Council of Ministers of 9 January 2026). The preliminary draft provides for the following:

• Employers with at least 50 employees who have offered company cars for more than 36 months must offer a mobility budget from 1 January 2027.
• For employers with 15 to 49 employees, this applies from 1 January 2028.
• Employers with fewer than 15 employees remain exempt.
• You may wait until the car’s lease contract ends before letting an employee switch.
• For certain roles, you may require employees to choose an electric car, based on objective and non-discriminatory criteria.

The final legal text has yet to follow, so the details may still change.

A mobility budget affects far more than mobility: your car policy, your lease contracts, your payroll and your cafeteria plan. And your employees will have questions. How big is my budget? Can I switch back to a car later? It’s better to have the answers ready. So make an overview of your company cars and the end dates of your lease contracts.

4. Copyright: once again an option for software developers

In 2023, the IT sector was excluded from the favourable tax regime for copyright. The law of 15 July 2026 changes that. With retroactive effect to 1 January 2026, software, databases and technical documentation can once again fall under the regime (ITAA, 2026).

The copyright portion of the remuneration is taxed at 15%, up to €77,220 per year (income year 2026). That portion may, however, account for no more than 30% of the total remuneration, and it must concern an original, protected creation (VLAIO, 2026).

In practice, this once again makes it an attractive way for IT employers to pay their people, but the case must be well documented. Without clear contractual agreements, the remuneration for software is deemed to be already included in the salary.

The common thread: a policy you can explain

They may look like four separate topics, but they all ask for the same thing: an HR policy that is documented, objective and up to date. And that clashes with reality. In our conversations with clients, we regularly see that the basics are not quite in order. Work regulations that are out of date, contracts that don’t match day-to-day practice, and policies that are missing or contradict each other. Those who do have the basics in place will handle new regulations much more smoothly.

A good job classification helps you with pay transparency, but also with your mobility policy. Up-to-date work regulations are your best preparation for an inspection. That’s why you get more out of one HR action plan than out of four separate solutions.

At Unikoo, we bring order to the chaos with a tailor-made HR action plan. We do this in three steps:

1. Analysis: we map your current situation, from regulations and contracts to policies and processes. That way, you immediately see what is in order and where the gaps are.
2. Action plan: you get a clear overview with priorities, timing and who does what.
3. Implementation: we manage the plan, help develop your HR policy and policies, and coordinate with the right partners, such as your payroll provider or a social law advisor.

Curious where your HR stands? Feel free to contact us and discover what an HR action plan can mean for your business.